Who may inject fillers and toxins in Panama: the law and the cases

The legal question: who may inject in Panama?

In Panama, injectable aesthetic medicine has no single statute that says it all; there are several pieces. The most recent is Law 491 of October 17, 2025, which regulates modeling and filler substances in medical-aesthetic treatments. According to TVN, only "qualified physicians specialized in Dermatology or Plastic Surgery", accredited by the Technical Health Council, may apply them, and only in public or private establishments authorized by the Ministry of Health (MINSA)¹. Telemetro adds that informed consents must detail the product's components, possible complications and risks². For the broader picture for physicians, see the physician's legal map in Panama.

This piece summarizes what we could verify. We could not open the Official Gazette text of Law 491; article numbers come from TVN¹.

Law 491: fines, official list and victim care

• Official list: MINSA issues the list of permitted substances (art. 4), updated every 90 days or sooner if authorities deem it necessary¹².
• Fines (art. 13): B/.10,000 for producing, advertising or donating non-permitted substances; B/.15,000 for importing, exporting or marketing them; B/.50,000 for applying them without MINSA authorization¹.
• Oversight (art. 12): MINSA receives complaints, inspects and exercises control nationwide¹.
• Victims (art. 10): medical and psychological care, including conditions such as ASIA syndrome, and protocols for safe removal of harmful substances¹.

According to the same report, the law targets mainly injectables such as biopolymers, polymers and other non-biodegradable or permanent substances¹. We found no official source clarifying whether temporary hyaluronic acid or botulinum toxin fall within that definition; that point remains open. More context in Law 491, IV drips and mycobacteria.

The legislative path had friction. In December 2024 the president partially objected to four articles; according to Panamá América, MINSA considered it incongruous to publish a list because "the only substances that should be used are those with sanitary registration"³. That connects to Law 419 of 2024: marketing a product without sanitary registration is a very serious offense, fined B/.15,001 to B/.25,000⁴.

Qualification and the Technical Health Council: what it means

The Technical Health Council dates from the Health Code (Law 66 of 1947): its article 110 provides that it is composed of Panamanian citizens and professionals legally authorized to practice, as Executive Decree 14 of 2023 (Official Gazette 29730-C) recalls⁵. Law 41 of 2002 on the Panama Medical Association requires members to have "qualification to practice the profession", to be registered with the Technical Health Council, and charges the Association with "reporting illegal practice to the competent authorities"⁶. In 2017 MINSA announced it was developing an app for the public to check whether a physician is qualified; the report does not confirm whether it was launched¹¹.

An older rule also matters: Resolution 9 of November 23, 2009 prohibits beauty salons, aesthetic centers, gyms and spas from performing invasive treatments and surgical interventions on the human body, and it was the basis for equipment seizures in 2021⁸.

Cases reported by the Panamanian press

• Pedregal (May 2021): MINSA and the Public Ministry permanently closed a clinic. The metropolitan region's public health chief said "alleged health professionals practicing medical functions without the corresponding qualification" were found; it had no operating permit and performed hyaluronic acid fillers and carboxytherapy. Three people were detained⁷.
• San Francisco (May 2021): operations at a spa where "staff practicing aesthetic medicine illegally" were found; equipment and products were seized⁸.
• Bella Vista (May 2023): two patients reported sequelae, including facial paralysis; the clinic was run by a foreign person who could not present medical degrees and held only short-course certificates. MINSA announced a complaint for illegal practice⁹.

In 2022 plastic surgeon Jorge Cowes, of the Panamanian Association of Plastic, Aesthetic and Reconstructive Surgery, told Telemetro that procedures by unqualified physicians "are on the rise" because of influencer promotion, and that authorities had told him they "have no staff or equipment" to investigate¹⁰. According to Panamá América, the Metropolitan Health Region began handling these complaints after meeting with the presidents of the Panamanian Society of Dermatology and the Panamanian Society of Plastic Surgery⁹.

Complications when people without medical training inject

The evidence is not from Panama, but it is consistent and relevant to the physician who sees the patient afterward:

• Brazil, 1,058 physicians surveyed: 12.69% of patients had been treated by nonphysician professionals; each physician saw an average of five complications a month, 17% with permanent sequelae, mainly scarring (78.68%), inflammation (72.15%) and infection (65.43%)¹².
• Fillers and the kidney: a systematic review of 29 patients with silicone, methacrylate or oil fillers (72.41% in the buttocks) found chronic kidney disease in 55.17%, surgery in 20.69% and 3 deaths; six reports named a non-medical injector¹³.
• Vision loss: a worldwide review identified 48 new published cases between 2015 and 2018, 81.3% with hyaluronic acid; complete vision recovery in 10¹⁴.
• Botulinum toxin: the CDC described 7 women with botulism symptoms after presumed counterfeit toxin in nonmedical settings (4 hospitalized, 2 in intensive care); the report recommends that it be given by licensed, trained providers¹⁵. A case series of illegal cosmetic botulism from 2014 to 2024 totaled 161 cases, half hospitalized¹⁶.

For the context of unregistered products and stem cells in the country, see the sanitary-registration double standard in aesthetics.