“To the extent microblading deposits ink or color under the epidermis and into the dermis, microblading meets the ordinary and statutory definition of "tattoo" and is subject to the laws and regulation applicable to tattooing. Normally, tattooing may be done only at a licensed tattoo studio by a registered tattoo artist, apprentice artist, or temporary artist. Tenn. Code Ann. § 62-38-204. Tennessee Code Ann. § 62-38-210(b) specifies that the tattoo-regulation scheme in Tenn. Code Ann. §§ 62-38-201 through - 212 “does not apply to any physician, surgeon or any person under the supervision of a physician or surgeon who is licensed to practice medicine in this state.” Therefore, “any physician, surgeon or any person under the supervision of a physician or a surgeon who is licensed to practice medicine in this state” may, without registering as a tattoo artist or operating at a licensed tattoo studio, perform microblading that deposits coloration in the dermis (including at, for example, a medical spa or physician’s office).”
For more information please contact the Department of Health at 615-741-7206.
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/assets/entities/attorneygeneral/opinions/op17-031.pdf