Updated September 2026
The short answer: A med spa supply list covers six areas: injectables and injection consumables, sharps and PPE, skincare and back-bar, devices and equipment, front desk, and compliance documents. Buy prescription products only from licensed, authorized sources, and settle your medical director, delegation protocols and ownership structure before you order anything clinical.
Opening an aesthetic practice means buying a long list of items before the first patient books. This checklist groups aesthetic clinic supplies by area so nothing gets missed, and flags the federal rules that apply to each. It's a planning list, not clinical guidance: your medical director decides which products, protocols and emergency supplies your practice uses.
Med spa startup checklist: what to settle before you buy
- Ownership structure. In states with a strong corporate practice of medicine (CPOM) doctrine, the medical practice generally has to be owned by physicians, often alongside a management services organization (MSO). Check your state on the CPOM map.
- Medical director and supervision. Who supervises, who examines patients and who may inject all vary by state. If you need a physician, MedGrid MSO matches practices with medical directors.
- Delegation protocols. Write a protocol for each service that matches your state's rules on who may inject.
- Vendor accounts. Open accounts only with licensed sources, and keep copies of their licenses.
- Then the supply list below.
1. Injectables and injection consumables
Neuromodulators
Botulinum toxins are FDA-licensed biologics and are prescription-only. Drugs@FDA lists Botox and Botox Cosmetic, Dysport, Xeomin, Myobloc, Jeuveau, Daxxify and Letybo. Units are product-specific and not interchangeable between brands, and toxins can't be compounded. In 2024, FDA warned that counterfeit Botox had been found in multiple states and given for cosmetic use, and said products from unlicensed sources may be counterfeit, contaminated or ineffective. Buy only U.S.-labeled product through the authorized supply chain.
Dermal fillers and biostimulators
Dermal fillers are Class III medical devices. Each one is approved through premarket approval (PMA) for specific indications and treatment areas. FDA's list of approved fillers covers materials including hyaluronic acid, calcium hydroxylapatite, poly-L-lactic acid and PMMA. Check a product's PMA before you buy: imported or grey-market fillers without a U.S. PMA are not legally marketed.
Injection consumables
- Syringes, needles and cannulas in the sizes your protocols specify (piston syringes and hypodermic needles are Class II devices)
- Diluent as specified in each product's labeling
- Alcohol prep pads, gauze, cotton-tipped applicators and skin-marking pencils
- Ice packs, hand mirrors and disposable headbands
- A medical-grade refrigerator with a thermometer or data logger, and a temperature log. Storage requirements are product-specific, so follow each label.
- The complication and emergency supplies your medical director's protocols require. If those protocols call for hyaluronidase, note that it is a licensed biologic, which FDA says is not eligible for compounding under 503A or 503B.
2. Sharps and PPE
- Safety-engineered sharps. OSHA's bloodborne pathogens standard (29 CFR 1910.1030) requires your exposure control plan to document, at least once a year, that you considered and put in place commercially available safer medical devices, with input from front-line staff.
- Sharps containers. FDA recommends puncture-resistant, FDA-cleared sharps containers. Put one within reach of every treatment chair.
- Medical waste pickup. EPA notes that medical waste is regulated mainly by state environmental and health departments, so line up a hauler that meets your state's rules before opening day.
- Gloves. Medical exam gloves are FDA-regulated devices, and FDA has banned powdered medical gloves since its December 2016 final rule.
- Masks, eye protection and gowns or lab coats, plus hand-hygiene supplies and surface disinfectant.
- Laser safety eyewear matched to each device's wavelength, if you offer laser or light treatments.
3. Skincare and back-bar
Back-bar products are what your team uses during treatments: cleansers, toners, peels, masks, post-procedure products and sunscreen. Retail is what patients take home. Two rules shape both:
- Claims decide the category. FDA says the law doesn't recognize "cosmeceuticals" as a category. A product that claims to treat acne or remove wrinkles is regulated as a drug, and sunscreen actives fall under FDA's over-the-counter drug rules.
- MoCRA applies to cosmetics. Under the Modernization of Cosmetics Regulation Act, cosmetic facilities must register and products must be listed with FDA (enforced since July 1, 2024, with some small-business exemptions), and the product's "responsible person" must report serious adverse events to FDA within 15 business days. If you plan to sell skincare under your own label, ask your supplier who holds those duties.
Track back-bar and retail stock separately, so you can see what's used in treatment and what's sold.
4. Med spa equipment list: devices and furniture
- Treatment chairs or tables, procedure lighting and magnification
- A photo station with consistent lighting for before-and-after documentation, used with patient consent
- Medical-grade refrigeration with temperature monitoring (see above)
- Locked storage for prescription products
Energy-based devices. Aesthetic lasers are Class II devices cleared through 510(k), and every laser must also meet FDA's laser performance standard. Powered microneedling devices are Class II and cleared for specific uses; FDA says they are not approved to deliver drugs, cosmetics or PRP into the skin, and cartridges must not be reused. In October 2025, FDA issued a safety communication on RF microneedling reporting burns, scarring and nerve damage. Non-invasive body-contouring devices are cleared for specific indications, and cryolipolysis is prescription-use only.
Before you buy a device, ask the seller for its 510(k) number and cleared indications, and check who may operate lasers in your state.
5. Front desk and operations
- Scheduling and charting software with secure photo storage
- Consent forms for each service, plus photo consent
- Payment processing and a retail point of sale
- A par-level reorder sheet covering every item on this list
- Staff ordering rules. On MedGrid, staff sub-accounts come with an ordering switch, so you choose who can place orders.
- A plan for paying for your opening inventory. MedGrid Pay is a Visa® commercial card, powered by Nitra, with 52-day net terms on purchases, up to 2.4% back on MedGrid orders, and up to 120 days at 0% on product purchases by application. The MedGrid Pay card is a Visa® commercial credit card issued by Continental Bank, Member FDIC, pursuant to a license from Visa U.S.A. Inc.
6. Compliance documents: medical director, delegation and state rules
This part of the list doesn't come in a box, and it's the part a board or inspector will ask about. Keep these on file:
- Entity and ownership documents that fit your state's CPOM rules, plus MSO agreements if you use one
- The medical director agreement, supervision plan and chart-review schedule
- Written delegation protocols, and standing orders only where your state allows them
- Staff licenses and training records for each service they perform
- Vendor licenses and product documentation for everything you administer
- Your OSHA exposure control plan
- Any clinic or facility license your state requires
The rules vary widely. Four examples from MedGrid's regulations research, current to September 2026:
| State | Who may inject neuromodulators and fillers | Ownership (CPOM) |
|---|---|---|
| California | RNs and PAs only under physician supervision, after a physician, NP or PA has examined the patient; medical assistants may not inject (Medical Board of California FAQ) | Strict CPOM: a med spa offering medical procedures must be physician-owned, and lay-owned spas may not hire a "medical director" (Medical Board of California) |
| Texas | Physicians may delegate to trained staff, but a physician, PA or APRN must first establish the patient relationship and be on site or immediately available (22 Tex. Admin. Code §§169.25–169.28) | Strict CPOM; med spas are typically physician-owned or use an MSO structure |
| Florida | No rule specific to cosmetic injectables; RNs may administer medications as prescribed or authorized by a licensed practitioner (Fla. Stat. §464.003) | No CPOM bar, but a med spa not wholly owned by licensed practitioners generally needs an AHCA health care clinic license and a medical director (Fla. Stat. §400.9905) |
| New York | RNs may inject only on a patient-specific order from a physician, PA or NP who examined the patient; standing orders aren't allowed for cosmetic injections (NYSED Office of the Professions) | Strict CPOM: only physicians, through PCs or PLLCs, may own a medical practice |
MedGrid's research covers all 50 states and DC, and it shows its gaps: for injector delegation, 20 jurisdictions are still marked "Not confirmed." Check yours on the delegation map and the CPOM map, then confirm with your board.
This article is general information, not legal or medical advice. Rules change, so confirm requirements with your state medical, nursing and pharmacy boards.
Ordering the aesthetic clinic supplies on your med spa supply list
Once your list is set, browse the catalog by category and check the vendor documents on each product page. On MedGrid, vendors clear per-category document diligence before listing, and their licences and documents are shown on product pages, marked verified. Everything goes in one cart with one invoice trail, and if another supplier has quoted you less, you can ask for a custom price or a price match.
Frequently asked questions
What supplies do you need to open a med spa?
Plan for six areas: injectables and injection consumables, sharps and PPE, skincare and back-bar, devices and equipment, front-desk systems, and compliance documents such as the medical director agreement and delegation protocols. Your medical director should sign off on the clinical items and protocols before you order.
Does a med spa need a medical director?
It depends on the state and the ownership structure. Florida, for example, generally requires a health care clinic license and a medical director for a med spa that isn't wholly owned by licensed practitioners. California requires the medical practice to be physician-owned and says lay-owned spas may not hire a "medical director." Check your state on MedGrid's CPOM map and confirm with your board.
Where should a med spa buy Botox and fillers?
Only from licensed, authorized sources, and only FDA-approved, U.S.-labeled products. FDA's 2024 warning about counterfeit Botox said products from unlicensed sources may be counterfeit, contaminated or ineffective. For fillers, confirm the product's U.S. premarket approval (PMA) in FDA's database.
Who can inject Botox and fillers at a med spa?
It varies by state. In New York, RNs may inject only on a patient-specific order after a physician, PA or NP has examined the patient. Texas lets physicians delegate to trained staff after a physician, PA or APRN establishes the patient relationship, with on-site or immediately available supervision. MedGrid's research still marks 20 jurisdictions "Not confirmed," so check with your board.
What equipment does a med spa need?
The basics are treatment chairs, procedure lighting, medical-grade refrigeration with temperature monitoring, a photo station, sharps containers and PPE. Energy-based devices depend on your services: lasers must be FDA-cleared and meet FDA's laser performance standard, and your state decides who may operate them.
Sources
- U.S. Food and Drug Administration, Counterfeit Version of Botox Found in Multiple States (May 2, 2024)
- U.S. Food and Drug Administration, FDA-Approved Dermal Fillers (November 9, 2020)
- eCFR, 29 CFR 1910.1030 — Bloodborne pathogens (September 1, 2026)
- U.S. Environmental Protection Agency, Medical Waste (April 20, 2026)
- U.S. Food and Drug Administration, Is It a Cosmetic, a Drug, or Both? (Or Is It Soap?) (September 11, 2024)
- U.S. Food and Drug Administration, Laser Products and Instruments (November 13, 2024)
- U.S. Food and Drug Administration, Potential Risks with Certain Uses of Radiofrequency (RF) Microneedling – FDA Safety Communication (October 15, 2025)
- U.S. Food and Drug Administration (openFDA), openFDA Drugs@FDA query: botulinum toxin A products (api.fda.gov), September 22, 2026
- U.S. Food and Drug Administration, Notice to compounders: changes that affect compounding as of March 23, 2020 (www.fda.gov), March 5, 2020
- U.S. Food and Drug Administration, Safely Using Sharps (Needles and Syringes) at Home, at Work and on Travel (www.fda.gov), November 19, 2021
- U.S. Food and Drug Administration, Medical Gloves (www.fda.gov), July 2, 2024
- U.S. Food and Drug Administration, Modernization of Cosmetics Regulation Act of 2022 (MoCRA) (www.fda.gov), August 10, 2026
- U.S. Food and Drug Administration, Microneedling Devices (www.fda.gov), October 15, 2025
- U.S. Food and Drug Administration, Non-Invasive Body Contouring Technologies (www.fda.gov), October 15, 2025
- Medical Board of California, Frequently Asked Questions – Cosmetic Treatments (www.mbc.ca.gov), September 23, 2026
- Cornell LII (Texas Medical Board rule text), 22 Tex. Admin. Code §169.25 – Other Delegation (www.law.cornell.edu/regulations/texas/22-Tex-Admin-Code-SS-169-25), January 9, 2025
- Florida Legislature, Florida Statutes §464.003 – Definitions (Nurse Practice Act) (www.leg.state.fl.us), July 1, 2026
- Florida Legislature, Florida Statutes §400.9905 – Definitions (Health Care Clinic Act) (www.leg.state.fl.us), July 1, 2026
- New York State Education Department, Office of the Professions, Non Patient Specific Orders and Protocols (RNs, LPNs, CNSs & NPs) (www.op.nysed.gov), September 1, 2026
- Permit Health, The Corporate Practice of Medicine 50-State Guide (www.permithealth.com), December 23, 2025
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