Texas med spa & injectable regulations

Practicing medicine without a license in Texas is a third-degree felony, and each day of unlicensed practice is a separate offense.

Tex. Occ. Code §165.152

The Texas Medical Board may issue a cease-and-desist order against an unlicensed person it believes is practicing medicine.

Tex. Occ. Code §165.052

Holding out — through advertising, titles, or stationery — as entitled to practice medicine without a license is a criminal offense, reachable against an individual or a business entity.

Tex. Occ. Code §165.156

Two enumerated forms of unprofessional or dishonorable conduct likely to deceive or defraud the public reach a med spa directly. One is a physician who “fails to supervise adequately the activities of those acting under the supervision of the physician”. The other is a physician who “delegates professional medical responsibility or acts to a person if the delegating physician knows or has reason to know that the person is not qualified by training, experience, or licensure to perform the responsibility or acts”.

Tex. Occ. Code § 164.053(a)(8)-(9)

The board may refuse to admit a person to its examination or refuse to issue a license to practice medicine and may take disciplinary action against a person who commits an act prohibited under the prohibited-practices section, who is convicted of a felony or of a misdemeanor involving moral turpitude, or who “fails to practice medicine in an acceptable professional manner consistent with public health and welfare”.

Tex. Occ. Code § 164.051(a)

A physician commits a prohibited practice by committing “unprofessional or dishonorable conduct that is likely to deceive or defraud the public”, and separately by using “an advertising statement that is false, misleading, or deceptive”.

Tex. Occ. Code § 164.052(a)(5)-(6)

⚠️ Texas permits office-use compounding outright, which few states DO. “A pharmacy may dispense and deliver a reasonable quantity of a compounded drug to a practitioner for office use by the practitioner in accordance with this chapter.” There is no commercial-availability condition and no patient-specific prescription requirement — the limit is the phrase “reasonable quantity”.

Tex. Occ. Code § 562.152

The conditions sit on the pharmacy, not the practice. To dispense and deliver a compounded drug for office use a pharmacy must verify the source of the raw materials; comply with applicable united states pharmacopoeia guidelines including the testing requirements, and with HIPAA; comply with all applicable competency and accrediting standards as determined by the board; and comply with board rules “including rules regarding the reporting of adverse events by practitioners and recall procedures for compounded products”. That last clause reaches back to the practice: adverse-event reporting is a practitioner duty imposed through the pharmacy’s rules.

Tex. Occ. Code § 562.153

⚠️ and injectables are sterile, which is its own license. “a pharmacy may not compound and dispense a sterile preparation unless the pharmacy holds a license as required by board rule.” Compounded semaglutide is a sterile preparation, so the office-use permission above runs only through a pharmacy holding that separate sterile-compounding license — the first thing to ask a supplier for.

Tex. Occ. Code § 562.156(a)

The sterile-compounding pharmacy carries two clocks. It shall notify the board “IMMEDIATELY of any adverse effects reported to the pharmacy or that are known by the pharmacy to be potentially attributable to a sterile preparation compounded by the pharmacy”, and “NOT LATER THAN 24 hours after the pharmacy issues a recall” for such a preparation. A practice that has administered from a recalled lot will hear about it on that timetable.

Tex. Occ. Code § 562.156(b)

A person may not operate a laser hair removal facility without a license issued for that facility, and a separate license is required for each location. The requirement does not apply to a facility owned or operated by a physician for the practice of medicine, to a licensed hospital, or to a clinic owned or operated by a licensed hospital.

Tex. Health & Safety Code §401.510

A laser hair removal facility must hold a written contract with a consulting physician to establish the protocols for the services it provides and to audit those protocols and the facility’s operations. The facility must document that contractual relationship with the department, and the consulting physician must be available for emergency consultation as the circumstances require.

Tex. Health & Safety Code §401.519

💰 Texas prices the premises by type, and late renewal is the expensive part. tdlr publishes “Initial Application Fees” of “$50 for Practitioners (Class A Barbers, Cosmetology Operators & Specialty license holders)”, “$70 for Mini-Establishments” and “$78 for Barbering & Cosmetology (“Full-Service”) Establishment, Mobile & Specialty Establishments”. Practitioner renewal runs “$50 for On-time Renewals”, “$75 for Late Renewals (expired less than 18 months)”.

TDLR Barbering and Cosmetology — Fee Changes Effective 09/01/2023 (accessed 2 September 2026)

And the term matters for cash-flow planning: “Establishment licenses are valid for two years from the date of issue.” The same page prices the three premises types side by side — “Establishment License … $78”, “Specialty Establishment License … $78” and “Mini-Establishment License … $70” — and warns that “all requirements must be met within one year of the date the application is received, or the application will be deemed void.”

TDLR — Apply for a Barbering or Cosmetology Establishment License (accessed 2 September 2026)

⚠️ an out-of-state pharmacy shipping into Texas needs a Texas license, and the rule reaches supply under chapter 562’s subchapter d. “a pharmacy located in another state may not ship, mail, or deliver to this state a prescription drug or device dispensed under a prescription drug order, or dispensed or delivered as authorized by Subchapter D” of Chapter 562 “unless the pharmacy is licensed by the board or is exempt under Section 560.004” — and that exemption is for a pharmacy that “restricts to isolated transactions the pharmacy's dispensing of a prescription drug or device to a resident of this state.” A Texas practice buying from an out-of-state compounder should ask for the Texas license number.

Tex. Occ. Code §§ 560.001(b), 560.004

A Texas physician may supply for a patient’s immediate needs, not run a dispensary. “a physician licensed under this subtitle may supply a patient with any drug, remedy, or clinical supply necessary to meet the patient's immediate needs”, and the section “does not permit a physician to operate a retail pharmacy without complying with Chapter 558”. Keeping an office supply of dangerous drugs to dispense, and being reimbursed for their cost without a pharmacy license, is allowed only where § 158.003 applies: “a county with a population of 5,000 or less, or in a municipality or an unincorporated town with a population of less than 2,500, that is within a 15-mile radius of the physician's office and in which a pharmacy is not located.”

Tex. Occ. Code §§ 158.001, 158.003