The Largely Unregulated Realm of Microblading in Pennsylvania: What Do Business Owners Need to Know?

Ashley J. Puchalski, Esq. apuchalski@tuckerlaw.com, (412) 594-5509

A new beauty trend known as “microblading” is becoming increasingly popular in all states, including Pennsylvania. Microblading is a form of semi-permanent makeup that involves tattooing eyebrow hairs to obtain desired eyebrow shape and fullness. During the microblading process, artists use a handheld, blade-like tool to cut a small amount of pigment into the skin, creating darker and fuller eyebrows. Unlike a traditional tattoo, which is permanent, the coloring from microblading fades over time and only lasts up to three years.

Microblading Risks

While microblading is a great option for individuals with naturally thin eyebrows or those with autoimmune diseases that cause hair loss, there are risks associated with the procedure. Although uncommon, allergic reactions can occur due to the microblading pigment. There is also a risk of bacterial skin infections or the transmission of bloodborne diseases, like HIV, during the process.

Microblading Regulations

Despite the risks involved, Pennsylvania does not have training or licensing requirements for microblading artists. Other states, such as New Jersey, have very strict microblading regulations. In fact, Pennsylvania is one of only four states to have no regulations. The Centers for Disease Control and Prevention require microblading artists to take a class on bloodborne illnesses, but enforcement efforts are inconsistent. Fortunately, some microblading artists choose to attend training or classes to become certified. However, such training or certifications are not required in Pennsylvania and are provided by third-party companies rather than state regulatory agencies. Pennsylvania State Representatives have even recognized the lack of regulation and have unsuccessfully tried to pass legislation that would regulate the state’s tattoo and microblading industry.

 Although there is a common misconception that microblading falls under the cosmetology “umbrella”, the Pennsylvania State Board of Cosmetology clarified that microblading is outside the scope of cosmetology in the state. Microblading cannot be performed in a licensed cosmetology salon in Pennsylvania because 49 Pa. Code § 7.77 prohibits the use of a salon for purposes other than cosmetology. The Board of Cosmetology has taken steps in recent years to enforce this regulation. In 2018, the Board ordered a salon in Cumberland County, Pennsylvania to pay a civil penalty in the amount of $500 to cease and desist from performing microblading within the square footage of a licensed salon and to cease and desist from advertising and offering microblading services through a licensed salon. The salon was found to be operating in an unethical manner by performing microblading services. Accordingly, salon owners holding a valid license issued by the Board of Cosmetology, and operating salons under its regulations, face restrictions that prevent them from offering microblading services within their salon. Presently, the practice necessitates a separate business location distinct from an existing salon. 

As microblading becomes increasingly popular, it is essential that business owners, particularly those with a Pennsylvania Cosmetology License, be aware of legal and regulatory requirements associated with operating a microblading business in Pennsylvania. If you need assistance with business-related matters, please contact Ashley Puchalski at apuchalski@tuckerlaw.com or by calling 412-594-5509.