According to AmSpa's sources, very recently, many medical spas and estheticians throughout the state of California were reminded that microneedling and dermarolling are both considered invasive procedures in the state. As such, estheticians and others licensed through the state's Board of Barbering and Cosmetology performing this practice are doing so illegally and may be penalized for these actions. Please see below for the official reminder:

The Board of Barbering and Cosmetology (Board) would like to remind its licensees that the practice of Micro Needling/Derma Rolling is not within the scope of practice for any Board licensee.
Micro Needling/Derma Rolling is a procedure that assists in reducing acne scarring and general skin damage. This procedure involves using a small roller with fine micro needles over the skin.  This procedure produces micro punctures in the skin.

Micro Needling/Derma Rolling is considered an invasive procedure by the Board.  Title 16, Division 9, Section 991 of the California Code of Regulations states:

§ 991. Invasive Procedures. 
(a) No licensee or student may use a product, device, machine, or other technique or combination of the same, which results in the removal, destruction, incision, or piercing of a client’s skin beyond the epidermis. Any such act shall be considered an invasive procedure. 
(b) Invasive procedures include, but are not limited to, the following: 
(1) Application of electricity which visibly contracts the muscle. 
(2) Application of topical lotions, creams, serums or other substances which require a medical license to purchase. 
(3) Penetration of the skin by metal needles, except electrolysis needles/wire filaments. 
(4) Abrasion and/or exfoliation of the skin below the epidermal layers. 
(5) Removal of skin by means of a razor-edged tool or similar device. 

NOTE: Authority cited: Sections 7312, Business and Professions Code. Reference: Sections 7312(e), 7316, 7320, 7320.1, Business and Professions Code.
Revised July 2015