Microneedling devices are ““capable of altering or damaging . . . living tissue” (emphasis added) and are properly considered “cosmetic medical device[s]” under Tenn. Code Ann. § 63-1- 153(a)(1). Procedures involving “cosmetic medical devices” may be performed only in medical spas or “an individual physician’s office or practice owned by a physician.” See Tenn. Code Ann. § 63- 1-153(a)(4) (defining “medical spa” as “any entity, however named or organized, which offers or performs cosmetic medical services”). Medical spas are required to register with the Department of Health. Tenn. Code Ann. § 63-6-105(a) (clarifying that “the registry shall include any physician-owned practice that advertises or holds itself out as a medical spa or a physician-owned practice that primarily engages in the performance of elective cosmetic medical services”).”
For questions regarding microneedling, you may contact the TN Department of Health, Health Related Boards at 615-532-3202 or tn.health@tn.gov
This FAQ is based off of Tennessee Attorney General’s Opinion 17-31. Like that opinion, this FAQ “assumes and is limited to the following definitions of the procedures of “microblading” and “microneedling.” “Microblading” is a semi-permanent makeup procedure that enables a person to recreate lost eyebrows. Microblading is performed by manually depositing pigment into the skin by use of a pen-like instrument, which contains several fine needles organized in a line. When the instrument is pressed against the skin, the needles penetrate the skin and leave behind pigment. “Microneedling” is a skin-rejuvenation procedure that involves the use of a device that contains fine needles, which may be between .25 and 3.0 mm in diameter. The needles are organized on a cylinder, which is rolled over a person’s skin to puncture it and create a controlled skin injury to infuse the skin with preparation materials or collagen. The devices used in both procedures are capable of causing bleeding or rupturing blood vessels.” All quotes provided below are pursuant to that Attorney General’s Opinion, which is available in its entirety at https://www.tn.gov/content/dam/tn/attorneygeneral/documents/ops/2017/op17-031.pdf.