Please note, this blog post is shared with the permission by my colleague Joshua Hanson, LAc.
If you’ve ever gotten dry needling from a physical therapist, chiropractor, or athletic trainer, you probably didn’t think twice about it. They stuck a needle in your tight muscle, it twitched, you felt better. Simple.
But if you step back and look at what actually happened, the story gets weird. The needle they used is classified by the FDA as an acupuncture needle. It’s regulated as a Class II medical device under 21 CFR 880.5580, and its official description says it’s “a device intended to pierce the skin in the practice of acupuncture.” The FDA labeling requirements say the sale of these needles must be restricted to “qualified practitioners of acupuncture as determined by the States.”
And yet, in almost 40 states and Washington D.C., physical therapists can legally use this device without an acupuncture license. Some with as few as 27 hours of weekend training.
How did that happen? The answer involves lobbying, legal workarounds, a booming education industry, and a question nobody has fully resolved: how did PTs convince everyone that using acupuncture needles isn’t acupuncture when they use them?
The regulatory loophole
Here’s the core issue. In 1996, the FDA reclassified acupuncture needles from Class III (high risk, requiring premarket approval) to Class II (moderate risk, special controls). The reclassification came from petitions by acupuncture needle manufacturers and was supported by the Anesthesiology Devices Advisory Panel’s earlier recommendation. The special controls required single-use labeling, sterility standards, biocompatibility requirements, and prescription labeling restricting their sale to qualified acupuncture practitioners.
The intent was clear: these are acupuncture needles, for acupuncture, used by acupuncturists.
But the FDA regulates how devices are marketed, not how they’re used in clinical practice. That’s determined state by state through scope-of-practice laws. And that’s where the door opened.
The state-by-state campaign
Starting in the 1980s, when Maryland became the first state to allow dry needling by PTs, and accelerating sharply after 2000, physical therapy associations began a methodical, state-by-state campaign to include dry needling in their scope of practice.
The playbook was consistent. State PT boards or associations would petition their state’s attorney general, board of healing arts, or legislature to declare that dry needling falls within the existing definition of physical therapy. Sometimes it was framed as a “rehabilitative procedure.” Sometimes as a “mechanical modality” or “physical agent.” The argument was always the same: dry needling is based on Western anatomical concepts, targets trigger points in muscle tissue, and is therefore fundamentally different from acupuncture.
The APTA’s own educational resource paper established the messaging framework: dry needling is a “skilled intervention that uses a thin filiform needle to penetrate the skin and stimulate underlying myofascial trigger points, muscular, and connective tissues for the management of neuromusculoskeletal pain and movement impairments.” Notice the careful language. No mention of acupuncture. No mention that the “thin filiform needle” is an FDA-regulated acupuncture needle. The word “acupuncture” doesn’t appear in the definition at all.
Acupuncture organizations fought back in almost every state. In Iowa, the state Association of Oriental Medicine and Acupuncture challenged the PT board’s decision all the way to the Court of Appeals. The court upheld the PT board, ruling in 2018 that the board had the authority to determine what falls within PT scope. In Oregon, the Attorney General initially ruled in 2017 that dry needling was not within PT scope, prompting the state PT association to develop a multi-year legislative strategy to change the law. Eight years later, that strategy succeeded: in August 2025, Governor Tina Kotek signed House Bill 3824, making Oregon one of the last states to authorize PTs to perform dry needling, with full implementation expected by 2027. In Montana, drafted rules for PT dry needling were stopped by the chief counsel of the governor’s office after concerns raised by acupuncturists, only to be reintroduced under the next administration.
The pattern was clear: professional lobbying, board-level petitions, attorney general opinions, and when those failed, legislative action. And the acupuncture profession, which is smaller, less funded, and less politically organized, was often outmatched.
The argument that never quite holds up
The central claim from PT organizations is that dry needling is fundamentally different from acupuncture because it targets trigger points using Western anatomical reasoning rather than meridians and traditional acupoints.
On the surface, that sounds reasonable. But it requires you to ignore a few things.
First, acupuncturists have been needling tender, reactive points in muscle tissue for over 2,000 years. Classical texts describe Ashi points, found by palpation and needled directly at the site of pain. Multiple acupuncture traditions developed muscle-focused and orthopedic needling techniques independently of Western trigger point research. The technique of palpating a sore spot in a muscle and putting a needle in it is not a Western invention.
Second, the research on anatomical overlap between acupuncture points and trigger points is substantial. Melzack et al. (1977) found 71% correspondence between trigger point locations and acupuncture points used for pain, concluding they likely “represent the same phenomenon.” Dorsher (2008) found the correspondence may be 95% or higher. A 2025 study in Deutsche Zeitschrift fur Akupunktur found that 238 of 262 common trigger points could be directly mapped to specific acupuncture points, with odds of that happening by chance calculated at roughly 1 in 10^75.
Third, the tool is the same. Not similar. Identical. The needles used in dry needling are FDA-classified acupuncture needles. Some manufacturers have rebranded them with labels like “dry needling needle” or “filiform needle,” but the product code, the regulatory classification, and the manufacturing specifications are the same. You can put a different label on the box, but you can’t change what’s inside it.
The weekend course industry
The expansion of dry needling into PT practice created enormous demand for training, and a profitable industry rose to meet it.
Continuing education companies now offer dry needling certification courses ranging from 27 to 80 hours, usually delivered over one to three weekends. Some states require as little as the 27-hour minimum. Maryland, which has some of the more rigorous requirements, asks for 80 total hours (40 didactic, 40 practical).
For comparison: a licensed acupuncturist completes a minimum of 3 years of graduate education, over 1,900 hours of training (per NCCAOM standards), including at least 660 hours of supervised clinical practice with needles. Many programs require over 3,000 total hours.
The education companies aren’t doing anything wrong. They’re meeting a market demand. But the result is that a provider can attend two weekends of training and legally perform the same invasive procedure that another provider spent three to four years learning to do. The question isn’t whether weekend-trained providers can learn to insert a needle safely. Most can. The question is whether they develop the palpation skill, the anatomical precision, and the clinical judgment that come from thousands of hours of deliberate practice.
Patients are noticing the difference. People who’ve experienced dry needling from a minimally trained provider and then from a practitioner with deep needling expertise often describe it as a completely different treatment. Not because one person is bad and the other is good, but because precision with a needle compounds over years.
This story isn’t over. In Part 2, I’ll look at the role the acupuncture profession itself played in letting this happen, the one phrase that shows up in every dry needling article that nobody questions, and what all of this actually means for you as a patient.
Source: How did using acupuncture needles become a physical therapy thing? (Part 1) by Teddy Levarda, L.Ac.
References
Food and Drug Administration. (1996). Medical devices; reclassification of acupuncture needles for the practice of acupuncture. Federal Register, 61(236), 64616-64617. https://www.govinfo.gov/content/pkg/FR-1996-12-06/html/96-31047.htm
Melzack, R., Stillwell, D. M., & Fox, E. J. (1977). Trigger points and acupuncture points for pain: Correlations and implications. Pain, 3(1), 3-23. https://pubmed.ncbi.nlm.nih.gov/69288/
Dorsher, P. T. (2008). Can classical acupuncture points and trigger points be compared in the treatment of pain disorders? Birch’s analysis revisited. Journal of Alternative and Complementary Medicine, 14(4), 353-359. https://pubmed.ncbi.nlm.nih.gov/18576919/
Dorsher, P. T., Schmid, O., & Fleckenstein, J. (2025). The “most common” myofascial trigger points and classical acupuncture points. Part 1. Deutsche Zeitschrift fur Akupunktur, 68, 58-70. https://doi.org/10.1007/s42212-025-00735-8