Microneedling procedures are extremely effective for skin and scalp treatments.  Creations of channels into the skin or scalp at depths varying from .05 – 3.0mm begin the customized treatment/solution plan.  If you, your clinic or medspa take advantage of this service you are very aware of the benefits. SO, why then, are the treatment regulations SO very different in each state?

Washington and California

Let’s dig in to the topic and review a few examples. In Washington, only master aestheticians perform microneedling. Whereas, in California, the Board of Barbering and Cosmetology considers microneedling an aggressive procedure and does not allow it to be performed by even licensed aestheticians under any condition.

Florida and Utah

The State of Florida allows licensed estheticians to perform microneedling, while in Utah, master estheticians perform microneedling, provided the needle depth does not exceed 1.5 mm. General supervision requirements by a licensed healthcare provider are needed if the needle penetration exceeds 1.5 mm. https://www.estheticianedu.org/microneedling/


On April 20th, 2017 Herbert H. Slatery III, Attorney General offered his Opinion for those in the state of Tennessee. Fortunately, for those in Tennesse, the rule of law is very clear as you see in the abbreviated overview below:


May a person not licensed as an aesthetician by the Board of Cosmetology and Barber Examiners perform microblading or microneedling at a medical spa, as defined by Tenn. Code Ann. § 63-1-153?


A person not licensed by the Board of Cosmetology and Barber Examiners may perform microneedling only if that person satisfies an exemption found in Tenn. Code Ann. § 62-4-109. A person not licensed by the Board of Cosmetology and Barber Examiners may perform microblading only if that person satisfies an exemption found in Tennessee Code Ann. § 62-4-109 and either is a licensed tattoo artist under TN Code Ann. § 62-38-204 or is exempt from tattooing laws and regulations under TN Code Ann. § 62-38-210(b).

You may view the full report at:  https://www.tn.gov/content/dam/tn/attorneygeneral/documents/ops/2017/op17-031.pdf

For more information on the microneedling with growth factors contact PepFactorSE; info@pepfactorse.com or visit www.pepfactorse.com. We are dedicated professionals who continually seek out products, services, and solutions to increase the options for the hair loss and aesthetics industries. We are committed to education, “real” results, and support for providers and patients. PepFactor SE can provide microneedling training to our clients, if needed. 

***The full opinion in its entirety can be found in the link listed above.  This is an abbreviated overview, focusing on microneedling and not microblading or cosmetic tattooing. All states vary in their regulatory requirements.  This information is only an overview and not full state regulations. PepFactor SE is not responsible for information regarding state regulations in their entirety. Regulations vary between states and change often. For full regulations in your state it is best to inquire information from your state boards and stay informed by them regularly.

2 Responses

    1. Hi Michael, I have you set up for a phone call tomorrow morning (02/04) at 10:00am. We will answer any of your questions in detail then. Thank you for reaching out to us. Look forward to talking to you tomorrow!

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