1.4 Scope of Practice by License Type & Services Exempt from Licensing
Key Takeaways
Minn. Stat. 155A.27 requires an individual license to practice as a cosmetologist, esthetician, hair technician, nail technician, eyelash technician, advanced practice esthetician, manager or instructor.
Cosmetology under Minn. R. 2105.0105 includes all esthetics, nail technology and eyelash extension services, but not advanced practice esthetic services.
Microdermabrasion, dermaplaning, chemical exfoliation beyond the stratum corneum, electrical energy treatments, lymphatic drainage, lancet extractions and skin needling are advanced practice services only (Minn. R. 2105.0105, subp. 5).
Nail technicians may not wax, do eyelash or eyebrow enhancements, or use any tool or equipment that penetrates the skin (Minn. R. 2105.0105, subp. 3).
Threading is exempt from licensing, and people who do only hairstyling and makeup are exempt if they complete a four-hour board-approved health, safety and law course and carry proof (Minn. Stat. 155A.27, subd. 9).
Why this section matters
The state exam's General Information domain lists scope of practice for cosmetology, esthiology, nail technology and eyelash technology (Minn. R. 2105.0105). Scope questions are usually scenarios: "A nail technician is asked to..." or "Which licensee may perform...?" Learn each subpart's lists and the services that are reserved for advanced practice estheticians.
Who needs a license
Under Minn. Stat. 155A.27, subd. 1, a person must hold an individual license to practice as a cosmetologist, esthetician, hair technician, nail technician, eyelash technician, advanced practice esthetician, manager or instructor. Licenses are classified by field, and a license allows only that field's services.
Cosmetology (Minn. R. 2105.0105, subp. 1)
The practice of cosmetology includes the services in 155A.23, subd. 3 plus everything in subparts 2, 3 and 4 (esthetics, nail technology and eyelash technology). It specifically includes:
- A. Shampooing, conditioning, cutting, clipping, coloring, dressing, processing, shaping, straightening, bleaching, tinting, styling, blow-drying or waving a person's hair, eyebrows or eyelashes
- B. Styling, cutting and coloring wigs when on a person's head
- C. Cleansing, massaging and stimulating the scalp
- D. Using a razor to remove hair from the head, face and neck
- E. Other cosmetic care of the hair, head and scalp
Cosmetology does not include advanced practice esthetic services (subp. 5). A cosmetologist does not need a separate esthetician, nail technician or eyelash technician license, but may get one (Minn. R. 2105.0145, subp. 5).
Esthetics (subp. 2)
Esthiology is the cosmetic treatment of the stratum corneum of the epidermis. It includes eyelash technology and:
- A. Cleansing, stimulating or massaging the scalp, face, neck, arms, legs or trunk, with or without cosmetic preparations
- B. Cosmetic care of the face, eyelashes, eyebrows, lips, nose, neck, arms, legs or trunk with preparations, paraffin, clay, cream or makeup
- C. Basic exfoliation, manual or machine skin cleansing, and basic extractions (gloved fingers, cotton swabs or comedone extractors)
- D. Hair removal with depilatories, waxes, sugaring or tweezing
- E. Makeup and airbrush makeup, eyelash and eyebrow tinting, brow shaping and trimming, lash and brow enhancements, facials and body wraps
- F. Other cosmetic services on the stratum corneum
Nail technology (subp. 3)
Nail technology is cosmetic care of the hands, feet and nails: cleansing, removing polish, cutting, trimming, polishing, tinting, coloring and manicuring; attaching and removing acrylic and other artificial nails; skin care of hands and feet including paraffin; callus removal with products, sanding, buffing or filing; and massaging hands, feet, lower arms and legs during a nail service. Nail technicians may not wax, perform lash or brow enhancements or any other esthetician service, and must not use any tool or equipment to penetrate the skin.
Eyelash technology (subp. 4; 155A.23, subds. 4a and 4b)
Limited to applying, removing and trimming natural or synthetic fibers attached to an eyelash, including cleansing the eye area and lashes. It excludes color agents, straightening agents, perm solutions, bleaching, eyebrow applications and any other cosmetology service. An eyelash technician license needs 14 training hours; estheticians, AP estheticians and cosmetologists already have eyelash extension in their scope.
Advanced practice esthetics (subp. 5)
AP esthetics covers the epidermis beyond the stratum corneum and includes all esthetic services plus:
| AP-only service | Examples |
|---|---|
| Advanced exfoliation | Dermaplaning, microdermabrasion, chemical or enzyme exfoliation that goes beyond the stratum corneum |
| Electrical energy treatments | Light therapy, galvanic current, microcurrent, high frequency, radio frequency, sound waves |
| Other | Lymphatic drainage, advanced extractions with lancets or needles, skin needling |
Laser is the practice of medicine under Minn. Stat. 147.081 and is never an AP service. An AP esthetician license supersedes an esthetician license.
Hair technician (155A.23, subd. 21)
A hair technician provides cosmetic care of hair on the scalp, including cutting and applying dyes, bleach, reactive chemicals, keratin or other products that color or alter the hair's structure. A person who only performs hairstyling is not a hair technician.
Quick scope map
| Service | Cosmetologist | Esthetician | AP esthetician | Nail technician | Eyelash technician |
|---|---|---|---|---|---|
| Haircut, color, perm, relaxer | Yes | No | No | No | No |
| Basic facial, basic extraction, waxing | Yes | Yes | Yes | No | No |
| Makeup, brow and lash tint | Yes | Yes | Yes | No | No |
| Eyelash extensions | Yes | Yes | Yes | No | Yes |
| Manicure, pedicure, enhancements | Yes | No | No | Yes | No |
| Microdermabrasion, dermaplaning, lancet extraction | No | No | Yes | No | No |
Exempt and unregulated activities
Exempt from licensing (Minn. Stat. 155A.27, subd. 9):
- Licensees from other states doing demonstrations in Minnesota, if services are performed in the physical presence of a licensed cosmetologist
- Threading
- People who perform only hairstyling and makeup, if they complete a four-hour board-approved course in health, safety, infection control and state law and carry proof of completion while working. Hairstyling (155A.23, subd. 19) is cleaning, drying, arranging or styling hair, including extensions and wigs, but not cutting or applying color, bleach, reactive chemicals or keratin.
Unregulated services (Minn. R. 2105.0010, subp. 13) are outside the board's authority: ear piercing, body art and body painting, henna and permanent tattoos, eyebrow embroidery and microblading, permanent hair removal, permanent makeup, UV and spray tanning, injectables, theatrical and media makeup, mortuary services, massage, body wraps and lymphatic drainage by a massage therapist, the practice of medicine, hair braiding, and threading. Barbering is regulated by a different board (Minn. Stat. chapter 154).
Important
A private weekend certificate does not expand a Minnesota license. Before offering any new service or device, Minn. R. 2105.0190, subp. 1a requires you to confirm it is inside your license's scope, follow the manufacturer's directions and keep your training records.
A licensed nail technician is asked to apply eyelash extensions. Under Minnesota rules, who could legally provide this service instead?
A cosmetologist, esthetician, advanced practice esthetician or licensed eyelash technician
Only an advanced practice esthetician
Any licensee who completed a private weekend certificate
Only a licensed cosmetologist, because cosmetology is the only license that includes all eye-area services
Which service is reserved for advanced practice estheticians and is outside a cosmetologist's scope?
Eyebrow tinting
Microdermabrasion
Soft waxing of the upper lip
Basic extractions with a comedone extractor
Which activity does Minnesota exempt from cosmetology licensing?
Applying gel polish for tips
Applying single-process color in a client's home
Blow-drying and cutting hair at a wedding
Threading eyebrows
What may a Minnesota nail technician use to reduce a client's calluses?
Callus removal products, sanding, buffing or filing
A credo blade if it is sterilized between clients
A disposable razor-type callus shaver
A lancet to drain a corn
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