Spa or Aesthetic Clinic: Who May Do What

A spa does non-invasive work: cleansing, masks, face and body massage, hair washing, foot soaks. Filler and botox injections, mesotherapy, thread lifts, lasers, tattooing with anaesthetic, fat removal and surgery belong in a licensed medical facility. If a place calling itself a spa offers anything from the second list, ask for its licence before you sit down.

This is the sentence we put on our about page and our FAQ, and what I say when a client asks:

Lụa Spa offers non-invasive skin care and relaxation. We do not inject, use lasers or needling, prescribe, diagnose, or replace a doctor.

I am Hân, and I opened Lụa Spa (lụa means silk) in 2023 after twelve years in skin care in Ho Chi Minh City, two of them at a hotel spa. In Vietnam the word “spa” covers a very wide range of places, and newcomers are often surprised by what some of them offer. So here is what each kind of place does and who to ask.

What a spa does

A skin care spa works on the surface of the skin with hands, towels and products applied on top. At Lụa Spa that means four facials:

Prices include 8% VAT; no tip is expected. No machines, no extractions. The sessions are named after how skin feels (tight, shiny, easily irritated), never after a skin condition.

A spa does not diagnose. A spa therapist is not a doctor and should not be called one. I keep a notebook of each client’s preferences (no scent, do not touch the chin), not their skin “problems”.

What a licensed medical facility does

The Vietnamese page on spa licensing we read on 4 October 2026 (Aztax, dated 30 September 2026, a secondary source) says that non-invasive skin care, relaxation massage, hair washing and foot soaks do not need a medical licence, while filler, botox, mesotherapy, thread lifts, lasers, tattooing with anaesthetic, fat removal and surgery need a licensed medical facility.

Put simply: anything that takes a needle, a thread, a beam or an instrument below the surface of the skin belongs where there is a doctor and a medical licence. If your skin has something that needs a name, such as a rash that will not settle, a wound that is slow to close, or anything that worries you, the person to see is a dermatologist.

This note does not describe how those procedures are done. That is not a spa’s business, and not mine.

Why the line is blurred

On 3 August 2026 a National Assembly delegate spoke of a “legal gap”: spas are not yet on the list of conditional business sectors, while many still inject filler, do thread lifts and remove fat (Tiền Phong, in Vietnamese). So the word “spa” on a sign does not tell you what happens inside. Read the menu and ask.

We are not lawyers. The above is what we read, not legal advice. For certainty about a particular place, ask the authorities.

Three signs a spa is overstepping

1. Injections on the menu. Filler, botox, mesotherapy, “vitamin injections”, or thread lifts. The licensing page above puts these in licensed medical facilities.
2. Lasers. A service called “laser”, or a laser machine in the room.
3. A “doctor” with no visible licence. Someone introduced as a doctor, but nobody can show you the facility’s medical licence when you ask.

One sign does not mean a place is breaking the law. It means ask before you book.

Where to ask, and how

At the place itself, before booking, ask three questions. If your Vietnamese is limited, ask a friend to come or send them in writing on Zalo:

• “Does this facility have a medical licence, and can I see it?”
• “Is the person doing my procedure licensed to practise medicine?”
• “If something goes wrong afterwards, who do I contact?”

A place working within its scope answers plainly, or says “we do not do that”. If the answer goes round in circles, or you are told “we’ll advise you later”, wait.

Elsewhere:

• A dermatologist at a hospital or a clinic you trust, if you are considering a procedure.
• The Ho Chi Minh City Department of Health (Sở Y tế), if you want to ask about a specific facility’s licence.

Why Lụa Spa does none of it

Simple: we are a spa. Five people, four rooms, no doctor. We do our own work well by keeping it within its scope: cleansing, masks, massage, herbal water, warm towels. A client who wants an injection should go where there is a doctor, and I tell them so.

There are limits inside our scope too. If your skin has an open wound, or a skin condition a doctor is looking after, we do not do facials; a hair wash or foot soak is still possible if that area is healthy. Our only answer to a question about a skin condition is: see a doctor, and come back when the doctor has no objection.

How we do it at Lụa Spa

• Four facials of 45 to 75 minutes, 590,000 to 1,090,000 VND. No machines, no extractions, no injections, no lasers, no needling.
• The booking form has four tick boxes: an open wound or broken skin; a skin condition a doctor is looking after; pregnant; I react to scents or oils. If any is ticked, the front desk calls before confirming.
• The treatment finder suggests a session from how you say you feel, not a conclusion about your skin. If you tick a wound or a skin condition, it suggests no facial.
• No before and after photos, no promises about your skin.

For a step-by-step look at a 60 minute facial, read what 60 minutes at a spa looks like. The four sessions are on the facials page. What we do and do not do is also on About Lụa Spa and the FAQ.

Updated 4 October 2026. Sources read on 4 October 2026: Aztax (secondary), Tiền Phong, both in Vietnamese. This is not legal advice.