According to the Tennessee Attorney General Opinion 17-31, Microblading is tattooing.
"Microblading" is a semi-permanent makeup procedure that enables a person to recreate lost eyebrows. Microblading is performed by manually depositing pigment into the skin by use of a pen-like instrument, which contains several fine needles organized in a line. When the instrument is pressed against the skin, the needles penetrate the skin and leave behind pigment.
“An individual may perform microblading only if that person satisfies an exemption foundin Tenn. Code Ann. 5 62-4-109 and is a licensed tattoo artist under Tenn. Code Ann. ç 62-38-204or is exempt from tattooing laws and regulations under Tenn. Code Ann. $ 62-38-210(b).”