What Services Can an Esthetician Perform in Texas?

A licensed esthetician in Texas can perform cleansing, stimulating, and beautifying treatments on the face, neck, shoulders, and arms, along with hair removal and eyelash extensions. Every service in scope shares one feature: it stays on the epidermis, the outer layer of skin. The moment a treatment reaches the living tissue underneath, it becomes a medical procedure and leaves your license behind. That single line explains almost every rule that follows.¹

Services Within Your Scope

The Texas Department of Licensing and Regulation (TDLR) lists the following services as within the esthetician scope of practice:¹

Facial treatments that cleanse, stimulate, and beautify the face, neck, shoulders, and arms.
Massage of the scalp, face, neck, shoulders, or arms, by hand or with a device, with or without lotions, creams, or other cosmetic products.
Application of cosmetic preparations, antiseptics, tonics, powders, oils, clays, and creams to the face, neck, or arms.
Hair removal using depilatories, chemical preparations, tweezers, waxing, or other devices.
Application of semipermanent, single-fiber eyelash extensions to natural lashes.

Esthetics is defined under the cosmetology chapter of the Texas Occupations Code, and only an individual holding a valid Texas license can perform these services for compensation.²

Microdermabrasion and Chemical Peels: It Depends on the Depth

Two common treatments sit directly on the boundary between cosmetic and medical. Whether you can legally perform them turns entirely on how deep they go.

Microdermabrasion

You can perform microdermabrasion as long as the device and technique only remove dead cells from the epidermis. If the treatment contacts or penetrates the dermis, it falls outside your scope and must be administered or delegated by a physician.³ Know your equipment settings, and know the difference between a surface exfoliation and an aggressive treatment that reaches living tissue.

Chemical Peels

The same rule governs peels. Light or superficial peels that remove dead cells and enhance the epidermis without piercing the dermis are within your scope. Medium and deep peels penetrate the dermis and are classified as medical procedures regulated by the Texas Medical Board.³ There is no bright-line rule tied to specific acid concentrations. If a peel causes visible wounding or reaches living tissue, treat it as a medical procedure.

What an Esthetician Cannot Do

Injectables

Your license does not authorize the use of hypodermic needles. That rules out Botox, dermal fillers, and any other injection, even for purely cosmetic purposes. The prohibition stands even when a physician is in the room, because a doctor can delegate medical procedures but cannot delegate cosmetology, and injections are a medical act.³ This is where enforcement has been most active; legislative analysis of a recent bill noted that some estheticians were hosting “Botox parties” and administering unauthorized injections, which drove proposals to tighten the statutory prohibition.⁴

Dermaplaning

Dermaplaning looks like a straightforward exfoliation, but in Texas it falls outside the esthetician scope entirely. Performed with a non-medical razor, it requires a Class A Barber license. Performed with a medical scalpel, it falls under the Texas Medical Board’s jurisdiction.⁵ Neither version is yours to perform under an esthetician license.

Laser Treatments

Laser services are not covered by your license. Laser hair removal has its own TDLR certification program for individuals and facilities.⁶ Other laser cosmetic services, such as skin resurfacing, are classified as medical treatments that require physician delegation.³

Diagnosing Skin Conditions

You cannot diagnose skin conditions, prescribe treatments, or offer medical advice. When a client presents with a suspicious lesion or an unusual reaction, refer them to a dermatologist. Crossing this line is practicing medicine without a license, a separate and more serious problem than a scope violation.

Services That Need a Separate License

A few treatments related to esthetics have their own TDLR credential. These are standalone licenses, not add-ons.

Eyelash Extension Specialist

Semipermanent eyelash extensions already fall within the standard esthetician scope, so if you hold a Texas esthetician license you do not need another credential to offer them.¹ The standalone Eyelash Extension Specialist license exists for someone who wants to perform only lash extensions without completing a full esthetics program; that path requires 320 hours of instruction at a licensed school plus a written and practical exam.⁷

Laser Hair Removal Technician

An esthetician license alone does not qualify you to perform laser hair removal. To add this service, you need the separate certification issued through TDLR’s laser hair removal program.⁶

Working in a Medical Spa Under Physician Delegation

A medical spa setting opens the door to procedures that would otherwise be off-limits. Texas law allows a physician to delegate certain nonsurgical cosmetic procedures to a qualified non-physician, including an esthetician, when proper supervision protocols are in place.⁸ TDLR classifies Botox and filler injections, body contouring, laser-assisted treatments, and medical-grade facials as medical services that require a physician’s order and delegation.³

Delegation runs one direction. A physician can delegate medical procedures to you, but a physician cannot pick up cosmetology by delegation. The services you perform under your esthetician license (facials, superficial peels, epidermis-only microdermabrasion) do not require physician presence or delegation at all, as long as the facility holds an appropriate TDLR establishment license. Physician delegation applies only to the medical procedures you perform beyond your esthetician scope.³

When a physician does delegate a medical procedure to you, the supervision requirements are substantial. The physician must establish a practitioner-patient relationship, maintain adequate medical records, ensure someone trained in basic life support is present while the patient is on site, and maintain signed written protocols reviewed annually. A physician, physician assistant, or advanced practice registered nurse must either be on site during the procedure or be immediately available for emergency consultation. The supervising physician remains legally responsible for the patient’s safety regardless of who performs the procedure.⁹

Penalties for Practicing Outside Your Scope

TDLR classifies unlicensed practice and scope-of-practice violations as Class C violations, which carry administrative fines of $2,000 to $5,000 per violation and can result in license suspension or revocation.¹⁰ The structure covers both performing services with no license at all and performing services that exceed the license you hold.

When a scope violation involves a procedure that constitutes the practice of medicine, the Texas Medical Board can pursue enforcement independently. A TDLR fine for an unauthorized injection is one problem; a TMB investigation for practicing medicine without a license is a different order of trouble. The two agencies regulate different sides of the line, and crossing it can trigger action from both.

1
Texas Department of Licensing and Regulation. Esthetician – Scope of Practice
2
Texas Occupations Code. Regulation of Cosmetology – Occupations Code Chapter 1602
3
Texas Department of Licensing and Regulation. Medical Spas – Barbering and Cosmetology
4
Texas Legislature. SB 378 Bill Analysis
5
Texas Department of Licensing and Regulation. Medspas At A Glance
6
Texas Department of Licensing and Regulation. Laser Hair Removal
7
Texas Department of Licensing and Regulation. Apply for an Eyelash Extension Specialist License
8
Legal Information Institute. 22 Texas Administrative Code 169.25 – Other Delegation
9
Texas Medical Liability Trust. Regulations for Medical Spas in Texas
10
Texas Department of Licensing and Regulation. Penalties and Sanctions for Practitioners and Establishments