There are two types. The “medical” vs. “cosmetic”
Per the FDA, the OTC “Cosmetic type” microneedling products that do not penetrate living skin (e.g., epidermal and dermal layers of the skin) and claim only to do the following would not be devices:
• facilitate exfoliation of the skin
• improvement in the appearance of skin
• give skin a smoother look and feel
• give skin a luminous look
You need anesthesia (local numbing) before doing a medical type microneedling but not for cosmetic OTC ones.