Who is legally allowed to inject you in Brazil? How to check before the procedure

By Ramon Martins Andrade, attorney (OAB/RJ 188.374)

In England, Parliament answered the question with a single provision. Section 180 of the Health and Care Act 2022 empowers the government to make regulations “prohibiting an individual in England from carrying out specified cosmetic procedures in the course of business, unless the person has a personal licence”, and the statutory definition of a cosmetic procedure expressly includes “the injection of a substance”. The licence comes from a local authority, premises need their own, and the detail is left to regulations; the design is one law, one licence, whatever the applicant’s profession.

Brazil has no single licence and no single list. Who may inject botulinum toxin, a filler or a biostimulator into your face depends on the profession of the person holding the syringe, on the resolutions of that profession’s federal council and, often, on a dispute between councils the courts have not finished resolving.

Each profession has its own council, and each council writes its own rules

Physicians register with a regional medical council (CRM), dentists with a dental council (CRO), nurses with a nursing council (Coren), pharmacists with a pharmacy council (CRF), biomedical scientists with a biomedicine council (CRBM). Each federal council’s resolutions bind its own profession, not the neighbouring one, and not a judge.

The Medical Act (Law 12.842/2013) reserves to doctors “indicating the performance of, and performing, invasive procedures, whether diagnostic, therapeutic or aesthetic” (article 4, III; translations here are ours). But two of the three clauses defining an invasive procedure were vetoed, and the survivor speaks only of the “invasion of the natural orifices of the body, reaching internal organs” (§ 4). The medical council fills the gap its own way: Resolution CFM 2.416/2024 reserves to physicians the prescription of “botulinum toxin, biostimulators, fillers, suspension threads” and allows nursing professionals to give injections “always upon medical prescription” (article 4, II). The Medical Act itself (§ 7) preserves the competences of nurses, pharmacists, biomedical scientists and other professions.

For dentists, Law 5.081/1966 authorises them to practise “all acts pertinent to dentistry, arising from knowledge acquired in a regular course or in postgraduate courses” (article 6, I). Resolution CFO-230/2020 bars dentists from blepharoplasty, brow lifting, otoplasty, rhinoplasty and facelift, but since Resolution CFO-285/2026 that bar “does not apply” to dentists registered as specialists in Orofacial Aesthetic Surgery, in Orofacial Harmonisation, or in Oral and Maxillofacial Surgery and Traumatology, for the procedures their specialty norms assign to them. On the face, the line is drawn by the specialty registration, not the degree, and its legal basis is contested in the federal courts.

Nurses, pharmacists, biomedical scientists

The nursing council’s Resolution 529/2016, as amended in 2020 and 2023, lists ten aesthetic procedures for the qualified nurse: carboxytherapy, cosmetics, cosmeceuticals, dermopigmentation, lymphatic drainage, electrotherapy, combined ultrasound and microcurrent therapy, micropigmentation, cavitational ultrasound and vacuum therapy. Botulinum toxin and fillers are not on that list. The nurse must also hold a postgraduate qualification in aesthetics with at least one hundred hours of supervised practice (article 4). The nursing council’s Technical Opinion 001/2022/GTEE, which its plenary chose to keep in force, concluded that the qualified nurse may perform, among other things, intramuscular botulinum toxin and dermal fillers. The medical and nursing councils, in other words, read the same statute in opposite directions.

My own view is that a council’s opinion, however official, cannot settle a boundary between two professions. It shows how the nursing council will treat its members, not how a court will rule; the same holds for the medical council’s resolution. Until Congress rewrites the definition the vetoes left half-finished, the boundary is drawn case by case.

For pharmacists, Resolution CFF 499/2008 allows injectable medicines to be given in pharmacies only “by the pharmacist or by a qualified professional, with the express authorisation of the pharmacist in charge” (article 21), always upon prescription (article 23) and with a record of each application (article 24). That rule concerns medicines in a pharmacy, not aesthetic injectables in a clinic. Biomedical scientists answer to their own council’s resolutions, and the question for them is the same: which resolution, which article.

How to check before the appointment

The medical council’s national search shows a doctor’s registration status and registered specialty; the dental council keeps a public search of registered dentists. The checklist is short:

• Ask for the full name, the profession and the registration number, in writing. A CRM, CRO, Coren, CRF or CRBM number, with the state.
• Look the number up on the council’s own portal. Name, status (active or not) and state should all match.
• Ask which specialty is registered, not which course was taken. Medical advertising must show the CRM number and, for a specialist, the specialist registration number (RQE); a doctor advertising a postgraduate course without that registration must add the words “NÃO ESPECIALISTA” (“not a specialist”) under Resolution CFM 2.336/2023.
• Ask which norm authorises this procedure for this profession. “It is allowed” is not an answer; a resolution and an article are.
• Ask who will actually inject. The clinic that advertised and the person who performs may differ.

In the United Kingdom, the General Medical Council keeps public registers where anyone can search for a doctor, see the registration status and whether the doctor is on the specialist register. Brazil has the same tool, split across councils.

What the research measures, and where it stops

De Oliveira and colleagues published in 2026, in Dermatologic Surgery, a multicentre survey of 1,058 Brazilian physicians, mostly dermatologists and plastic surgeons. Each respondent reported treating, on average, five complications a month from aesthetic procedures by non-physicians, 17% with permanent sequelae. The finding is serious and limited: a questionnaire answered by one side of a professional dispute, with no comparison group and no denominator, counting only complications that reach a doctor’s office, and the abstract does not separate nurses or dentists from people with no health training. It shows that harm exists; it does not tell you which profession is competent.

A valid registration is not a promise

An active registration and a matching specialty are the floor, not a guarantee. A properly qualified professional can produce a result you dislike, and a known, disclosed risk can materialise with flawless technique; neither is, by itself, an error. Under the Consumer Protection Code, “the personal liability of liberal professionals shall be established upon verification of fault” (article 14, § 4). The reverse also holds: an unqualified professional who caused no harm raises a disciplinary matter for the council, not a claim for damages.

A registration check removes one uncertainty in advance and leaves you a document if something goes wrong. Records and consent for foreign patients are covered in Cosmetic surgery in Brazil: the legal rights foreign patients don’t know they have, and the page for international clients is the place to start for anyone writing from abroad. Before booking, the question worth asking of your own case is simple: can the person who will inject me show, in writing, a registration number I have checked myself and the norm that allows their profession to do exactly this?

Ramon Martins Andrade (OAB/RJ 188.374) is a lawyer who graduated from UFRJ in 2011, with master’s degrees from Université Sorbonne Nouvelle and from the Naval War College (EGN, Brazilian Navy). He is currently a researcher in Human Rights and Health at ENSP/Fiocruz.

This content is for information and education only. It does not constitute legal advice, advertising of results or any guarantee of outcome, under Rule 205/2021 of the Brazilian Bar Association (OAB).