Michigan’s New Law:

On September 11, 2025, Michigan’s Department of Health & Human Services (MDHHS) rolled out new body art facility rules. Among the most important changes:

Artists can no longer apply topical anesthetics (numbing creams, gels, or sprays) during a body art procedure unless the anesthetic is prescribed by a licensed physician, with dosage and instructions documented in the client’s file.

This rule is for all MI body art: tattoos, piercings, and permanent makeup (PMU).

What?

No Numbing cream?

Wait, I need my numbing cream!

Anesthetic use is pretty standard practice for PMU artists across the board.  The skin of the face is thinner and more sensitive than other areas for body art, and the eyeliner and lips are so sensitive that many clients will simply choose not to undergo the procedure without numbing agents.

In fact, we have already begun hearing reports of clients cancelling appointments because they do not want to be in pain. Numbing is a very important aspect of our work as artists!

Why the Law Changed

Michigan regulators want consistent, clear standards for body art safety. Before this change, numbing cream use varied widely — some artists used over-the-counter (OTC) creams that were allowed, and some did… not. OTC numbing agents are supposed to top out at 5%, but (at least in recent history) if you look hard enough you can find creams with higher percentages.

Higher percentages means higher risks for adverse reactions to anesthetic, which can include skin burns, dizziness, vomiting, seizures, irregular heartbeat, cardiac arrest, fatigue, confusion, shortness of breath, blue/gray fingertips or lips, and death (in extreme cases).

The new law removes the risk: unless it’s a prescription and it has been documented, numbing agents cannot be applied by the artist.

What This Means for PMU vs. Tattoo Artists

You can’t do it! Your clients will need a prescription to use numbing cream. But since your clients can easily buy an OTC cream at the store, they technically could apply at home and then come in.

The language of the law appears to disallow this, but interpretation may vary as health departments refine and clarify their enforcement. As an artist, it is implied that you are not supposed to tattoo over skin that has been numbed with anything except a prescribed cream.

This is inconvenient for body artists, but very prohibitive to PMU artists in particular.

Something important: Tattooing and permanent makeup aren’t the same when it comes to anesthetic needs.

• Tattooing: Large areas of skin may be numbed, which increases the concern of adverse effects.
• PMU: Only small, highly sensitive areas (lips, brows, eyeliner) are involved. Artists typically use very small amounts of numbing for client comfort during delicate facial procedures.

This difference is huge — but under the law, both practices fall under the same regulation. We are currently enquiring with technicians and regulators to see what may be done for PMU artists.

Risks and Benefits of Anesthetics in PMU

Benefits

• Client comfort: Brow, eyeliner, and lip procedures are more tolerable with numbing, allowing clients to stay still and relaxed.
• Better experience: Reducing pain improves trust and overall satisfaction with PMU services.
• Precision for artists: We didn’t get into this business to hurt anyone! A comfortable client helps us focus on our work without anxiety over pain management.

Risks

• Unsafe creams: Using OTC anesthetics that are not FDA registered or do not follow FDA rules may use amounts of anesthetics that are too high.  Anesthetic ingredients that are over 5% can introduce higher percentages of anesthetic into the bloodstream and cause real danger to clients.
• Unsafe usage: Occluding the skin with plastic wrap after applying numbing cream traps the anesthetic directly onto the skin and then forces into the bloodstream. This effect increases the strength of numbing, and allows it to absorb faster, but increases risks of irregular heartbeat and cardiac arrest, especially when done over a large area, like a chest or back piece.

SofTap’s Role in Client Comfort

One of the advantages of SofTap® permanent makeup is that it’s already known as one of the gentlest PMU methods. The manual, hand-tapping technique causes less trauma and is naturally more comfortable for clients compared to machine tattooing.

• Procedures often feel tolerable without strong numbing agents. Brows may be completed without any anesthetic. We still use OTC creams for extra comfort for eyeliner and lips, however.
• If stronger numbing is needed, artists can suggest that clients contact their doctor for physician-prescribed options.

How Michigan PMU Artists Can Adapt

1. Remove all numbing from your station.
2. Educate your clients — let them know Michigan law changed in September 2025, and you cannot legally apply OTC anesthetics anymore.
3. Find prescription options — clients can contact their physicians to prescribe strong numbing cream.
4. Document thoroughly — prescriptions, directions, and dosage must be in each client’s file.
5. Highlight your technique — if you’re a SofTap artist, emphasize that SofTap is gentle, precise, and often doesn’t require strong numbing in the first place.

Final Thoughts

This is a big deal for MI artists. No numbing cream for PMU means less procedures for artists because clients are (justifiably) more timid about booking.

From a PMU artist’s perspective, it is important to comply with all of your local laws. However, the need for numbing cream in PMU is different than other areas of body art. The sensitive skin of the face ought to have more consideration with regards to the acute pain of tattooing.

Are you a PMU artist? Consider writing to your local health department and voicing your concerns. This country is a great one, and your voice matters—as long as you use it.

Until next time, Happy Tapping!

Disclaimer: This article is for informational purposes only and does not constitute legal advice. Always check your state and local regulations before performing any procedure.

FAQ: Michigan’s New Anesthetic Rules for PMU Artists

Q: Can PMU artists in Michigan still use numbing cream?
A: Only if the product is prescribed by a licensed physician and the prescription details are documented in the client’s file. Over-the-counter numbing creams may no longer be applied by PMU artists.

Q: Does this rule apply to permanent makeup as well as tattoos?
A: Yes. Michigan’s September 2025 body art rules cover all forms of body art, including tattooing, piercing, and permanent makeup (PMU).

Q: Can clients apply their own numbing cream before an appointment?
A: The new law restricts what the artist can apply, not what a client chooses to do at home.

Q: How is PMU different from tattooing when it comes to anesthetics?
A: Tattoos often involve numbing large skin areas, which raises concerns. PMU targets small, delicate areas on the face, typically requiring only a small amount of numbing. Despite these differences, both are treated the same under Michigan’s new law.

Q: How can SofTap artists keep clients comfortable without anesthetics?
A: SofTap’s hand-tapping technique is already the most gentle PMU method available, minimizing discomfort naturally. Other body artists can also work in shorter sessions and encourage clients to seek physician-prescribed numbing if needed.