Michigan Esthetician Scope of Practice 2026: What's Allowed

Michigan spent 2024 doing something most states have not managed: it opened the esthetics statute and wrote a modern service list into it. Public Act 160 of 2024 took effect on March 20, 2025, and estheticians who had been dermaplaning in a legal grey zone for years woke up with the treatment named in black-letter law.

The second half of that story is what makes Michigan interesting in 2026. The Legislature drew its boundary with unusual precision — dead skin cells, nonmedical grade, light that does not penetrate — and every qualifier is a wall. Cross it and you are no longer an esthetician performing an expanded service; you are an unlicensed person practising medicine, answerable to LARA, the Michigan Board of Cosmetology and potentially the Michigan Board of Medicine. This guide walks the menu service by service, with a verdict on each. Our companion guide on who can inject Botox in Michigan covers the injectable side of the same line, and the med spa regulations by state reference sets Michigan beside its neighbours.

What a Michigan Esthetician Licence Actually Authorises

Start where a regulator starts: with the enabling statute, not the device vendor's trade-show pitch.

MCL 339.1210 is the entire scope

Article 12 of the Occupational Code (1980 PA 299) creates the esthetics licence. MCL 339.1201 supplies the definitions and MCL 339.1210 sets the permitted services: cleansing or stimulating the skin using hands, devices, apparatus, noninvasive light or appliances; beautifying it with cosmetic preparations, tonics, lotions or creams, including body wrapping; facials, removable makeup and eyelashes; and removing hair temporarily.

Treat that as a closed list, not a set of examples. Michigan grants named services, not a general skin-treatment authority with carve-outs. A treatment that is absent is unauthorised not because someone prohibited it, but because the statute never reached it — a far harder position to argue out of.

Michigan's licence tiers — and the master esthetician that does not exist

Verdict: Michigan has one esthetics licence and nothing above it. The Occupational Code recognises the cosmetologist, the esthetician, the manicurist, the electrologist and the natural hair culturist. There is no advanced esthetician, no master esthetician and no medical esthetician licence — a real difference from states that stack a second tier on top and hand it extra devices.

The tiers Michigan does have are walled off from one another. MCL 339.1203a provides that someone licensed for a particular specialty renders only that service: an esthetician does not acquire electrology authority by buying an epilator.

Private certificates cause the usual confusion. A "medical esthetics" or "master esthetician" programme issues a certificate Michigan does not recognise as a credential. In a delegation file it is real evidence that a named individual was trained for a named act — but it confers no scope, and advertising it as a licence creates the holding-out problem discussed below.

Training hours moved; scope did not follow

Michigan raised the entry bar at almost the same moment it widened the menu, and the two get conflated constantly. Under 2024 PA 78, candidates who began training on or after July 1, 2024 must complete at least 750 hours in a licensed school of cosmetology, or six months as an apprentice in a licensed establishment where skin care services are rendered. Earlier entrants qualified on 400 hours; cosmetologists remain at 1,500.

Nothing in that change enlarged anyone's scope. A 750-hour esthetician and a 400-hour esthetician hold identical authority, and a curriculum containing a microneedling module does not put microneedling inside the licence. Hours describe preparation; the statute describes permission.

Two Statutes, One Esthetician: How Michigan Splits the Regulation

Almost every scope mistake in a Michigan skin room comes from reading one statute and assuming it is the only one in play. There are two, run by different boards, with different penalties.

The Occupational Code and the Public Health Code

The Occupational Code licenses the esthetician and defines what that licence permits. The Public Health Code (1978 PA 368) licenses physicians, nurses and physician assistants, defines the practice of medicine at MCL 333.17001, and governs everything that counts as treating the human body. An esthetician is not a health professional under Article 15 — which is exactly why crossing into it is so costly. You arrive not as a licensee performing an unauthorised act, but as an unlicensed person performing a licensed one.

Rule R 338.2179g, the hinge between the two

Michigan bolted the systems together in its cosmetology rules, and this is the provision most worth memorising. R 338.2179g provides that a student, apprentice or licensee shall not perform services limited to the scope of practice of a licensed health profession regulated under Article 15 of the Public Health Code — unless performing a service delegated under section 16215. The same rule bars an esthetician from using razors, scissors or clippers on a patron's scalp.

Read the exception as carefully as the prohibition. Michigan did not simply fence estheticians out of medical territory; it wrote the delegation statute into the cosmetology rulebook. That is how an esthetics licensee can lawfully perform a medical act here — as a delegatee, never as an esthetician.

Public Act 159 of 2024 and the practice-of-medicine carve-out

The 2024 reform arrived as a tie-barred pair, and the second bill is the one nobody mentions. Public Act 159 of 2024 (House Bill 5683) amended the Public Health Code to confirm that Part 170 (medicine) and Part 175 (osteopathic medicine and surgery) do not prohibit a licensed esthetician or cosmetologist from performing acts described in section 1210 of the Occupational Code, even where those acts would otherwise be the practice of medicine — provided they stay within scope and the individual does not use titles protected under those parts.

Two consequences follow. The expanded services are genuinely safe: the Legislature anticipated the practice-of-medicine objection and neutralised it, so nobody needs a physician standing by for a nonmedical grade peel. Less comfortably, the carve-out reaches only acts described in section 1210 — which is why the omissions below matter so much.

Michigan's 2025 Scope Expansion: What PA 160 Added and What It Left Out

Public Act 160 of 2024 (House Bill 5684) was signed in December 2024 and took effect on March 20, 2025. It is the most consequential change to Michigan esthetics in decades — and routinely overstated in trade coverage.

The services the amendment added

The expanded MCL 339.1210 authorises exfoliation of only the dead skin cells of an individual — including, but not limited to, in the performance of dermaplaning or microdermabrasion — using products, chemicals, mechanical devices, electrical services or Class I medical devices. It authorises applying a nonmedical grade chemical peel, confirms lash and brow services including extensions and lamination, and permits light therapy only where the light is FDA approved and intended not to penetrate the layers of living skin.

The qualifiers that do all the limiting

Every permission arrived with a governor attached, and each is a different kind of test. Dead skin cells is anatomical — the authority stops at the stratum corneum. Nonmedical grade is a product-certification test, examined below. Intended not to penetrate the layers of living skin is a device-intent test, and it is what removes lasers and IPL. Note the device ceiling too: Class I is the lowest-risk FDA category, so a Class II device — where deeper microneedling pens and most energy equipment sit — falls outside the grant.

What was deliberately not added

Microneedling is not in the statute. Neither are lasers, IPL, radiofrequency, injections or medical grade peels. The absences are choices, not gaps awaiting a reasonable reading: when a legislature enumerates and stops, what it declined to enumerate stays outside.

Chemical Peels: Michigan Draws the Line by Product Grade, Not Peel Depth

Most states analyse peels by depth — superficial is esthetics, medium and deep are medicine. Michigan chose a different axis in 2025, and practices importing the depth framework get the answer wrong in both directions.

The nonmedical grade test

Verdict: yes to nonmedical grade peels, and the certification decides it. MCL 339.1201 defines nonmedical grade as a product or material that is not certified for medical use only. That is a question about the agent on your shelf and how its manufacturer certified it — not the acid's pH, not its percentage, not how much frost the protocol produces.

So the controlling evidence is a purchasing record, not a clinical one: supplier documentation showing each product in the treatment room is not certified for medical use only, kept per SKU. A practice relying on "it's only a 30% glycolic" has answered a question Michigan did not ask.

Where depth still matters

Verdict: medium and deep peels stay outside the esthetics licence. Depth is now the second question rather than the first. Agents used for genuine medium-depth and deep resurfacing — higher-concentration TCA and phenol formulations — are overwhelmingly certified for medical use only, so they fail the nonmedical grade test on their own terms. They also wound living tissue, which places them in the practice of medicine and outside the PA 159 carve-out.

One failure mode deserves naming. Stacking or repeating a nonmedical grade product to chase a deeper result does not change the product's certification, but it does change what you are doing to living tissue — and a complaint following a chemical burn is assessed on the injury, not the invoice. Our chemical peel scope of practice guide sets Michigan's product-grade approach against the depth-based rules used elsewhere.

What a medium or deep peel requires here

Resurfacing beyond the nonmedical grade line needs the medical apparatus around it: a prescriber who has evaluated the patient, a protocol predating the treatment, a documented delegation, and supervision meeting MCL 333.16109. The esthetician may still perform it — as a delegatee, on the strength of the file, not the licence.

Microneedling: Cosmetic Depth, Medical Depth, and Michigan's Pointed Silence

Microneedling is the highest-revenue service on the boundary and the one Michigan handled most quietly. No statute or rule here says "estheticians shall not microneedle." None needed to.

Why the omission is the answer

Verdict: no, not on the esthetics licence. Handed an opportunity to modernise the list, the Legislature added dermaplaning and microdermabrasion by name — two surface treatments — and did not add microneedling. It then capped exfoliation at dead skin cells and devices at Class I. Microneedling that does anything worth charging for defeats both limits at once, and the PA 159 carve-out reaches only acts described in section 1210.

The 0.3 mm line, and what it does not settle

The FDA treats a microneedling device as cosmetic where the needles penetrate no deeper than roughly 0.3 mm and do not pass the stratum corneum, and as a Class II medical device above that. That federal split maps onto Michigan's language with unusual neatness — a genuinely sub-0.3 mm device is arguably exfoliation with a Class I device, while anything deeper is a Class II device puncturing living tissue.

Do not over-read the alignment. LARA has published no guidance blessing shallow needling as esthetics work, and marketing "0.2 mm cosmetic microneedling" invites a regulator to examine your device's real classification and your real settings. This corner is genuinely unsettled, and the safe reading is that anything called microneedling belongs under delegation. Our microneedling laws by state guide tracks how each state draws the same line.

RF microneedling is not a closer call

Radiofrequency microneedling combines needle penetration to dermal depth with thermal energy delivery, and it is medicine on both counts — no depth argument, no Class I argument, no exfoliation argument. It requires a prescriber-led model with delegation, and an esthetician performing it without one is exposed under both codes at once.

Dermaplaning: Expressly Authorised, With Conditions Attached

Dermaplaning is the clearest win Michigan estheticians took from the 2025 reform. It is worth knowing how far it extends.

What the statute now permits

Verdict: yes, expressly, on the esthetics licence. MCL 339.1210 authorises exfoliating only the dead skin cells of an individual, including in the performance of dermaplaning or microdermabrasion, using products, chemicals, mechanical devices, electrical services or Class I medical devices. No physician, no delegation, no supervision — and PA 159 confirms it is not unauthorised practice of medicine.

The qualifier that still constrains the blade

"Only the dead skin cells" is not decorative drafting. A pass that abrades living epidermis, removes a lesion, treats a skin condition or draws blood is not the authorised exfoliation, whatever the appointment was booked as. Dermaplaning over active acne, moles, keratoses or inflamed skin moves toward treatment — and treatment is Public Health Code territory. Keep the adjacent rule in view too: R 338.2179g separately bars an esthetician from using razors, scissors or clippers on a patron's scalp.

Laser and IPL: The One Device Michigan Legislated Directly

Michigan wrote exactly one aesthetic-device statute, more than twenty years ago, and it has survived every scope reform since. Hair removal belongs in the same discussion, because that is where the statute quietly splits one menu item into three.

MCL 333.16276 and the supervision requirement

MCL 333.16276, added by 2004 PA 144 and effective June 15, 2004, provides that a licensee, registrant or other individual shall not perform a procedure using a laser for dermatological purposes unless it is performed under the supervision of a licensed physician and the patient knows of, and consents to, that individual performing it. The section treats the practice of dermatology as including cosmetic conditions of the skin, hair and nails, so cosmetic laser work is inside it.

Why lasers sit outside the esthetics licence anyway

Verdict: no, not as an esthetician. Even before reaching MCL 333.16276, the esthetics statute disposes of it: MCL 339.1210 permits light only where it is FDA approved and intended not to penetrate the layers of living skin. Lasers, IPL and laser hair removal all work by depositing energy into living tissue — the mechanism, not a side effect. LED and low-level light therapy survive this test comfortably.

The delegated route is genuinely unsettled

Here honest advice diverges from most published summaries, which state flatly that Michigan estheticians may never touch a laser. That overstates a real ambiguity. MCL 333.16276 regulates by condition — physician supervision plus patient knowledge and consent — rather than by a closed list of licences, and it reaches "other individuals," not only health professionals. R 338.2179g then expressly permits a cosmetology licensee to perform a health-profession service when it is delegated under section 16215. Together they describe a defensible path.

What is missing is any published LARA or board interpretation confirming it, and proposed rules discussed below would bar laser use in a cosmetology establishment outright. If your model depends on an esthetics licensee firing a laser as a delegatee, get a written opinion from Michigan counsel first.

Temporary hair removal is squarely in scope

Verdict: yes. MCL 339.1210 authorises removing hair temporarily — waxing, sugaring, threading, tweezing, depilatory creams. No supervision, no delegation, no prescriber: esthetics work in Michigan for decades, untouched by the 2024 amendment.

Electrolysis and laser hair removal each need something else

Verdict: no to both, for different reasons. Permanent hair removal by electricity is electrology, a separate specialty licence with its own training requirement, and MCL 339.1203a's one-service rule applies in full. An esthetician offering electrolysis is practising a regulated occupation without the licence for it.

Laser hair removal is the subtler trap: because the statute grants hair removal and the service contains those words, operators reason their way into the wrong place. It is a laser procedure performed for dermatological purposes, so MCL 333.16276 applies, and it fails the non-penetrating light test in MCL 339.1210.

The Practice-of-Medicine Line Under the Michigan Public Health Code

Every verdict above applies one boundary. Learn to run the test yourself and you can evaluate a service Michigan has never named — which, given how fast device manufacturers move, is most of them.

How MCL 333.17001 defines the boundary

The Public Health Code defines the practice of medicine as diagnosing, treating, preventing, curing or relieving a human disease, ailment, defect, complaint or other physical or mental condition, by attendance, advice, device, diagnostic test or other means. Two words carry the weight in an aesthetic setting. Device means using a machine is not a defence. Relieving means you need not cure anything — offering to improve a condition is enough.

Marketing a treatment as beauty rather than medicine therefore changes nothing. If your consent form says the service treats acne scarring, melasma or rosacea, you have described treatment of a physical condition in your own words.

The four-question test before adding any service

Before a new treatment reaches your price list, answer these in order and stop at the first no:

• Is it named in MCL 339.1210? If yes, it is esthetics work and PA 159 protects it.
• Does it stay above living tissue? Anything that punctures, abrades, wounds or deposits energy below the stratum corneum has left a grant that stops at dead skin cells.
• What is the device or product certified as? Class I and not-certified-for-medical-use-only sit inside the scope; Class II and medical grade do not.
• What are you claiming it does? Marketing that promises to treat a condition supplies the regulator's evidence, whoever performed the service.

A no does not mean you cannot offer the service — only that you cannot offer it on an esthetics licence.

When Physician Delegation or Supervision Is Required

Michigan is a delegation state: more permissive than most, far more demanding to document. Nearly everything excluded above becomes available to an esthetics licensee this way — as an individual, never as an esthetician.

MCL 333.16215 and the delegation ceiling

Under MCL 333.16215, a licensee may delegate to a licensed or unlicensed individual otherwise qualified by education, training or experience the performance of selected acts, tasks or functions, where those acts fall within the delegating licensee's own scope and are performed under that licensee's supervision. An esthetician is an unlicensed individual for these purposes — not licensed under the Public Health Code — and is therefore eligible.

The statute then imposes the limit that stops delegation swallowing licensure: a licensee shall not delegate an act which, under standards of acceptable and prevailing practice, requires the level of education, skill and judgment required of the licensee. Patient selection, screening contraindications, choosing the agent or device, and setting depth or energy parameters sit at that ceiling. Executing a defined protocol on an evaluated patient is what delegation contemplates.

The three-part supervision test at MCL 333.16109

Michigan defines supervision rather than leaving it to negotiation. MCL 333.16109 requires all of the following: continuous availability of direct communication between the supervised individual and a licensed health professional, in person or by telephone or telecommunication; availability of a licensed health professional on a regularly scheduled basis to review that individual's practice, consult, review records and further educate them; and the provision of predetermined procedures and drug protocol.

Operators misread this in both directions. Physical presence is not required, which is why off-site medical direction works here and fails in proximity-rule states. But the test is conjunctive — a phone number satisfies one limb of three. Without scheduled practice review and protocols that existed before the first treatment, there is no supervision within the meaning of the Code, and no valid delegation.

What a defensible esthetician delegation file contains

Michigan has no med spa facility licence and no inspection cycle, so nobody examines your paperwork until something has gone wrong — at which point the paperwork is the entire case. Build one file per delegatee per act, dated before the first treatment: the delegating licensee's name and licence number; the acts delegated, described narrowly enough that a reviewer can tell what was authorised; qualification evidence including training, supervised cases and a signed competency assessment; the predetermined written protocol; the emergency protocol; and records of practice review.

Then keep the two hats visibly separate. The same person may perform facials as an esthetician on Tuesday and microneedle as a delegatee on Wednesday, but scheduling, job descriptions, consent forms and advertising should never blur which authority is in play — the inference you cannot afford is that the esthetics licence was the permission.

What Happens When a Michigan Esthetician Works Out of Scope

Enforcement here is complaint-driven, arriving through LARA's Bureau of Professional Licensing after an adverse outcome, a departing employee or a competitor reports. What surprises people is how many consequences one out-of-scope treatment triggers.

Occupational Code exposure

Under MCL 339.601, engaging in a regulated occupation, or using a designated title, without the required licence is a misdemeanour — up to $500, 90 days, or both, rising to $1,000 and a year for a second or subsequent violation. Separately, LARA may issue a cease and desist order, and the Board of Cosmetology may discipline the esthetics licence itself — usually the outcome that actually ends a career.

Public Health Code exposure

If the service was the practice of medicine, a heavier statute engages. MCL 333.16294 makes practising, or holding oneself out as practising, a regulated health profession without a licence a felony. Published descriptions of the penalty range vary enough to confirm with Michigan counsel rather than any secondary source, this one included. The holding-out language deserves attention: advertising staff as "medical estheticians" can supply that element without a single treatment.

The physician's exposure and the insurance gap

The esthetician is rarely the only person exposed. A supervising physician or APRN faces discipline under MCL 333.16221, which lists negligence or failure to exercise due care — expressly including negligent delegation to or supervision of employees or other individuals — as grounds for sanction whether or not injury results. Michigan needs no harmed patient to act on a bad delegation.

Then there is the exposure that lands at the worst moment. Professional liability policies commonly exclude acts performed outside the insured's scope. In a delegation state, scope is established by the delegation file rather than the licence on the wall — so a defective file can be both the reason a claim exists and the reason it is not covered.

The Rules Rewrite That Could Narrow All of This

One more thing belongs in an honest 2026 picture: the statutory expansion above is not the only rulemaking in motion, and the other points the other way.

What LARA's proposed cosmetology rules would do

LARA has had a cosmetology rule set in development for several years, and its proposed prohibitions are considerably broader than the current ones. As proposed, they would bar using any device, apparatus, appliance, product, technique or practice to abrade, resurface, pierce, puncture or inject any tissue or skin layer below the stratum corneum, except when performing electrology or hair removal — capturing microneedling and microblading — and would prohibit lasers and ultrasound in a cosmetology establishment, on the reasoning that such establishments are not medical practices.

How to plan while the rules are pending

Two things are worth saying plainly. The proposals largely restate the boundary described above — anything below the stratum corneum, plus energy devices — so a practice built on that analysis is undisturbed. And the drafting predates Public Act 160: where a rule conflicts with a statute the statute controls, so LARA cannot rescind by rule the dermaplaning and microdermabrasion authority the Legislature granted in 2025.

The genuinely unsettled item is the laser question: a final rule barring laser use in cosmetology establishments would narrow the delegated-esthetician route sharply in a spa setting while leaving it arguable in a physician-owned practice.

Summary: A Michigan Esthetician Scope Checklist

A defensible Michigan skin services menu has a recognisable shape.

1. Audit your price list against MCL 339.1210 line by line. Every service either appears in the statute or needs a delegation behind it.
2. Document product certification for every peel. Nonmedical grade is a purchasing question here — keep supplier documentation per SKU.
3. Check device classification before purchase. The grant reaches Class I devices; Class II equipment needs a medical model around it.
4. Treat microneedling as delegated work in every form. Shallow, deep or radiofrequency, the statute never named it.
5. Keep dermaplaning above living tissue. The authority is express, and it stops at dead skin cells — no lesions, no bleeding, no scalp.
6. Do not run lasers or IPL on an esthetics licence. MCL 333.16276 requires physician supervision plus patient consent.
7. Hold the right licence for permanent hair removal. Electrology is a separate specialty; temporary methods are the esthetics grant.
8. Build the delegation file before the first treatment, with all three limbs of MCL 333.16109 satisfied.
9. Audit your marketing as carefully as your protocols. Treatment claims and titles like medical esthetician create exposure on their own.

If drafting those protocols, consent forms and delegation templates from scratch is not how you want to spend the month, our library of ready-to-use med spa compliance SOPs covers the documentation behind every step above.

For more Michigan-specific guidance as this cluster grows, browse the Michigan med spa compliance hub.

This article is for informational purposes only and does not constitute legal or medical advice. Michigan esthetics scope is administered by LARA and the Michigan Board of Cosmetology, medical scope by the Michigan Board of Medicine, and both change over time — several points here, including shallow microneedling, the delegated-esthetician laser route, and the pending cosmetology rule set, are genuinely unsettled. Confirm current requirements with LARA, the Michigan Board of Cosmetology, or the Michigan Board of Medicine, and consult a Michigan healthcare attorney before adding a service to your menu.

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