Many salons, spas, and other businesses require their makeup artist employees to have a cosmetology license or one of the other beauty practitioner licenses. But what if you don’t want to be employed, what if you want to be your own boss and become a Freelance Makeup Artist? As a lawyer, you need to be licensed to practice the law. It’s the same for engineers, social workers, nurses, architects, etc. So, where are Makeup Artists in this?

First of all, there is no Freelance Makeup Artist or general Makeup Artist license. If a professional license is required, depending on what you do, you’ll either need a cosmetology, esthetician, or hairdresser/barber license. When you need such a beauty license is regulated by each state. Let Jen’s story be a cautionary tale. Thus, if you are unsure, the best advice we can give is to contact the cosmetology board of your state and inquire about the license requirements for your specific situation. You can find the contact information for your state here: Beauty Licenses per State.

We know that this is very unsatisfying advice and so we contacted every state board to find out if there are any common rules applicable to most states.

This is what we wrote:

Dear
[Name],
It is often said that a freelance Makeup Artist doesn’t need a Cosmetology license. However, I’ve heard from some Makeup Artists that they were required to have a beauty (cosmetology/esthetician) license from their state to lawfully do business as freelance Makeup Artists. I agree that a cosmetology license is always a good investment in terms of education, but I could not find out whether it is mandatory for freelance Makeup Artists in your state.
Could you help me out with this question?
Thank you,

We are posting this here to be transparent about what we asked because the situation is not always very clear in every state. In general, we can sort the answers into four categories.

 

1. No license needed under certain conditions

In other words, you generally need a license to apply makeup unless one of the below-listed exceptions applies. This is the situation in most states.

Exception 1: Media and theatrical makeup work

“Yes, it is required to have either a cosmetology or aesthetic license to perform makeup services in Arizona, with the exception of media or theatrical.”

Arizona State Board of Cosmetology

Exception 2: Retail

If there is a fee or exchange, then you must possess a cosmetology or esthetics license to apply makeup.  If you will be providing complimentary facials (with no strings attached: such as working at cosmetic counters in stores), or working for theater or tv or movies, then you do not need to possess a license.

NYS Department of State, Division of Licensing Services

 

Exception3: Military or Doctors

“Nevada statute NRS 644.025 defines the practice of aesthetics in Nevada. This law includes beautifying the skin with cosmetics. Makeup services may be performed by licensed cosmetologists or aestheticians in Nevada. There are some exemptions set forth in the law under NRS 644.190 and NRS 644.460 which cover working on a motion picture or similar production, retailers, photographers, doctors, military and other exemptions.”

Nevada State Board of Cosmetology

Exception 4: Unpaid work

“It would depend, there are some exceptions in the law.
7319.  The following persons are exempt from this chapter:
…(d) Persons engaged in any practice within its scope when done outside of a licensed establishment, without compensation….”

California Board of Barbering and Cosmetology

 

Here is the list of states in this category (exceptions that not require a license in parentheses):

  • Arizona (media, theatrical)
  • California (military/doctors, theatrical, media, retail, unpaid)
  • Florida (unpaid, retail)
  • Indiana (medical, unpaid)
  • Iowa (medical settings)
  • Kansas (retail)
  • Kentucky (retail)
  • Minnesota (theatrical, media, mortuary practice)
  • Montana (theatrical, media, unpaid)
  • Nevada (theatrical, media, military/doctors, retail)
  • New England (retail)
  • New York (theatrical, media, unpaid, retail)
  • Oregon (photography, theatrical)
  • South Dakota (retail)
  • Tennessee (retail)
  • Texas (medical profession, unpaid, theatrical, media, photography)

2. You always need a license for makeup application

These states don’t specify any exemptions, consequently, you need to have a license regardless.

To provide “make-up” services in the State of Alaska requires you hold an active/current Esthetician license issued by the Alaska Board of Barbers & Hairdressers.

Alaska Board of Barbers & Hairdressers

States in this category are:

  • Alabama*
  • Alaska**
  • Colorado
  • Hawaii
  • Idaho
  • Louisiana
  • Maine
  • Missouri
  • North Carolina*
  • North Dakota
  • South Carolina
  • West Virginia

*Unpaid work may be exempt, but not if it happens in a business setting, e.g. in retail.

** Hairdressing is exempt, You can apply for a Hairdresser Courtesy License to work on a television, film, or stage production.

 

3. You don’t need a license for makeup application

Yes, there are indeed some states that apparently don’t require any license for the application of makeup:

From Washington (Professional Licensing Support Services) we received this response:

At this time makeup artists are not regulated in Washington state and they are not required to have a cosmetology or esthetician license.

States in this category are:
  • Arkansas (unless you are working in a licensed salon)
  • Maryland
  • Washington
  • Michigan
 

 4. Unclear or no response

Unfortunately, for a couple of states it was impossible to get a response via email. Email was important for us to have at least some written reference. In some cases we would get an answer, which ended up not being an answer at all:

” The Department of Licensing and Regulatory Affairs, CSCL Bureau, and its employees cannot provide legal advice and you may wish to consult an attorney to discuss legal matters pertinent to your individual situation; however, licensing requirements for cosmetologists are established in the Occupational Code, 1980 PA 299, as amended, which can be found at www.michigan.gov/cosmetology.  However, you may wish to look at the section of definitions under MCL 339.1201, in particular, the definition of skin care services under MCL 339.1201(q).”
In other cases, I think, I am just not smart enough to understand what that means:
Per Virginia Code § 54.1-701.10. Exemptions., “persons whose activities are confined solely to applying make-up, including such activities that are ancillary to applying make-up” are exempt from regulation and licensing by this Board.
Does it mean this board does not regulate it, and another board does? In some cases I got bounced around between different departments , which all claimed not to be responsible. Or do you actually not need a license in Virginia if you are only applying makeup? I would ask a legal professional to
If you haven’t found your state among the first three categories  then we are sorry to disappoint you. As soon as we get additional information, we will add it to this post. If you have additional information, please let us know in the comments.
 
Disclaimers
What was expressed in the response of Michigan’s Department of Licensing and Regulatory Affairs is very valid for us: We cannot provide legal advice nor are attempting to. Don’t rely on the information presented here and always consult professionals with regards to your situation. Although the information presented in this post is based on responses we received from the various state boards, it is quite possible that it is wrong, not complete or has changed at the time when you read this post. Please also note that this post only discusses beauty professional licenses and not other licenses required to operate your business.