When the Peel Becomes More Than a Peel
Chemical peels have occupied an interesting space within professional esthetics for decades. They are familiar, effective, relatively accessible, and capable of producing meaningful improvements in pigmentation, acne, texture, and photoaging.
They are also not all created equal.
The difference between controlled exfoliation and a chemical injury can come down to the peeling agent, concentration, formulation, number of layers, skin preparation, application technique, treatment endpoint, patient selection, and ultimately, the depth of tissue affected.
That distinction is becoming particularly important in California.
Two developments have recently brought chemical peels and esthetician scope of practice into sharper focus. A highly publicized case involving a California aesthetician and a patient who alleges she was permanently scarred following a chemical peel has reignited questions about treatment depth and professional scope. At the same time, California is approaching a January 1, 2027 deadline that will prohibit trichloroacetic acid, commonly known as TCA, as an intentionally added ingredient in cosmetic products sold in the state (California Legislature, 2023).
These stories are related in what they tell us about the direction of the industry, but an important factual distinction needs to be made at the outset.
The California TCA prohibition was not created in response to this chemical-peel injury, and the chemical peel involved in the reported injury has not been publicly established as TCA.
Understanding those distinctions is essential to understanding what is actually changing.
The Sonya Dakar Case That Put Chemical-Peel Safety Back in the Spotlight
In 2025, Victoria Nelson publicly described an experience with celebrity aesthetician Sonya Dakar that she says began during an April 2021 appointment.
According to Nelson’s allegations, she had been seeing Dakar for acne-related skin care when a chemical peel was added to a facial. Nelson has said she was told the peel would involve little or no irritation or downtime. Instead, she reported experiencing immediate burning and stinging after the solution was applied.
Photographs later shared publicly showed substantial areas of apparent skin injury.
Nelson has said that she continued receiving treatments from Dakar afterward in an attempt to correct the damage, including treatments she described as aggressive microneedling. She eventually sought evaluation from a dermatologist and subsequently underwent laser treatments to address persistent pigmentary and textural changes (Nesvig, 2026).
Nelson filed a lawsuit in December 2025 alleging, among other claims, that Dakar had performed treatments outside the scope of an esthetician license. She also filed a complaint with the California Board of Barbering and Cosmetology.
Dakar has not publicly responded in detail to Nelson’s allegations. In 2026, however, the California Board of Barbering and Cosmetology confirmed that Dakar surrendered both her esthetician license and the establishment license associated with her clinic (Nesvig, 2026).
For clinicians and estheticians reading about the case, there is another important detail.
The chemical used in the peel has not been publicly established.
Nelson herself has stated that she does not know what was in the solution (Nesvig, 2026). Therefore, it would be inaccurate to describe this specifically as a TCA-peel injury based on the publicly available evidence.
What the case does illustrate is something larger: the consequences that can occur when the depth of a chemical treatment exceeds what was intended, expected, or permitted within a practitioner’s scope.
Dr. Krystal Briglia, L+A Medical + Wellness Contributor
Dr. Krystal Briglia of Triada Integrative Medicine + Wellness is a board-certified nurse practitioner specializing in aesthetic dermatology, integrative medicine, and wellness. She has an extensive and diverse background in healthcare, with over a decade of experience working in emergency, critical care, trauma, aesthetics, healthcare administration, and healthcare education. Krystal holds multiple board certifications, including family practice, emergency, and critical care. Her educational background includes two undergraduate degrees, a degree in health sciences, and a bachelor’s degree in nursing from the University of Delaware. She holds three graduate-level degrees, including a master’s degree in nursing leadership, a master’s degree in business administration, and completed her nurse practitioner education at the University of Massachusetts. In 2016, Krystal completed her clinical doctorate in nursing practice. Dr. Briglia is an entrepreneur and specializes in organizational process improvement. She is a Lean Six Sigma master black belt, a certified Six Sigma champion, and a certified Kaizen facilitator. She also has a passion for education and spent 6 years teaching health profession graduate-level courses. During that time, she held a lead faculty position and helped the university develop a family nurse practitioner program from inception to credentialing and first graduates. Read Full Bio
What California Estheticians Are Actually Allowed to Do
California regulations draw an important distinction based on tissue depth rather than simply naming particular acids.
Under Section 992 of the California Board of Barbering and Cosmetology regulations, exfoliation performed by Board-regulated professionals may remove only the epidermis. Techniques resulting in destruction of living tissue beyond the epidermal layer are prohibited. Products used for exfoliation must also be over-the-counter products rather than products designated for physician use only and must be applied according to manufacturer instructions (California Board of Barbering and Cosmetology, n.d.).
That distinction matters tremendously when discussing chemical peels.
“TCA peel” does not describe one uniform procedure.
Trichloroacetic acid can produce different depths of injury depending on concentration, formulation, application technique, number of coats, pretreatment of the skin, and other factors. TCA has historically been used in superficial and medium-depth chemical peeling, with higher concentrations and deeper penetration carrying greater risks of pigmentary alteration, prolonged erythema, infection, and scarring (Landau, 2008; Nikalji et al., 2012).
In other words, asking whether an esthetician can “do chemical peels” is not sufficiently precise.
The more important question is: What tissue is the treatment intended and capable of affecting?
California’s existing scope rules already provide a clear boundary. Esthetic practice is directed toward beautification and exfoliation of the epidermis. Destruction of living tissue beyond that level crosses that boundary (California Board of Barbering and Cosmetology, n.d.).
Then Comes 2027
A separate change is now approaching.
In October 2023, California enacted Assembly Bill 496, expanding the state’s restrictions on ingredients that may be intentionally added to cosmetic products. Beginning January 1, 2027, the law prohibits the manufacture, sale, delivery, holding, or offering for sale in commerce of cosmetic products containing a list of specified ingredients.
One of those ingredients is trichloroacetic acid (California Legislature, 2023).
This is where language matters.
AB 496 does not simply state that “California estheticians are banned from performing TCA peels.”
Instead, it prohibits TCA as an intentionally added ingredient in cosmetic products sold in California.
For professional esthetics, however, the practical consequence could be substantial. If the peel being used is legally categorized and distributed as a cosmetic product containing TCA, that product will no longer be legally marketable in California under the statute beginning January 1, 2027.
That means many estheticians, spas, manufacturers, and distributors using TCA-containing cosmetic peel formulations will need to reassess their protocols and product portfolios before the deadline.
Why TCA Has Been So Valuable
It is important not to turn this conversation into “TCA is dangerous.”
That would be scientifically simplistic.
TCA is a well-established chemical peeling agent with decades of clinical use. It causes controlled protein coagulation and chemical injury at a depth influenced by concentration and application technique. Properly selected and performed chemical peels can produce meaningful improvements in photoaging, pigmentation, acne scarring, and textural irregularities.
The same mechanism that makes a chemical peel effective, however, creates its risk.
Clinical literature consistently demonstrates that complications increase as the depth of chemical injury increases. Potential complications include prolonged erythema, post-inflammatory hyperpigmentation, hypopigmentation, infection, delayed healing, and scarring. Pigmentary complications are especially important when treating patients with higher Fitzpatrick skin types (Nikalji et al., 2012).
The FDA has separately warned consumers against purchasing high-concentration chemical-peel products for unsupervised use, citing the potential for serious chemical burns and permanent injury. The agency specifically identified TCA along with glycolic, salicylic, and lactic acids as ingredients that may create significant risk at inappropriate concentrations or without appropriate professional supervision (U.S. Food and Drug Administration, 2024).
The lesson is not that acids are inherently unsafe.
The lesson is that chemical exfoliation is dose, depth, patient, and technique dependent.
What This Means for California Estheticians
For California estheticians, 2027 should not be viewed as the end of professional chemical peeling.
It should be viewed as a transition.
Chemical exfoliation remains part of esthetic practice within the limits established by California law. What will change is access to TCA-containing products that fall within the cosmetic-product prohibition.
That creates several immediate questions for practices.
What replaces TCA in an esthetician’s peel portfolio?
Can alternative acids provide comparable results for specific indications?
How are manufacturers reformulating existing professional peels?
Which treatments remain comfortably within superficial epidermal exfoliation?
And when should a patient be referred to a medical provider for a deeper resurfacing procedure?
Those are not merely regulatory questions. They are clinical ones.
Manufacturers Are Already Paying Attention
Whenever a market as large as California changes ingredient regulation, manufacturers have a significant incentive to adapt.
Some professional peel companies are already examining alternative formulations and TCA-free approaches in anticipation of the 2027 deadline. That creates an interesting next chapter for professional esthetics.
Rather than simply removing one ingredient, the industry has an opportunity to reconsider how professional peel systems are formulated.
Alpha-hydroxy acids such as glycolic, lactic, and mandelic acid, beta-hydroxy acids such as salicylic acid, combination formulations, and newer delivery systems may all play increasingly prominent roles. Their clinical behavior, however, cannot be assumed to be interchangeable with TCA.
That subject deserves its own examination and will be the focus of Part Two of this series.
Could California Influence Other States?
California’s decision deserves national attention even among estheticians who never intend to practice there.
The immediate legal effect of AB 496 is California-specific. An esthetician practicing in another state remains governed by that state’s laws, licensing rules, and scope of practice.
California law does not automatically change those scopes.
But California represents an enormous consumer market. When manufacturers must reformulate or create California-compliant products, those decisions can influence products distributed nationally.
There is also a broader regulatory issue.
States regulate esthetic practice differently, creating substantial variation in what an esthetician may perform from one jurisdiction to another. High-profile adverse events can bring those differences into public view and create pressure for regulators, professional organizations, manufacturers, insurers, and medical directors to reassess where the boundary between esthetic and medical treatment should sit.
California’s experience therefore matters even outside California.
It may become a case study in how ingredient regulation, scope-of-practice rules, manufacturer innovation, and patient safety intersect.
The Bigger Conversation: Depth Matters More Than the Name on the Bottle
Perhaps the most important lesson from the current conversation is that the industry needs to become more precise when discussing chemical peels.
“Chemical peel” is an umbrella term.
A superficial lactic acid treatment and a medium-depth TCA peel are both chemical peels, but they are not clinically equivalent. They do not create the same tissue response, carry the same risk profile, require the same recovery, or necessarily belong within the same professional scope.
That distinction should influence education.
Estheticians should understand not only how to follow a manufacturer’s protocol, but why an acid behaves the way it does. Concentration matters. pH matters. Free acid value matters. Skin preparation matters. Application technique matters. Layering matters. Fitzpatrick type matters. Barrier integrity matters. Treatment depth matters.
Knowing the product is not enough.
Understanding the chemistry and the skin is what makes chemical peeling a professional discipline.
Where We Go From Here
The conversation surrounding TCA in California should not become a debate between those who believe estheticians are being unfairly restricted and those who believe chemical peels belong exclusively in medicine.
There is a more productive conversation available.
What treatments can estheticians perform safely and effectively within their education and legal scope? How can manufacturers continue to innovate within changing regulatory requirements? How should we differentiate superficial cosmetic exfoliation from procedures intended to create deeper controlled injury? And how can professional education evolve alongside increasingly sophisticated products?
Those questions matter far beyond one ingredient and one state.
The California case involving an alleged severe chemical-peel injury reminds us what can happen when treatment outcomes move far beyond superficial exfoliation. The approaching TCA restriction reminds us that the regulatory environment surrounding professional skin care is also changing.
Neither means the end of chemical peeling.
They mean the industry needs to understand it better.
Coming Next in The Changing Landscape of Chemical Peels
Part II: Life After TCA and the Reformulation Race will examine how professional peel manufacturers are responding to California’s 2027 deadline, which alternative acids and formulations are emerging, and whether those alternatives can realistically reproduce the clinical benefits that have made TCA such an important tool in professional skin resurfacing.
Part III: The Science of the Peel will return to the fundamentals and compare the major chemical peeling agents, including TCA, Jessner’s solution, glycolic acid, lactic acid, mandelic acid, salicylic acid, and newer blended systems, with particular attention to mechanism, depth, indications, patient selection, Fitzpatrick considerations, and risk.
Because the future of professional peeling should not simply be about finding another bottle.
It should be about understanding exactly what we are putting on the skin, what we expect it to do, and why.
References
California Board of Barbering and Cosmetology. (n.d.). Article 12: Health and safety regulations, § 992 skin exfoliation. California Department of Consumer Affairs.
California Legislature. (2023). Assembly Bill No. 496: Cosmetic safety, Chapter 441. California Legislative Information.
Garelick, E., Pohani, P., Aswani, A., Khan, S., Chadha, S., Patel, T., & Kebbe, M. B. (2026). Chemical peels in skin of color: A scoping review of safety, efficacy, and practice patterns. Cureus, 18(5), e108851. https://doi.org/10.7759/cureus.108851
Landau, M. (2008). Chemical peels. Clinics in Dermatology, 26(2), 200–208.
Nesvig, K. (2026, June 30). A full timeline of the case against celebrity aesthetician Sonya Dakar. Allure.
Nikalji, N., Godse, K., Sakhiya, J., Patil, S., & Nadkarni, N. (2012). Complications of medium depth and deep chemical peels. Journal of Cutaneous and Aesthetic Surgery, 5(4), 254–260. https://doi.org/10.4103/0974-2077.104913
U.S. Food and Drug Administration. (2024, July 30). FDA warns against purchasing or using chemical peel skin products without professional supervision. U.S. Department of Health and Human Services.