Tooth whitening Q & As

Tooth whitening Q & As

What is the practice of dentistry?

The practice of dentistry is limited to GDC registrants. Applying materials and carrying out procedures designed to improve the aesthetic appearance of teeth amounts to the practice of dentistry. So too does the giving of clinical advice about such procedures. Therefore all tooth whitening procedures, including bleach and laser treatment, are the practice of dentistry.

Which GDC registrants can undertake tooth whitening?

Until recently, it was the Council’s position that only dentists could undertake tooth whitening. However, it has since been decided by Council that in addition to dentists being able to carry out tooth whitening, dental hygienists, dental therapists and clinical dental technicians, on the prescription of a dentist, can carry out tooth whitening as an additional skill. 
It has also been decided that dental nurses can, as an additional skill, take impressions and make bleaching trays to a dentist’s prescription. Any registrant who undertakes work for which they are not sufficiently competent risks fitness to practise proceedings which may affect their registration.

What are the ethical considerations?

Ethical issues arise in treating patients. GDC registrants must:
  • act in the best interests of the patient in providing a high standard of care,
  • obtain fully informed consent for treatment, which they must be competent to carry out,
  • obtain a medical history of the patient before starting treatment, and
  • give necessary explanations about benefits and risks.

These and similar issues can arise in connection with any dental treatment proposed or carried out, including treatment designed to improve the appearance such as tooth whitening. They apply whether the registrant personally delivers the treatment or gives advice to patients about the use of home kits. It is open to patients to complain to the GDC about these matters, as with any form of care or treatment.


Who has indemnity/insurance cover to carry out tooth whitening?

Registrants must always check with their defence organisation or other indemnity/insurance provider, because different organisations have different rules and policies. The registration of anyone practising in any field without appropriate indemnity/insurance arrangements will be at risk. 

Tooth whitening products

On 31 October 2012, the EU Council Directive 2011/84/EU (amending EU Council Directive 76/768/EEC) came into force in the UK. It sets out who can use what strength of product when performing tooth whitening.
This directive states that the use of tooth whitening or bleaching products containing more than 0,1 % and up to 6% of hydrogen peroxide present or released from other compounds or mixtures in these products may be safe if the following conditions are satisfied:
  • an appropriate clinical examination is carried out in order to ensure there are no risk factors or any other oral pathology of concern and 
  •  that exposure to these products is limited so as to ensure that the products are used only as intended in terms of frequency and duration of application.
  • These conditions should be fulfilled in order to avoid reasonably foreseeable misuse.
It adds:
  • For each cycle of use of those products, the first use should be limited to dental practitioners, as defined under Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the recognition of professional qualifications or under their direct supervision if an equivalent level of safety is ensured.
  • Dental practitioners should then provide access to those products for the rest of the cycle of use.
We do not bring prosecutions under these regulations and is not able to offer an interpretation of the law for individuals. Dental professionals and patients should seek independent legal advice on how this affects them.

What happens if the cosmetics regulations are breached?

It is the responsibility of local Trading Standards officers to bring prosecutions under the EU Council Directive 76/768/EEC in England, Scotland and Wales. In Northern Ireland the responsibility lies with the environmental health departments of local district councils. Queries about prosecution policy should be directed to the local Trading Standards office.

Further information

A list of frequently asked questions for patients is available here.