On the 22nd, at clinic A of traditional Korean medicine in Gwangjin-gu, Seoul. Stand signs promoting skin lifting procedures were lined up in front of the entrance. Various types of skin lifting procedures were listed on the clinic's signboard and windows. All were procedures that used laser devices.
Ultra-low-price events were also underway. It advertised that procedures that normally cost at least 50,000 won on the market were offered for under 10,000 won. The notice included the phrase, "All procedures adhere to the principles of fixed dosage and genuine products."
Is it okay to get a lifting procedure at a traditional Korean medicine clinic instead of a dermatology or plastic surgery clinic? We asked people in the industry and legal circles out of sudden curiosity about whether traditional Korean medicine doctors are allowed to use cosmetic medical devices, and whether the equipment is safe and post-procedure care is properly carried out.
◇Traditional Korean medicine doctors turning to laser and ultrasound procedures
Skin lifting procedures are performed with laser devices. They work by physically stimulating tissue under the skin to induce regeneration, tightening sagging skin and promoting collagen production. There are also ultrasound and radiofrequency procedures that apply heat energy, and thread lifting, which injects medical threads.
Consumers who usually want lifting procedures go to dermatology or plastic surgery clinics, but recently, traditional Korean medicine clinics that front cosmetic procedures are also increasing. A search for "lifting traditional Korean medicine clinic" on social media (SNS) brings up more than 100 promotional posts.
More traditional Korean medicine doctors are also touting the use of medical devices such as lasers as their specialty. The Korean Society for Integrative Laser Medicine under the Korean Medical Association of Korean Medicine holds annual academic conferences and clinical special lectures.
There is no regulation that uniformly bans traditional Korean medicine doctors from using medical devices. However, depending on the principle, risk, and purpose of each device, it is necessary to determine whether the procedure falls outside the scope of a traditional Korean medicine doctor's license. As the criteria for what is allowed remain unclear, the cosmetic procedure market at traditional Korean medicine clinics is growing rapidly.
◇Laser device makers wary of "legal risk" say they won't supply
The companies that actually produce and sell lifting medical devices say they do not supply equipment directly to traditional Korean medicine clinics. All four major companies we contacted said, "We do not supply products to traditional Korean medicine clinics."
Company A announced on its website that "products and related consumables are supplied only for physicians' procedural purposes," adding, "They are not supplied for dental or traditional Korean medical treatment and procedures." Company B wrote on its device demonstration application page that "traditional Korean medicine clinics, skin care salons, and individuals cannot apply."
The biggest reason companies are reluctant to supply to traditional Korean medicine clinics is cited as legal risk. Article 27 of the Medical Service Act provides for punishment of instigating or aiding a medical professional to perform medical acts outside the scope of their license. Article 2 of the Medical Service Act defines the work of traditional Korean medicine doctors as "traditional Korean medical care and traditional Korean health guidance."
Because there are no clear criteria on whether the use of a specific lifting device constitutes traditional Korean medical care, manufacturers cannot help but worry that supplying equipment could lead to future legal disputes.
Then through what channels do traditional Korean medicine clinics acquire the equipment? One industry official said, "It may have been through used medical device dealers or wholesalers rather than direct supply from manufacturers." Under current law, medical device sellers are not restricted in their counterparties based on the type of medical institution.
◇Concerns over gaps in training and after-sales support
It is not illegal per se to purchase equipment through used dealers or separate distribution channels. One cannot conclude that the equipment is defective or that procedures are dangerous solely because the manufacturer did not supply it directly.
However, there are concerns that consumer protection could have gaps if equipment outside the manufacturer's training and after-sales support system is used. If operators do not fully understand the device's output and usage, or if they do not use genuine consumables, the risk of side effects such as burns and hyperpigmentation can increase.
It is also burdensome that responsibility can be unclear when a product malfunctions or an incident occurs during a procedure. If the manufacturer did not supply the equipment on the premise of use at a traditional Korean medicine clinic, it may be difficult to receive support for training, inspections, or responses to side effects.
On the other hand, some say it is hard to take at face value the claim that companies making lifting-related equipment do not supply to traditional Korean medicine clinics. Because opposition from physician groups is so strong, there are quite a few cases where companies choose indirect supply through dealerships.
An industry official for traditional Korean medicine doctors said, "Traditional Korean medicine clinics also use genuine products," adding, "Because dermatology clinics and others are important customers, there are quite a few companies that keep quiet about delivering products to traditional Korean medicine clinics."
◇Debate over traditional Korean medicine doctors' use of medical devices
Legal opinions are also divided over the scope of traditional Korean medicine doctors' use of medical devices.
Attorney Hong Seung-pyo of Daeryun Law Firm said, "Regarding traditional Korean medicine doctors' use of laser devices, non-referral and non-indictment dispositions are continuing," adding, "The fact that health insurance recognizes laser acupuncture by traditional Korean medicine doctors as a traditional Korean medical act is also proof that it effectively acknowledges traditional Korean medicine doctors' use of lasers."
In fact, in Nov. last year, police closed a case against a traditional Korean medicine clinic that had been reported for performing laser procedures, finding no charge. In 2023, the Supreme Court also finalized a ruling that the use of ultrasound diagnostic devices by traditional Korean medicine doctors could not be punished as a violation of the Medical Service Act.
There is also a rebuttal. They say that allowing the use of some diagnostic devices should not be interpreted as allowing the use of all cosmetic and therapeutic devices.
Attorney Lee Yong-hwan, head of Godo Law Firm, said, "We need to distinguish between using diagnostic devices as an auxiliary means and fully using therapeutic devices," adding, "Lifting procedures by traditional Korean medicine doctors clearly violate the scope of their license."