The short answer

Professional title alone does not answer the question. At least four levels must align for PRP: who may collect the blood, who may prepare the autologous blood product, who may perform the specific invasive treatment, and who bears professional responsibility. That is why sweeping claims such as “only dermatologists may perform PRP” or “a course is enough for a Heilpraktiker” are not legally reliable.

Four legal levels matter – not just the injection

May physicians perform PRP?

Generally, yes. There is no special state-issued “PRP licence”. Medical licensure is the professional-law basis, but it does not replace competence for the specific procedure. The physician must be able to manage the indication, blood collection, preparation, injection technique, informed consent and complications competently.

Speciality boundaries should neither be overstated nor ignored. The Federal Constitutional Court has not generally prohibited private medical activity outside a recognised speciality; this does not amount to blanket permission for any procedure. For PRP, the decisive factors should therefore be demonstrable competence in the specific procedure and the applicable professional rules of the federal state.

May dentists use PRP or PRF?

Yes – within dentistry and on a separate statutory basis. Section 28 TFG excludes the collection of a small amount of autologous blood for the manufacture of products for dental treatment from the scope of the TFG under specified conditions. Preparation and application must occur in the dental practice according to the established recognised standard of dental science and technology.

This reference standard is specified by the guideline of the German Dental Association (BZÄK), published in agreement with the Paul-Ehrlich-Institut. It expressly covers autologous blood products including PRP/PRGF and PRF, as well as collection, preparation, application, quality assurance, documentation and qualification.

May Heilpraktiker perform PRP?

As an independent PRP autologous-blood treatment, in practice no. The decisive issue is not the injection first, but the blood collection. In 2024, the Bavarian Higher Administrative Court expressly held that PRP plasma autologous blood therapy is subject to the physician reservation in section 7(2) TFG.

A second obstacle arises under medicinal-products law: human blood preparations for medicinal use are prescription-only. For prescription medicines, the permit-free manufacturing route in section 13(2b) AMG does not apply to persons who are neither physicians nor dentists. A manufacturing authorisation under section 13(1) AMG would theoretically be a different legal route, but it would not remove the physician reservation applying to the preceding blood collection.

May beauticians offer PRP?

Not as an independent PRP treatment. Cosmetic training, a PRP course or a manufacturer certificate replaces neither the physician reservation for blood collection nor the necessary medical and pharmaceutical authority.

Labels such as “Vampire Facial” or “PRP Facial” do not change the assessment if blood is actually collected, processed and then invasively applied. The real procedure, not its marketing name, is decisive.

May a medical assistant collect blood for PRP?

Blood collection can generally be delegated. Section 7(2) TFG permits collection by other qualified staff under the responsibility of a physician. Whether a particular staff member is sufficiently qualified must be assessed and organisationally safeguarded by the responsible practice.

This does not create independent authority to provide PRP. Additional requirements apply to preparation, indication, informed consent and application. General delegation rules should not be used to assume categorically that every PRP injection can be delegated to non-medical staff.

What a PRP practice should check organisationally

• Assess the notification requirement for permit-free medicinal-product preparation under section 67 AMG and complete the notification correctly before starting the activity.
• Define patient-specific preparation and clear responsibilities throughout the workflow.
• Document a standard operating procedure for blood collection, preparation/centrifugation and application.
• Observe the intended purpose and instructions for use of every medical device used; do not confuse CE marking with approval of a therapy.
• Implement hygiene requirements for punctures and injections and, where applicable, additional indication-specific standards.
• Organise informed consent, documentation of batches/materials and traceability in a verifiable manner.
• Check competence, emergency management and professional liability coverage for the specific application.

Questions patients can ask before a PRP treatment

• Who establishes the medical indication and who bears overall responsibility?
• What qualifications and experience does the treating person have for this exact procedure?
• Which PRP system is used and is it used within its intended purpose?
• How are blood collection, preparation and injection organised hygienically?
• What realistic chances, limitations, alternatives and risks are explained for the specific indication?

Frequently asked questions

Primary sources and further authorities

This article reflects the legal and research status for Germany as of 15 August 2026. It provides general professional orientation and is not legal advice for a specific practice location, treatment workflow or PRP system. State professional rules, authority requirements and the manufacturer documentation of the system used may impose additional requirements.