Lashes, Brows and Microblading in Florida

Makeup application is exempt from licensing in Florida — it needs no cosmetology license and no registration. Lash extensions, lash and brow tinting, microblading, permanent makeup, hair removal and exfoliation are not — the statute names them as exclusions from that exemption. The line runs straight through services that are usually sold together, which is why this is the boundary worth knowing exactly.

The exemption, and its closed list of exclusions

Section 477.0135(11) exempts a practice “confined solely to makeup application”, and then lists what that does not include:

• manual or chemical exfoliation
• semipermanent lash application
• lash or brow tinting
• permanent makeup application
• microblading
• hair removal

(s. 477.0135(11))

This is the same statute section that sets out the other exemptions. The two lists behave differently and it matters. What the exemption includes is open — “includes, but is not limited to” — covering primer, face paint, lipstick, eyeliner, eye shadow, foundation, rouge or cheek color, mascara, strip lashes, individual lashes, face powder, corrective stick and makeup remover. What it excludes is closed.

Strip lashes yes, semipermanent lashes no

That is the sharpest edge on the page. Applying strip lashes or individual lashes sits inside the makeup exemption by name. Semipermanent lash application is named as an exclusion. Same service area, opposite answers.

What covers the excluded work

Skin care services and non-invasive hair removal including wax treatments fall to cosmetologists and to full and facial specialists — but expressly not electrolysis, which is regulated under chapter 478 rather than chapter 477 (Rule 61G5-18.00015). Which credential fits which service is set out under license types.

That accounts for exfoliation and hair removal. It does not account for microblading, and the reason is that microblading is not a chapter 477 question at all.

Microblading is tattooing, and a different agency licenses it

The Florida Department of Health — not the Board of Cosmetology — publishes the answer, and states it in its own first sentence:

Microblading, permanent cosmetics, and ONLY micro-needling using pigments, dyes, or ink are considered a form of tattooing in the state of Florida.

The practice of tattooing in Florida requires licensure as a tattoo artist and must occur in a licensed tattoo establishment.

(Florida Department of Health, microblading, permanent cosmetics and micro-needling)

So chapter 477 names microblading only to say the makeup exemption does not cover it. What does cover it sits in a different chapter, under a different regulator, with a different application:

• a tattoo artist license, applied for at the local county health department rather than at DBPR — $60 state fee, with local county fees possible on top
• 18 or over, proved by government-issued photo ID
• a Department-approved bloodborne pathogens and communicable diseases course, passed at 70% or better
• the work must happen in a licensed tattoo establishment — $200 state fee — and the artist’s application has to name it
• a biomedical waste generator permit, $85, which DOH names for microblading and permanent cosmetics specifically, because the procedure generates biomedical waste

DOH cites the governing law as sections 381.00771–381.00791 of the Florida Statutes, “The Practice of Tattooing”, and chapter 64E-28 of the Florida Administrative Code.

The statute’s own definition is what makes that checkable rather than something to take the Department’s word for (s. 381.00771(6)):

“Tattoo” means a mark or design made on or under the skin of a human being by a process of piercing and ingraining a pigment, dye, or ink in the skin.

Microblading makes a mark under the skin by piercing it and ingraining pigment. The Department’s position is not an assertion of jurisdiction on top of the statute — it is what the definition says.

A license already held under chapter 477 does not substitute for any of this, and none of the four cosmetology credentials reaches this work.

What this page still does not resolve

The Department’s answer covers microblading, permanent makeup and micro-needling with pigment. It does not reach the other exclusions on the list. Lash extensions, lash and brow tinting, and hair removal are named as outside the makeup exemption without chapter 477 naming what authorizes them, and this site does not publish an answer it has not read from a primary source. Anyone planning to offer those should put that question to the Board directly.