21.3 Student Permits, Shampoo Permits, Temporary Permits, and Unlicensed Practice

Keep the FAQ and the 2025 statute on two lines

This is the easiest Domain 6 trap in the guide. The Board FAQ (last modified May 2, 2025) and P.L. 2025, c.18 (approved February 3, 2025) do not say the same sentence. Teach both. Do not merge them into "students may work after 60 hours" or into "nothing changed in 2025."

Board FAQ question 2: you may practice cosmetology and hairstyling while attending school if you hold a student permit, which can be obtained once you have completed half of the required training. For a 1,200-hour C-H student, half is 600 hours. N.J.A.C. 13:28-1.3(b) still says the Board shall issue a student permit, consistent with the student's course work, to a student registered at a licensed New Jersey school or enrolled in a State-approved high school or vocational program. The application takes the N.J.A.C. 13:28-5.1 fee ($5) and a school certification that the student completed the requisite hours in N.J.S.A. 45:5B-3(r) and N.J.A.C. 13:28-6.29 through 6.34. Subsection (r) is the senior student definition: a registered student who has successfully completed one-half of the total hours required for that license. N.J.A.C. 13:28-5.1 also charges $5 for a student registration card, which is not the same document as the permit.

P.L. 2025, c.18 amended N.J.S.A. 45:5B-3 and 45:5B-25. It defines a junior student (N.J.S.A. 45:5B-3(ff)) as a registered student who has completed less than one-half of the hours for C-H, beautician, barber, manicurist, skin care specialist, or hair braider. A senior student remains the half-hours student (N.J.S.A. 45:5B-3(r)). It defines a shampoo permit (N.J.S.A. 45:5B-3(gg)) as a permit that enables a registered C-H, beauty-culture, or barbering student who has successfully completed 60 hours of relevant coursework to shampoo and rinse hair. N.J.S.A. 45:5B-25(b) states the junior-student eligibility test: at least 60 hours of relevant course instruction, and no communicable, contagious, or infectious disease that could reasonably be expected to be transmitted during shampoo and hair-rinsing services. N.J.S.A. 45:5B-25(a) states student-permit eligibility as registered-student status plus the same health showing. N.J.S.A. 45:5B-25(c) says permits remain valid only while the student is registered or enrolled and expire upon graduation, withdrawal, or a leave of absence of more than 90 consecutive days.

Sections 1 through 4 of the 2025 act (definitions, Board duties, the license-requirement exceptions, and student/shampoo permit eligibility) took effect 90 days after enactment. Sections 5 through 8 create a separate shampoo technician certification for people not enrolled in a license program (60-hour school or shop training, a practical examination, Board certification, biennial renewal). Those sections take effect on the first day of the thirteenth month after enactment and require the Board to promulgate rules. That is the delayed non-student pathway. Do not tell a graduate to work as a "shampoo tech" under sections 5–8 as if the Board FAQ already lists that certification. N.J.S.A. 45:5B-7(g), in sections 1–4, already excepts persons employed as shampoo technicians from the general license-before-service rule; that exception is not a substitute for a Board-issued certification under the delayed sections.

Put the two sources in one sentence you can actually use: FAQ and N.J.A.C. 13:28-1.3 still describe a student permit after half the hours; the 2025 statute adds a junior-student shampoo permit after 60 hours for shampooing and rinsing only; the non-student shampoo-technician certificate in sections 5–8 is delayed and rule-dependent.

Where a student permit actually lets you work

N.J.S.A. 45:5B-7(f) excepts registered students holding a student permit provided that those services are rendered in a school clinic or licensed shop during hours that the student does not have scheduled classes. The permit is not a freelance C-H license. It is not permission to skip school, work during class time, or set up a chair in a basement.

N.J.S.A. 45:5B-8 and 45:5B-12(g) close the other door: it is unlawful to engage in these practices in premises not licensed as a shop or school, except the narrow 45:5B-8 list (health-care facilities, certain institutions, a disability home visit sponsored by a licensed shop with a shop record, performers or models around a performance, unpaid retail demonstration). Board FAQ item 7: "in-house" practice is illegal, with those statutory exceptions. N.J.S.A. 45:5B-12(e) also makes it unlawful to aid, abet, or knowingly permit an unlicensed person to render the services.

Scenario: the student asked to work off-site

Maya is a senior C-H student with a $5 student permit. A cousin offers $80 for bridal updos in the cousin's apartment on Saturday, while Maya has no scheduled classes. Maya wants the money and thinks the permit covers "any practice while I am still in school." It does not. N.J.S.A. 45:5B-7(f) locates student-permit services in a school clinic or licensed shop. An apartment is neither. N.J.S.A. 45:5B-8 and 45:5B-12(g) treat unlicensed premises as unlawful practice. The lawful version of the same Saturday is a paid clinic appointment at school or a shift in a licensed shop that is allowed to host senior students, not a house call. If Maya has only a shampoo permit (60 hours, junior student), she may not hide a bridal updo inside "shampoo and rinse."

Temporary permits: 120 days, upon request, one time

N.J.A.C. 13:28-1.3(a): upon the Board's acceptance of an application to sit for an examination, a temporary permit, valid for 120 days, shall be issued upon request to an applicant for a practicing license. N.J.A.C. 13:28-5.1 sets the fee at $20.

N.J.S.A. 45:5B-26: after satisfactory evidence of eligibility and payment of the Board fee, the applicant is scheduled for examination and issued a temporary permit to engage in the practice sought. The permit remains valid for no more than 120 days and expires upon receipt of the newly issued license. Only one temporary permit shall be issued to an applicant. No temporary permit is issued to applicants awaiting the teacher examination.

Board FAQ item 8: the temporary permit cannot be extended. It is valid for 120 days and may be issued only one time while you wait to be scheduled for the examination. Once it expires, if you do not have your license, you must stop practicing until you receive the license.

Hold those three sources side by side. The rule emphasizes upon request after the Board accepts the exam application. The statute emphasizes scheduling, a 120-day cap, one permit only, and no teacher temp. The FAQ answers the working graduate who wants more time: no extension, no second permit, stop when it expires.

Scenario: the graduate who wants a second temporary permit

Andre completed 1,200 hours, paid the $50 Board examination fee, requested the $20 temporary permit, and worked in a licensed shop. He scored at least 75 percent on theory, then failed the practical near the end of the 120 days. The shop wants him on the floor next week and tells him to "just renew the temp." He cannot. FAQ item 8 and N.J.S.A. 45:5B-26 allow one 120-day permit and no extension. When it expires without a license in hand, he stops practicing until the license is issued. Unlicensed work after that date is not a paperwork delay; it is unlicensed practice. He reschedules the practical, pays the current Prometric practical fee published at scheduling (this guide does not invent that dollar amount), and stays off the floor until he is licensed. A second $20 payment does not create a second permit.

Unlicensed practice and the penalty the FAQ publishes

Board FAQ item 13: the Board may investigate and penalize unlawful, including unlicensed, practice. In addition to suspension or revocation of a license, an individual may be subject to a civil penalty of not more than $10,000 for a first violation and not more than $20,000 for each additional second and subsequent violation of a law or regulation the Board administers (the FAQ cites the N.J.S.A. 45:1-25 structure). Performing cosmetology services for payment without a Board license is the example the FAQ gives. A licensee who performs services that are noncompliant with existing law may also be penalized. Violations are determined case by case.

N.J.S.A. 45:5B-12 adds a list of unlawful practices: misleading advertising; practicing under another's name; continuing to practice with a transmissible infectious disease; fraudulent financial-aid practices; aiding unlicensed practice; failing to display a practicing license; and practicing in unlicensed premises except as 45:5B-8 allows.

The working rules for this exam are simple. A student permit (FAQ/rule: after half the hours) authorizes course-consistent work in a clinic or licensed shop outside scheduled classes. A shampoo permit (2025 statute: 60 relevant hours, junior C-H/beauty/barber student) authorizes shampooing and rinsing, not a full C-H service menu. A temporary permit is 120 days, $20, once, upon request after the Board accepts the exam application; then stop until licensed. Sections 5–8 of P.L. 2025, c.18 are the delayed shampoo-technician certification. Shop, EPL, mini-suite, 350 square feet, and the N.J.A.C. 13:28-2.15 prohibited list remain Chapter 22.

The shampoo-permit fee is unpublished on the N.J.A.C. 13:28-5.1 table extracted for this chapter. Do not invent a dollar amount for it. The practical-exam vendor fee remains unpublished on the Prometric written-fee listing used here; pay the amount posted at scheduling.