Facial Harmonization and the CFM: Rules and Opinions

Facial harmonization is at the center of a dispute among professional councils, and the Federal Council of Medicine (CFM) is one of the main players. For physicians, the practical questions are different: which CFM rules apply to those who perform facial aesthetic procedures, what changes in advertising, and what to check before choosing a course. For other professionals, understanding the CFM's position helps in reading the news more critically.

This page gathers the rules and documents with number, date and source. Status checked on October 20, 2026. It reports what the law, opinions and resolutions say; it does not state what each profession may or may not do. For any professional decision, consult your regional council. This page is not legal advice.

What is the legal basis?

In Brazil, medicine is regulated by Law No. 3,268/1957, which created the CFM and the regional councils (CRM), and by Law No. 12,842/2013, known as the Medical Act Law. The second one comes up in almost every discussion about aesthetics.

What does CFM Opinion 35/2016 say?

CFM Opinion No. 35/2016 answered an inquiry from the Brazilian Society of Dermatology about the meaning of "invasive procedure." Its summary states that "invasive procedures in dermatology/cosmiatry should be indicated and performed only by physicians, in accordance with Law 12842/2013."

The document analyzes procedures one by one, including botulinum toxin and dermal fillers, and describes complications such as nodules, irregularities and necrosis from intravascular injection. The central reasoning is that breaking the skin barrier with a needle or cannula and depositing a substance in the tissue is an invasive procedure, with no practical distinction between "invasive" and "minimally invasive."

CFM opinions express the council's understanding and guide physicians. They do not have the force of law over other professions; what each one may do ends up being decided in court.

Which procedures does the CFM identify as medical?

On June 27, 2024, at the 1st Forum for the Defense of the Medical Act, the CFM released a document from the Brazilian Society of Dermatology and the Brazilian Society of Plastic Surgery listing aesthetic procedures that, in the view of those bodies, should be performed only by physicians. The CFM news item lists:

• Botulinum toxin injection.
• Dermal fillers for facial harmonization, citing hyaluronic acid and polylactic acid.
• Collagen biostimulators.
• PMMA.
• Electrocautery and removal of lesions such as moles, warts and keloids.
• Endolaser for cellulite.
• Chemical peels, such as phenol.

This is the position of the medical bodies. The dentistry, biomedicine, pharmacy and nursing councils have their own rules and opposing positions on several of these items.

What have the courts already decided in the CFM's lawsuits?

The CFM and medical bodies are plaintiffs in lawsuits against other councils' rules on aesthetics. The most cited decisions in 2026:

News about these decisions often comes from the parties themselves. Read the ruling by case number and each council's official statements before drawing conclusions.

Is facial harmonization a medical specialty?

No. Facial harmonization is not a medical specialty, and aesthetic medicine is not a specialty recognized by the CFM either, an understanding confirmed by the Superior Court of Justice (STJ) in a case reported by the CFM. Facial aesthetic procedures appear mainly in the training of specialties such as dermatology and plastic surgery.

In practice, this means:

• A physician with an active CRM registration may perform medical acts, including aesthetic ones, with the technical and ethical responsibility of any medical act.
• To advertise as a specialist, you need a title in a recognized specialty, registered with the CRM (the Specialist Qualification Registry, RQE).
• A lato sensu postgraduate program or standalone course in aesthetics or harmonization does not confer a specialist title and should not be advertised as one.

Facial harmonization course for physicians: what to assess?

The general criteria apply to any profession and are in facial harmonization course: how to evaluate. For physicians, add this: the course must not promise a "specialist title," must include real supervised hands-on practice with patients, and must cover vascular anatomy and management of complications, including the use of hyaluronidase. A good anatomy foundation is in vascular danger zones of the face.

What changes in advertising with CFM Resolution 2,336/2023?

CFM Resolution No. 2,336/2023, published in September 2023, replaced the previous medical advertising rule and took effect 180 days later, in March 2024. According to the CFM news item on the new rule, the changes include:

• Before and after. The previous rule prohibited it; the new one allows it, for educational purposes and accompanied by information such as indications. Legal commentary on the rule also cites a ban on manipulating the image and a requirement to protect the patient's identity.
• Consultation price. It became possible to advertise the consultation fee.
• Social media. Allowed, without sensationalism, improper self-promotion or promises of results.

Using a patient's photo in advertising requires specific authorization. There is a patient image use consent template that can be adapted, with legal review.

What should a physician who does aesthetics check?

1. Active CRM registration in the state where you practice, and RQE if you will present yourself as a specialist.
2. The Code of Medical Ethics and advertising rules, especially Resolution 2,336/2023.
3. Facility structure in line with health surveillance and CFM rules on procedure environments.
4. Products registered with ANVISA (Brazil's health regulator) and the lot number in the patient record. See how to look up an injectable's registration with ANVISA.
5. A written complication protocol, with a checked kit. See emergency kit for the HOF practice.
6. Complete documentation: informed consent, patient record and standardized photos.

How to answer the patient who asks "who can do it"?

Patients often arrive with a news story or a post. The answer should be honest and should not attack other professions.

And in Harmy?

Physician checklist for facial aesthetics

1. Law 12,842/2013 read, including §§ 4, 6 and 7 of art. 4.
2. CFM Opinion 35/2016 known.
3. RQE checked before advertising as a specialist.
4. Advertising reviewed against CFM Resolution 2,336/2023 and the CFM manual.
5. Image use consent signed before publishing any photo.
6. Products registered and lot number in the patient record.
7. Written complication and referral protocol.
8. Progress of the lawsuits among councils followed in official sources.