License for Precursors in Cosmetology: How to Avoid Criminal Liability

Did you know that the use of certain components in laser procedures, injections, or sterilization can put the legality of your beauty business at risk and lead to criminal liability under Article 311 of the Criminal Code of Ukraine?

For owners of cosmetology clinics and salons offering hardware-based and invasive procedures, working with precursors (controlled substances) is an integral part of service delivery. However, the presence of these substances moves routine cosmetology practice into a sphere subject to particularly strict state control.

The greatest risk lies in the fact that the absence of a specific license, improper execution of even a single document, or an accounting error can result not only in fines, but also in the confiscation of expensive equipment and even imprisonment of the business owner. In the context of intensified inspections, this is not a theoretical risk, but a very real scenario.

In this material, we explain in detail who exactly needs a license to work with precursors in cosmetology, when it is required, and what requirements regulators impose on premises and staff. This will help ensure full legal compliance of procedures and protect your business, assets, and personal freedom from any risks.

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When a Precursor License Is Required in Cosmetology

In our legal practice, we constantly encounter the same problem. Cosmetology establishments and even medical centers are confident that they do not need a precursor license until they face an inspection. However, under Ukrainian law, if the products used in your activities contain controlled precursors, such as ephedrine, safrole, or piperonal, licensing is mandatory.

A license is required for carrying out any operations involving precursors, including:

• purchase and storage;
• transportation;
• use in procedures or technological processes;
• any other operations involving precursors.

This applies to cosmetology service centers where such substances are used in laser and injection procedures, sterilization, chemical peels, and a number of other areas.

Please note! Even minimal use of controlled substances does not exempt you from the obligation to properly оформ all required permits and documentation.

To obtain a precursor license, an establishment must meet several requirements:

1. provide specially designated storage areas;
2. maintain proper accounting and reporting of precursors;
3. appoint a responsible person with appropriate training.

Liability for Violations: A Risk That Can Cost Your Freedom

Illegal acquisition, storage, production, use, transportation, or shipment of controlled precursors without the appropriate license entails criminal liability.

Article 311 of the Criminal Code of Ukraine establishes penalties for violations of the rules governing the handling of precursors. The maximum sanction is up to eight years of imprisonment with confiscation of property.

Under Ukrainian law, any actions involving precursors, including acquisition, storage, transportation, or shipment, are considered unlawful regardless of whether there is an intent to distribute. Accordingly, any illegal operation involving precursors, even within the framework of cosmetology services, may result in criminal prosecution.

For this reason, having a valid precursor license and complying with all regulatory requirements is essential for lawful operations. This is a key factor in ensuring legal protection for both business owners and employees.

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How to Obtain a Precursor License: A Step-by-Step Procedure

Licensing allows an institution to legally store and use precursors in its practice, ensures compliance with all regulatory requirements, and minimizes risks for both staff and management. The licensing process includes several mandatory stages.

Personnel preparation

All employees who will have access to precursors must provide medical certificates confirming the absence of psychiatric contraindications and documentary proof of a clean criminal record.

Establishing the Material and Technical Base

The storage area for precursors must be a permanent structure that is separate or isolated from other zones. It must be equipped with safes or metal cabinets with reliable locks, as well as a full set of security measures, including alarm systems, video surveillance cameras, and access control systems.

If only small quantities of substances are involved, it is permitted to set up a dedicated section within the main premises, but only provided that all safety standards are strictly observed.

Obtaining Approval from the National Police

The National Police conduct an inspection of the premises, assessing the level of security and the proper functioning of protection systems. Following the inspection, they issue an official inspection report confirming that the facility is suitable for working with precursors. After that, a document package is prepared and submitted to the licensing authority. This package includes:

• an application for the permit (license) prepared in the approved format;
• medical certificates and documentary proof of no criminal record for employees;
• information on technical equipment and the implemented precursor accounting system;
• the authorization document issued by the National Police;
• copies of the manager’s documents confirming professional qualifications.

Review of the Application and Issuance of the License

The licensing authority reviews whether the submitted document package is complete and complies with established safety requirements. If a positive decision is made, the license is issued in electronic form and grants the institution the legal right to use precursors in cosmetology procedures.

Proper document preparation, compliance of the material and technical base, and qualified personnel are the key factors for successfully passing all inspections and obtaining the license without delays.

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Turnkey Legal Support for Obtaining a Precursor License

We understand that a business owner should not have to spend time dealing with bureaucracy and legal risks. That is why our law firm provides comprehensive, end-to-end support for medical and cosmetology institutions working with precursors.

We assist clients at every stage, from preparation for obtaining a license to ensuring full legal compliance after it is issued. Our services include:

• Consultations and case analysis. We determine whether your institution requires a precursor license, assess potential risks, and recommend the most effective course of action.
• Document preparation. We prepare applications, information on the material and technical base and personnel, medical certificates, and other required documents in full compliance with current licensing requirements.
• Submission and monitoring of the licensing process. We submit the complete document package to the licensing authority and oversee the review process.

You receive a ready to use solution that allows you to operate with confidence, without fear of unexpected inspections by law enforcement authorities.

Do not wait for an inspection to discover violations. Contact us for an express audit of your activities. We will review your products for the presence of precursors and create a clear roadmap for legalizing your business.