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Texas Cracks Down on Unlicensed Botox Injections: What Med Spa Owners Need to Know

April 15, 2025
2 min read
Senate Bill 378

Growing Health Risks Spark Botox Bill in Texas

In response to a troubling rise in adverse reactions tied to unlicensed Botox injections, Texas lawmakers are taking action to better regulate cosmetic procedures performed outside of medical settings. This legislative push follows multiple incidents involving untrained or unauthorized individuals performing injections in salons, private homes, and pop-up "Botox parties."

One high-profile case involved a woman in Dublin, Texas, who suffered a seizure after receiving an injection from someone trained by a Texas-based company but operating without medical oversight. Texas is currently one of only four states without a dedicated board to oversee medical spas, leaving enforcement to the Texas Medical Board (TMB) and local law enforcement.

Alarming Trends in Unregulated Cosmetic Procedures

Between 2018 and March 2024, the TMB issued 63 disciplinary actions related to unauthorized cosmetic procedures. These mostly included cease and desist orders to individuals performing injections without a license or required supervision. The lack of a proactive regulatory body has made it difficult to prevent violations before they cause harm.

A broader national trend further underscores the issue. According to the CDC, 22 people across 11 states—including Texas—suffered serious complications from receiving counterfeit or unapproved Botox in non-medical environments. Symptoms ranged from blurred vision to muscle weakness and, in severe cases, required hospitalization.

What Senate Bill 378 Proposes

To address these concerns, Texas Senator Charles Schwertner introduced Senate Bill 378, which proposes the following:

  • Bans estheticians and cosmetologists from administering injectable treatments like Botox unless they hold appropriate medical licensure.

  • Requires that cosmetic injections be performed only by licensed medical professionals or under their direct supervision.

  • Grants the Texas Department of Licensing and Regulation (TDLR) authority to take action against non-compliant individuals and businesses.

If passed, this bill would close major regulatory loopholes and make it easier for state agencies to proactively prevent unsafe practices.

What This Means for Med Spa Owners in Texas

For licensed med spa owners, this bill could level the playing field and boost consumer trust. Here’s how it could impact your business:

  • Increased Credibility: With stricter enforcement against unlicensed competitors, properly licensed med spas can differentiate themselves as safe and compliant.

  • Higher Standards for Oversight: Medical directors and supervisors will need to ensure all staff meet the new regulatory criteria.

  • Potential Growth Opportunity: As illegal Botox parties are curbed, consumers seeking cosmetic procedures may turn to properly licensed med spas instead.

  • Documentation and Training: You may need to update protocols and training certifications to ensure alignment with future regulations.

Med spa owners should begin reviewing their staffing and supervision models now to prepare for compliance if the bill is signed into law.

Final Thoughts

As the demand for aesthetic treatments continues to grow, Texas lawmakers are working to ensure patient safety isn't compromised by unqualified providers. Senate Bill 378 represents a significant step toward creating a safer and more trustworthy cosmetic industry in the state.

Read more about proposed Texas bills that could affect med spas here: https://optimantra.com/blog/new-texas-bills-could-reshape-med-spa-laws-what-you-need-to-know 

Source: NewsNationNow, ‘Wild west’: Texas Botox injections happening in back rooms

Leonor Keller
Leonor Keller

Leonor Keller is the President of OptiMantra and a seasoned product leader with years of experience in SaaS and healthcare technology. She is passionate about creating content that helps healthcare practices—especially those just starting out—navigate the complexities of running and growing their business. Her work is driven by a deep appreciation for healthcare professionals and a commitment to supporting their success.