Cosmetic Practitioners Take Huge Risks Purchasing and Administering Illegal Botulinum Toxin Drug Products

September 2017 | Volume 16 | Issue 9 | Editorials | 936 | Copyright © September 2017

Sheldon Bradshaw JD

FDA and Life Sciences Practice Group, King & Spalding,Washington, DC

Caveat EmptorBuying counterfeit or misbranded botulinum toxin products (or other prescription drugs) from illegal internet sellers or unlicensed distributors puts practitioners (and their patients) at serious risk. The question isn’t whether, but when, the FDA, medical licensing boards, and the public will find out about these purchases. When the FDA shuts down an illegal seller, it typically looks for the seller’s customer list and will reach out to those persons. Practitioners who are purchasing from overseas internet sellers or other unapproved distributors should immediately stop doing so. These practitioners, especially if they have received an FDA letter regarding purchases of unapproved prescription drugs, should also talk to their lawyers.


Sheldon Bradshaw currently represents Allergan, Inc.


1. Beer, K, Rothschild K. Importing injectables. J Drugs Dermatol. 2014;13:9:1156.


Sheldon Bradshaw JD