Cristina is one of the hundreds of entrepreneurs, most of them women, whose small businesses were imperiled when Minnesota began requiring cosmetology school for makeup artists. Cristina, who specializes in bridal and special event hair and makeup, took her Twin Cities-area business underground to avoid fines and criminal penalties.

Yet, and as Cristina knows all too well, cosmetology school does not prepare people to work as makeup artists. Indeed, she is a cosmetology school graduate.

Cristina hoped cosmetology school would prepare her for an exciting career in makeup. But while she learned all about hair, nails and even waxing, Cristina estimates the one-year, $20,000 program spent only about a week on makeup. Her disappointment was compounded when an instructor recommended she take a separate $400 makeup artist certification course, saying it would teach her much more about makeup than her
cosmetology program.

Nevertheless, Cristina finished the program. She also took—and passed—Minnesota’s three cosmetology licensing exams. But she could not afford the state’s $100 licensing fee. To save for it, she got a job selling, and applying, makeup at a department store beauty counter. In the meantime, she began freelancing as a makeup artist, eventually building a successful small business.a

Since she didn’t need a license to do what she was doing, Cristina never ended up paying the fee. When she tried to pay it later, she was told too much time had elapsed. She would need to repeat cosmetology school and once again learn all about cutting and coloring hair and doing other things special event hair and makeup artists do not do.b

Debbie Carlson, during her 40 years in the beauty industry, has met many women like Cristina who have been ill served by cosmetology school. She knows better than most that makeup is an afterthought in cosmetology curricula. Herself a licensed cosmetologist, Debbie worked for years as an instructor and later education director for a large chain of cosmetology schools. As she describes it, cosmetology school just teaches students how to touch up clients’ makeup.

Debbie has also seen firsthand how cosmetology schools, hungry for financial aid money, reel in aspiring makeup artists. “They tell them, ‘Everything you want is on the other side of this contract,’” she says. Such students would often ask Debbie how they could build a career in makeup like hers. It gave her no pleasure to tell them they would not learn the necessary skills in cosmetology school.

This experience inspired Debbie to open Faces Etc, the first dedicated makeup school in the Upper Midwest and the only licensed makeup school in Minneapolis. When the state started requiring cosmetology school for makeup artists, Face Etc’s enrollment plummeted since graduates could no longer legally work unless they also had a cosmetology license.c

If hair stylists and makeup artists can safely do their jobs with just four hours of education, it is worth asking whether cosmetologists truly need so much more time in school to do theirs.

Unwilling to let the state destroy their livelihoods,Cristina and Debbie decided to fight back. In October 2019, they sued the state cosmetology board.d They also joined with the Institute for Justice to push for a bill to explicitly exempt special event hair and makeup artists from cosmetology licensure.e

Despite opposition from the cosmetology lobby,f the bill became law in May 2020.g The new law restores special event hair and makeup artists’ right to work freely as they always had, with one change: Now, they must complete a four-hour course on health, safety and infection control. And the new law goes even further. It also frees shampooers and hair stylists to work in blow dry bars after taking the same short course.h Just one day after the law went into effect, Debbie offered the first such class to eager students who had signed up in advance.i

This is important progress, and it will help Minnesota’s special event hair and makeup artists get back to work once the pandemic ends. But cosmetology licensing in Minnesota and other states remains burdensome, requiring aspiring cosmetologists and, in some cases, other beauty industry workers to spend over a year of education and experience on average.j

If hair stylists and makeup artists can safely do their jobs with just four hours of education, it is worth asking whether cosmetologists truly need so much more time in school to do theirs.


a   Civil Rights Complaint for Declaratory and Injunctive Relief, Ziemer v. Minn. Bd. of Cosmetologist Exam’rs, Case No. 62-CV-19-7607 (Minn. Dist. Ct. Oct. 22, 2019).
b   Id.
c   Id.
d   Id.
e   Hairstyling and Makeup Application Exempted from Licensing: Hearing on H.F. 3202 Before the H. Gov’t Operations Comm., 91st Leg., Reg. Sess. (Minn. Feb. 27, 2020),; Sibilla, N. (2020a, May 19). Minnesota bill would untangle red tape for freelance hair and makeup artists [Press release]. Arlington, VA: Institute for Justice.
f   McClallen, S. (2020, Mar. 2). Committee okays bill seeking to exempt Minnesota hairstylists and makeup artists from licensing laws. The Minnesota Sun See also Hearing on H.F. 3202, supra note e, at 23:30 (statement of Jim Hirst, Minnesota Salon & Spa Professional Association).
g   Minn. H.J., 91st Leg., Reg. Sess. 8955 (May 27, 2020); Sibilla, N. (2020b, May 27). Minnesota ends licenses for freelance makeup artists and hairstylists, preserves over 1,000 jobs [Press release]. Arlington, VA: Institute for Justice.
h   SF 2898, 91st Leg., Reg. Sess. (Minn. 2020);
i   Debbie Carlson (personal communication, Apr. 27, 2021); Faces Etc. of MN – Professional Makeup School. (2020, June 26). Are you signed up? 4 hour sanitation class [Facebook update].
j   Carpenter, D. M., Knepper, L., Sweetland, K., & McDonald, J. (2017). License to work: A national study of burdens from occupational licensing (2nd ed.) Arlington, VA: Institute for Justice.