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7.7 - Semi-Permanent Makeup: Licensing Guide

Semi-permanent makeup - microblading, powder brows, lip blush, eyeliner, scalp micropigmentation - involves breaking the skin and depositing pigment. That puts it in the same regulatory category as tattooing, regardless of how the industry markets it. You need local authority registration, specialist insurance, and at least a Level 4 qualification for any insurer to take you seriously. This guide covers all of it.

Quick rule of thumb: semi-permanent makeup is tattooing in the eyes of the law. Every regulation that applies to tattooing applies to you - local authority registration, infection control, age restrictions, all of it. Don't let the word "semi-permanent" make you think the rules are lighter.

What counts as semi-permanent makeup?

All of these involve depositing pigment into the skin using needles or blades:

All of these break the skin. All of them involve pigment entering the body. All of them carry infection risk. The law treats them the same as conventional tattooing.

Local authority registration: mandatory

The legal requirement

Under the Local Government (Miscellaneous Provisions) Act 1982, anyone carrying on the practice of semi-permanent skin colouring must be registered with their local authority.

This is identical to the tattooing registration requirement (see Guide 7.5). You need:

• Personal registration - you as the practitioner
• Premises registration - the location where you work

Both must be in place before you treat a single client. Working without registration is a criminal offence.

Tip for new starters: Budget for everything before you start: Level 4 qualification (£1,000-2,500), local authority registration (£100-300), specialist insurance (£200-500 per year), and a starter kit of devices and pigments (£500-1,500). You're looking at £2,000-4,500 minimum before your first paying client.

The new aesthetics licensing scheme

Semi-permanent makeup falls under the green tier of the new aesthetics licensing scheme. Green tier is for procedures that break the skin but are non-surgical and don't require medical supervision.

This means:

• Your local council manages your licence
• Environmental Health will inspect your premises
• You must meet qualification and hygiene standards
• You must renew your licence annually

Working from home or mobile

If you work from home, you still need local authority registration for your home address. The same hygiene and premises standards apply - your treatment room must meet the same standards as a commercial salon.

If you're mobile (travelling to clients' homes), registration is more complex. Some councils register mobile practitioners differently. Contact your local authority and explain your working model.

Qualifications

Level 4: the industry standard

For semi-permanent makeup, Level 4 is the minimum qualification that insurers and most councils will accept. This is higher than the minimum for conventional tattooing because:

• The face is a more visible and sensitive area than most tattoo locations
• Mistakes are highly visible and difficult to correct
• The procedures require detailed knowledge of facial anatomy, skin typing, colour theory, and ageing

What Level 4 covers

A Level 4 qualification in semi-permanent makeup or micropigmentation typically includes:

• Facial anatomy and skin structure
• Colour theory (warm vs cool tones, how pigments change in different skin types, colour fading patterns)
• Fitzpatrick skin typing and its impact on pigment selection
• Contraindications (medications, skin conditions, allergies, medical history)
• Infection control and sterilisation
• Device operation (hand tools for microblading, PMU machines for powder brows/lip/liner)
• Consultation and consent procedures
• Treatment protocols for each procedure
• Aftercare and follow-up
• Managing complications (colour migration, allergic reactions, scarring)

Manufacturer training

On top of your formal qualification, manufacturer or brand training is strongly recommended. Each PMU device and pigment range has specific protocols - device settings, needle configurations, pigment dilution. Manufacturer training teaches you to use their specific system correctly.

Manufacturer training alone is NOT enough. It's a supplement to your formal qualification, not a replacement.

Ongoing CPD

The industry moves fast. New techniques, new pigments, new devices. Your insurer and your local authority expect you to maintain your competence through continuing professional development. Keep records of all CPD - courses attended, conferences, online training, peer observation.

Insurance: treatment risk cover is essential

Standard public liability insurance does not cover semi-permanent makeup. You need specialist treatment risk insurance.

What you need

Common claims in SPMU

The most common insurance claims in semi-permanent makeup are:

• Wrong shape or colour - client unhappy with the result (professional indemnity)
• Allergic reaction to pigment - redness, swelling, granulomas (product liability / treatment risk)
• Infection - bacterial infection from poor hygiene (public liability / treatment risk)
• Scarring - from too-deep application, keloid formation, or poor aftercare (treatment risk)
• Colour migration - pigment spreading beyond the intended area (professional indemnity)

What insurers want to see

• Level 4 qualification (minimum)
• Local authority registration
• Manufacturer/brand training for your specific device and pigments
• Documented consultation and consent process
• Patch test protocol
• Aftercare documentation
• CPD records
• Clean claims history

Client consultation: getting it right

The consultation is where you identify risks, manage expectations, and protect yourself legally. Every client needs a thorough consultation before treatment.

Allergy history

Ask about:

• Previous reactions to cosmetics, skincare products, or makeup
• Known allergies (especially to metals - nickel is present in some pigment formulations)
• Previous reactions to hair dye (PPD sensitivity can cross-react with some pigments)
• History of contact dermatitis or eczema

Fitzpatrick skin type

Skin type affects:

• Pigment colour selection - warm tones in cool skin can look unnatural over time; cool tones in warm skin can turn grey
• Healing response - darker skin types are more prone to keloid scarring and post-inflammatory hyperpigmentation
• Pigment retention - different skin types hold pigment differently; oily skin tends to blur and fade faster

Medications

Screen for:

• Blood thinners (warfarin, aspirin, clopidogrel) - increased bleeding during the procedure, which dilutes pigment and affects retention
• Retinoids (isotretinoin/Accutane, topical retinol) - thinned skin, poor healing. Most protocols require stopping retinoids 6-12 months before treatment for isotretinoin, 2-4 weeks for topical retinol
• Immunosuppressants - increased infection risk, poor healing
• Antibiotics - some are photosensitising, which matters for healing
• Iron supplements - can affect pigment colour

Pregnancy and breastfeeding

Semi-permanent makeup is contraindicated during pregnancy. The reasons:

• Numbing creams (lidocaine/prilocaine) are absorbed through the skin and cross the placental barrier
• Infection risk (however small) to the pregnancy
• Hormonal changes affect skin sensitivity and pigment retention
• No evidence of harm, but no evidence of safety either - the precautionary principle applies

Most practitioners also avoid treating breastfeeding clients, though the evidence here is less clear. Check your insurer's position.

Patch testing

Is it required?

There's no specific UK law that mandates patch testing for semi-permanent makeup pigments. But:

• Many manufacturers recommend it
• Many insurers require it (check your policy)
• Some local authorities require it as a licence condition
• It's strongly recommended by professional bodies

How to patch test for SPMU

1. Apply a small amount of the chosen pigment to an inconspicuous area (usually behind the ear or on the inner arm)
2. Some protocols involve a superficial needle application to mimic the treatment
3. Wait at least 48 hours (some protocols recommend 72 hours)
4. Check for redness, swelling, itching, or any adverse reaction
5. Document the result

The practical reality

Many SPMU artists don't patch test because clients travel long distances for appointments and don't want to make two trips. This is understandable but risky. Options:

• Offer a remote patch test - send a small sample to the client with instructions (legally questionable - you're providing a product for self-application)
• Require a separate consultation appointment before the treatment appointment
• At minimum, do a patch test on the day and wait the recommended period before proceeding - though this means the client may need to return

Document whatever approach you take. If you decide not to patch test, document why and get the client's informed consent.

Tip for new starters: Set up a separate consultation appointment before every treatment booking. This gives you time to do a proper patch test, check contraindications, and manage expectations. It also filters out clients who are not suitable and protects you from complaints.

Aftercare documentation

You must provide every client with written aftercare instructions. These should cover:

Immediately after treatment

• Keep the area clean and dry for the first 24 hours
• Don't touch the treated area with unwashed hands
• Apply aftercare balm as instructed (specific to your product system)
• Expect some redness, swelling, and tenderness - this is normal

Days 1-14

• Don't pick, scratch, or peel any scabbing - let it fall off naturally
• Avoid makeup on the treated area
• Avoid swimming, saunas, steam rooms, and excessive sweating
• Avoid direct sunlight and tanning beds
• Don't apply AHA/BHA products, retinol, or exfoliants to the area
• Sleep on a clean pillowcase

Long-term

• Apply SPF 30+ to the treated area when exposed to sun (UV breaks down pigment)
• Expect the colour to fade by 30-50% as the skin heals - this is normal
• A top-up appointment is usually needed 4-8 weeks after the initial treatment
• Semi-permanent makeup typically lasts 1-3 years before a refresh is needed (varies by skin type, lifestyle, and pigment)

When to seek medical attention

• Signs of infection: increasing redness, warmth, pus, fever
• Severe swelling (especially around the eyes for eyeliner treatments)
• Allergic reaction: widespread rash, difficulty breathing (rare but serious - call 999)

Infection control

The same infection control standards apply as for tattooing (see Guide 7.5). Key points:

• Single-use needles and blades (microblading blades are always single-use)
• Nitrile gloves, changed if contaminated during the procedure
• Autoclave for any reusable equipment
• Sharps disposal in BS 7320 compliant containers
• Licensed waste carrier for clinical waste
• Clean, non-porous treatment surfaces
• Hand washing before and after every client

Specific risks by treatment area

For lip treatments: always ask about cold sore history. Lip procedures frequently trigger herpes simplex reactivation, even in clients who haven't had an outbreak for years. Many practitioners recommend clients take aciclovir (antiviral) for 3-5 days before and after treatment. The client should get this from their GP.

What to do next

1. Get a Level 4 qualification if you don't have one
2. Register with your local authority (both you and your premises)
3. Get specialist SPMU treatment risk insurance
4. Set up a thorough consultation and consent process
5. Establish a patch test protocol (and document it)
6. Create comprehensive aftercare documentation
7. Ensure your infection control procedures match tattooing standards
8. Keep CPD records - the industry changes fast

Who to Contact

• Your local council Environmental Health department - registration and licensing (Free)
• HSE (Health and Safety Executive): 0300 003 1647 (Free) - hse.gov.uk - workplace safety
• HMRC Self Assessment: 0300 200 3310 (Free)
• Citizens Advice: 0800 144 8848 (Free)
• VTCT / ITEC / City & Guilds - Level 4 qualifications in micropigmentation
• SPMU professional bodies - British Association of Cosmetic Nurses (BACN), Society of Permanent Cosmetics Professionals (SPCP)
• Your insurer - specialist SPMU cover
• Pigment manufacturers - safety data sheets, training programmes

Sources

• Local Government (Miscellaneous Provisions) Act 1982
• Tattooing of Minors Act 1969 (applies to SPMU on under-18s)
• Health and Safety at Work etc. Act 1974
• General Product Safety Regulations 2005
• UK REACH Regulation - tattoo and PMU ink restrictions
• Health Education England Core Competencies Framework
• UKHSA guidance on infection control in skin-piercing procedures
• New aesthetics licensing scheme guidance (green tier)

Related Guides

• Guide 7.5 - Tattooing and Piercing: Licensing Requirements
• Guide 7.6 - Laser and IPL: Qualification and Insurance Requirements
• Guide 7.8 - Advertising Rules for Beauty and Aesthetics
• Insurance by Specialism
• GDPR for Beauty Workers
• Safeguarding Under-16s and Vulnerable Adults

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