2.2 Scope of Practice and Prohibited Practices

Illinois scope of practice is a surface-of-the-skin license. If you remember only one legal sentence from this chapter, remember this: estheticians may use techniques, products, and devices that affect the stratum corneum for cosmetic or beautifying purposes, and they are prohibited from using techniques, products, and practices intended to affect the living layers of the skin. That line is in 225 ILCS 410/3A-1. IDFPR restated it in the Statement on Prohibited Practices dated 04/06/2026. Public Act 104-0134 also made using a living-layer technique a listed ground for discipline (Section 4-7) and a listed criminal violation (Section 4-20).

The Statutory Definition: 225 ILCS 410/3A-1

Section 3A-1(A) says any one or combination of the following, when done for cosmetic or beautifying purposes and not for the treatment of disease or of a muscular or nervous disorder, constitutes esthetics:

1. Beautifying, massaging, cleansing, exfoliating, or stimulating the stratum corneum of the epidermis by cosmetic preparations, including superficial exfoliants, body treatments, body wraps, hydrotherapy, or any device, electrical, mechanical, or otherwise, for the care of the skin, including microdermabrasion, hydrodermabrasion, and dermaplaning.
2. Applying makeup or eyelashes, or lightening or coloring hair on the body except the scalp.
3. Removing superfluous hair from the body of any person.

Section 3A-1(B) defines an esthetician as a person who, with hands or mechanical or electrical apparatus, uses cosmetic preparations, body treatments, wraps, hydrotherapy, makeups, antiseptics, tonics, lotions, creams, or other preparations, or practices massaging, cleansing, exfoliating the stratum corneum, stimulating, manipulating, beautifying, grooming, threading, or similar work on the face, neck, arms, hands, or body in a superficial mode, and not for the treatment of medical disorders.

Two limits sit in the same section. Esthetics does not include services provided by a cosmetologist or electrologist as those professions are defined. You may render advice on what is cosmetically appealing. You may not render advice on what is appropriate medical treatment for diseases of the skin.

Illinois school curriculum treats facial massage as non-therapeutic skin massage. Scalp work is a cosmetology/barbering lane, not an esthetics curriculum block. On the exam, “massage” in an esthetics stem means cosmetic manipulation of the skin, not physical-therapy or medical massage, and not a scalp treatment billed as esthetics.

What Surface Services Look Like in the Treatment Room

Translate the statute into services you will actually perform:

• Cleansing, toning, masking, and moisturizing the face and body for cosmetic purposes.
• Non-therapeutic massage of the skin (effleurage, petrissage, and similar cosmetic manipulations).
• Superficial exfoliation that stays in the stratum corneum: enzymes, superficial chemical peels, gentle mechanical exfoliation.
• Cosmetic preparations and product recommendation for appearance, not as a medical treatment plan.
• Makeup, false eyelashes, and lash or brow cosmetic services that do not implant pigment into living dermis.
• Hair removal by wax, tweezers, depilatory, or threading.
• Body treatments and wraps, including cosmetic hydrotherapy.
• Microdermabrasion and hydrodermabrasion when they are used as surface services to remove dead cells, oil, and debris—not as dermal injury.
• Dermaplaning as a surface-skin esthetics service after Public Act 104-0134.

If a device or product is marketed as “medical grade,” “dermal remodeling,” or “collagen induction,” read the intended depth. Marketing language does not expand your license. 1175.115(d) also requires that any manual or mechanical device used in the practice be used consistent with the manufacturer’s intended use, client safety, and services within the licensee’s scope.

Public Act 104-0134 and Dermaplaning

Public Act 104-0134 (Senate Bill 2154), effective August 1, 2025, amended Section 3A-1 to name microdermabrasion, hydrodermabrasion, and dermaplaning as examples of devices and methods for care of the skin at the stratum corneum. Before that amendment, dermaplaning sat in a gray zone because older IDFPR statements had listed it among procedures that were not esthetics. The 2025 Act resolved the gray zone: dermaplaning is within surface-skin esthetics when it is done for cosmetic or beautifying purposes and is not used to treat disease.

That confirmation is not a blank check. A blade used to shave stratum corneum is esthetics. A blade or device used to wound living epidermis or dermis, or marketed as a medical procedure, is not. Keep the service cosmetic, superficial, and documented as esthetics—not as a medical peel or as a substitute for a dermatologic procedure.

The Living-Layers Line: IDFPR Statement on Prohibited Practices (04/06/2026)

IDFPR’s Statement on Prohibited Practices, dated 04/06/2026, is the current Department statement on the profession page. Cosmetologists and estheticians are prohibited from using any technique, product, or practice intended to affect the living layers of the skin, citing 225 ILCS 410/3-1 and 410/3A-1.

The statement lists procedures that constitute the practice of medicine and are not within the scope of a cosmetologist or an esthetician:

Memorize the list. Then memorize the exception that trips people: superficial chemical peels remain in scope because they target the stratum corneum. “Chemical peel” without the word superficial is the exam trap. A medium or deep peel is medicine. An AHA, BHA, or enzyme peel kept at the dead-cell layer is esthetics.

Microneedling is not “advanced exfoliation.” Microblading is not “makeup.” Radio frequency is not “a facial machine like a steamer.” Botox is not “an esthetic finishing product.” Those rebrands do not move the procedure into Article IIIA.

Physician Delegation: When a Medical Procedure Is Performed by a Non-Physician

The 04/06/2026 statement addresses the medspa fact pattern: a physician wants an esthetician to perform a medical procedure. Delegation does not enlarge the esthetics license. If a licensed physician delegates one of the listed procedures, the individual may not hold himself or herself out as a cosmetologist or an esthetician while performing the delegated procedure and may not indicate in any manner that the delegated procedure is part of the practice of cosmetology or esthetics.

Delegation is valid only when all of the following are true:

• The person receiving services is a patient of the physician (a physician-patient relationship exists).
• The physician examines the patient and determines the appropriateness and the course of treatment.
• The person receiving the delegation carries out the treatment as instructed.
• The work is not represented as esthetics.

If any piece is missing—no exam, no physician-patient relationship, standing “Botox Fridays” under an esthetician’s name, or a menu that lists injectables as an esthetics add-on—the arrangement is not lawful esthetics practice. You are either practicing medicine without a license or holding out a medical service as esthetics, both of which the Act now treats as disciplinary and, for living-layer techniques, as a listed violation under Section 4-20.

Lasers and the Medspa Memo

IDFPR’s Statement Regarding Lasers is linked from the esthetician page. Laser hair removal and similar laser procedures are medical. A physician must examine the patient first. A laser is not an esthetician-scope device just because a spa owns one or a manufacturer will train an esthetician on it. Completing a laser certificate does not amend 225 ILCS 410.

On October 30, 2025, IDFPR and IDPH issued an updated medspa memo. It flags that many Illinois medical spas perform non-surgical cosmetic procedures that are medical, including injections of botulinum toxin (Botox), weight-loss medication injections, dermal fillers, laser hair removal, platelet-rich plasma (PRP), and vitamins. The memo stresses infection prevention and compliance with both IDFPR professional-practice rules and IDPH public-health rules. Injections, fillers, laser, and PRP are not esthetics services. They belong on a medical practice’s treatment plan, with medical infection-control standards, not on an esthetician’s independent menu.

High-Yield Trap: Superficial Versus Medium or Deep Peels

Exam writers like stems in which a client wants “a stronger peel,” a supervisor tells you to “just go a little deeper,” or a product label says “medical peel” or “dermal peel.” The correct professional response is to stay at the stratum corneum or to refer. Depth, not the brand name, decides the legal question.

The same depth test applies to devices. Surface microdermabrasion or hydrodermabrasion that removes dead cells is in the statute. A setting, crystal, or tip protocol intended to injure living layers is not. Dermaplaning is in; microneedling is out. Wax is in; laser hair removal is out. Tinted brow henna or cosmetic tint, depending on product and depth, is still a surface cosmetic service; microblading is pigment placed into living skin and is listed as medicine.

When you are unsure, ask: Is this intended to affect only the stratum corneum for cosmetic purposes? If the honest answer is no, it is not Illinois esthetics.