The FDA and Laser Hair Removal

If you look at a few sites for electrolysis businesses, you’ll probably notice how often they say something about how electrolysis is “the only FDA-approved method of permanent hair removal”. Sometimes they’ll also mention that the FDA only considers laser hair removal to be “permanent hair reduction”.

Personally, I’d be wary of deferring to the FDA as an ultimate authority in our current moment given its dubious credibility with Robert F. Kennedy leading it. But also, this is a claim that’s difficult to source. The one source which I’ve sometimes seen given is the “FDA Consumer Health Information Bulletin” from June 27th, 2007, which is quoted as saying:

“The U.S. Food and Drug Administration (FDA) recognizes electrology as providing permanent hair removal. The FDA identification in Title 21, CFR, Sec. 878.5350 for needle-type epilators is: “a device intended to remove the hair by destroying the dermal papilla of a hair”. As no other device for hair removal has the unique identification of “destroying the dermal papilla of a hair”, only electrologists are allowed to claim permanent hair removal in their advertising.”

If you try to Google “FDA Consumer Health Information Bulletin”, most of what you’re going to find is electrologists making this claim and posting this quote with no source. I haven’t been able to find the original statement and don’t know if it exists.

With regard to laser hair removal, however, there was an FDA webpage (now removed, but archived here) stating the following:

“Several manufacturers received FDA permission to claim, “permanent reduction,” NOT “permanent removal” for their lasers. This means that although laser treatments with these devices will permanently reduce the total number of body hairs, they will not result in a permanent removal of all hair. The specific claim granted is “intended to effect stable, long-term, or permanent reduction” through selective targeting of melanin in hair follicles. Permanent hair reduction is defined as the long-term, stable reduction in the number of hairs re-growing after a treatment regime, which may include several sessions. The number of hairs regrowing must be stable over time greater than the duration of the complete growth cycle of hair follicles, which varies from four to twelve months according to body location. Permanent hair reduction does not necessarily imply the elimination of all hairs in the treatment area.”

There’s no mention of electrolysis on this page, but presumably this is what the “permanent hair reduction” claim comes from. The FDA won’t allow laser manufacturers to claim that their devices offer “permanent hair removal”, whereas the epilators used by electrologists don’t seem to have any such restriction, so this became one point where electrologists could claim an edge over laser hair removal in their marketing.

In some ways this is a distinction without a difference. “Permanent reduction” as defined above also means hair is permanently removed, just not all of it. I sometimes see electrologists claim that because electrolysis is “the only FDA-approved method of permanent hair removal,” laser hair removal has no permanent effect at all, which contradicts the FDA statement and the fact that one of the words in “permanent reduction” is “permanent”. The only real difference is that laser hair removal can’t claim the specific term “permanent removal” and can’t claim to remove all hair from an area, while electrolysis can.

If you’re a good candidate for laser hair removal, I would recommend at least starting with that in most areas, and then starting electrolysis when you start to see diminishing returns. A good candidate would be someone with dark hair, whereas laser is unlikely to have much effect for blonde/red/gray hair and is much more likely to have adverse effects. Laser hair removal has also historically had problems with darker skin tones, but an analysis in the American Journal of Clinical Dermatology (found here, but unfortunately not available for free) found that it can be effective for darker skin depending on the approach, so some clinics could work well with that, but it’s something to be careful about. If you want laser hair removal in Portland, I would recommend Luxe Laser. I received my own treatment there paid for through insurance.

The one purpose for which I’d hesitate to recommend laser hair removal at all is surgery preparation. Regrowth from laser hair removal is sometimes observed years after the last treatment. In the case of bottom surgery, this would result in hair growth inside the vagina that will be extremely difficult to get rid of.