June 3
Utah's stem cell disclosure law: what suppliers and providers both must do under sb 275 2

Utah’s stem cell disclosure law lives in Section 58-1-512 of the Utah Code. It began as SB 199 in 2024, which required providers to give patients a written notice and obtain consent before performing non-FDA-approved stem cell therapy. SB 275, passed in the 2025 session, amended that section to add a new obligation aimed upstream at suppliers: persons who supply human cells, tissues, or cellular or tissue-based products for use in stem cell therapy now carry a notice requirement of their own. This post covers what Utah providers and the suppliers who serve them must each do.

TLDR: Utah Code 58-1-512 requires a provider performing non-FDA-approved stem cell therapy to give the patient a written FDA-non-approval notice, display it at the office entrance and in patient-visible areas on paper at least 8.5 by 11 inches in at least 40-point type, and obtain signed consent. SB 275 (2025) added a notice obligation on persons who supply cells for stem cell therapy. Violations are treated as unprofessional conduct subject to discipline by Utah’s licensing division. Several specifics below are flagged for verification against the enrolled bill text. Banking adipose tissue does not enroll a patient in therapy and does not guarantee any future eligibility, access, or benefit.

Important Disclaimer: Save My Fat does not provide FDA-approved treatments or cures for any disease. Banking adipose tissue today does not guarantee eligibility, access, or clinical benefit from any future therapy, clinical trial, or medical program. No adipose-derived stem cell product currently holds FDA approval for the conditions discussed in this article. All content is for educational purposes only and does not constitute medical advice. Patients must consult their own licensed healthcare professionals regarding all medical decisions.


If you supply tissue to Utah providers, or you are a Utah provider sourcing tissue, the 2025 amendment changed your compliance map. The disclosure duty no longer sits only with the clinician at the point of care. It now reaches the supply chain. Understanding which obligation belongs to whom is the difference between a compliant arrangement and a shared liability.

Background: From SB 199 to SB 275

The 2024 law, SB 199, enacted Section 58-1-512 and established the provider-side disclosure regime. It defined stem cell therapy by reference to afterbirth placental perinatal stem cells and human cells, tissues, or cellular or tissue-based products, and it required certain providers to disclose FDA approval status and obtain consent before administering such therapy. SB 275 in 2025 amended the same section. Its stated purpose is to impose a notice requirement on persons who supply or provide human cells, tissues, or cellular or tissue-based products for utilization in stem cell therapy. The practical effect is to extend a piece of the disclosure responsibility upstream from the provider to the supplier.

Because the operative requirements are spread across the original enactment and the 2025 amendment, the safe practice is to read the current consolidated text of 58-1-512 rather than either bill in isolation. Several specific points below should be confirmed against that enrolled text, and they are flagged where they appear.

The Provider’s Obligations

Before performing a non-FDA-approved stem cell therapy, a Utah provider whose scope of practice includes such therapy must give the patient a written notice. The statutory notice language is:

“THIS NOTICE MUST BE PROVIDED TO YOU UNDER UTAH LAW. This health care practitioner performs one or more stem cell therapies that have not yet been approved by the United States Food and Drug Administration. You are encouraged to consult with your primary care provider before undergoing a stem cell therapy.”

The notice has format and display requirements. It must be on paper at least 8.5 by 11 inches and written in no less than 40-point type, and the provider must prominently display it at the entrance and in an area visible to patients in the office. These display specifics trace to the original 58-1-512 enactment; confirm the current type size and display language against the consolidated statute, because amendments can adjust them.

The provider must also obtain a signed consent form before performing the therapy, signed by the patient or the patient’s representative. The consent must address the nature and character of the proposed treatment including its FDA approval status, the anticipated results, the recognized serious possible risks, complications, and anticipated benefits, the available alternatives, and the option of nontreatment. Retain the signed consent in the patient’s medical record. What this kind of consent must accomplish is covered more fully in the discussion of informed consent in regenerative medicine.

The Supplier’s Obligation Under SB 275

This is the new layer. SB 275 imposes a notice requirement on persons who supply or provide human cells, tissues, or cellular or tissue-based products for use in stem cell therapy. The precise mechanics of that supplier notice, what it must say, to whom, and at what point in the transaction, should be read directly from the enrolled SB 275 text and the amended 58-1-512, because the supplier provision is the part of this law most recently changed and least settled in secondary summaries.

The operational implication for a supplier is straightforward even where the statutory detail needs verification: build a documented notice and confirmation step into onboarding and fulfillment, retain the records, and treat the requirement as a precondition to supply rather than a post-shipment formality. Suppliers should also confirm their handling meets federal current good tissue practice standards. A supplier that ships without satisfying its statutory obligation is exposed to regulatory action in its own right. What “intact” tissue means and where supplier responsibilities begin is covered in the explainer on intact adipose tissue.

The Required Notice and a Verification Flag

Reader caution: the exact wording, the type size, and the supplier-side mechanics should be verified against Utah Code Section 58-1-512 as amended by SB 275 before any clinic or supplier relies on this article operationally. Secondary trackers and news summaries of this law have not always been precise, and the section has been amended more than once. The notice text and the provider display rules above reflect the enacted language as written into the statute, but the consolidated current version controls.

Penalty for Non-Compliance

A failure to provide the required disclosures is treated as unprofessional conduct under Utah law. Unprofessional conduct can result in licensing discipline through Utah’s Division of Professional Licensing, which oversees the relevant practitioner licenses. A supplier that violates the SB 275 supply-side requirement is likewise exposed to regulatory action. The structure mirrors a recurring pattern in state stem cell statutes: the law does not create a new criminal scheme for routine violations; it routes enforcement through existing professional-discipline channels, which is where a clinician’s or supplier’s license is actually at risk.

Utah SB 275 vs. Florida SB 1768

The two states took different structural approaches. The comparison below highlights where they diverge. Cells marked “verify” depend on the consolidated enrolled text and should be confirmed before reliance.

RequirementUtah (58-1-512, as amended by SB 275)Florida (SB 1768, Ch. 2025-185)
Authorized providersHealth care providers within scope of practice (verify exact class against statute)MDs and DOs only
Authorized conditionsNot limited to named conditions in the disclosure statute (verify)Orthopedics, wound care, pain management only
Notice displayAt least 8.5×11, no less than 40-point type, entrance and patient-visible areas (verify current text)Statutory ad notice; type no smaller than the largest type in the ad; no fixed office-display size in the statute
Signed consentYesYes
Post-thaw viability reportNot specifiedYes, required before each use
Supply chain obligationYes, SB 275 adds a supplier notice requirementNot specified; instead imposes sourcing-contract and accreditation duties on the physician
PenaltyUnprofessional conduct; licensing division disciplineBoard of Medicine disciplinary action

The Florida framework, set out in Chapter 2025-185, including its accreditation and sourcing-contract requirements, is detailed in the companion overview of why physicians add adipose banking and the broader picture in FDA regulations for adipose tissue.

Practical Checklists

For providers: confirm the current notice text and format against 58-1-512; post the notice at the entrance and in patient-visible areas; have counsel review your consent form against the statutory elements; retain signed consents; and train staff on the notice and consent workflow.

For suppliers: read the SB 275 supplier provision in the enrolled text; build a documented notice and confirmation step into onboarding and fulfillment for Utah-bound product; retain those records; and hold shipment where the statutory step has not been completed.

Frequently Asked Questions

Does SB 275 replace the provider’s disclosure duty?

No. SB 275 adds a supplier-side obligation. The provider’s notice and consent duties under 58-1-512 remain. After SB 275, both the provider and the supplier carry distinct responsibilities.

Is the 40-point type requirement still current?

The 40-point type and 8.5×11 paper requirements trace to the original 58-1-512 enactment. Because the section has been amended, confirm the current type size and display rule against the consolidated statute before relying on it.

Does banking adipose tissue trigger these supplier rules?

That depends on the statutory definitions and the specific transaction, which is exactly why the supplier provision should be read against the enrolled text. Banking is the preservation of a patient’s own tissue and does not itself enroll anyone in therapy or guarantee any future use. The FDA’s consumer alert on regenerative medicine products underscores that no such product is FDA-approved for these uses.

Key Takeaways

Utah’s disclosure law is now a two-sided regime. The provider side, established in 2024 and carried in Section 58-1-512, requires a specific written notice, a 40-point posted display, and signed consent before any non-FDA-approved stem cell therapy. The supplier side, added by SB 275 in 2025, places a notice requirement on the people who supply cells for that therapy. Both sides route enforcement through professional-discipline channels rather than a new penalty scheme, which means a license is the thing genuinely at stake. Because the section has been amended more than once and the supplier mechanics are the newest piece, the single most important step before relying on any of this is to read the consolidated current text of 58-1-512 and the enrolled SB 275, and to confirm with Utah counsel. Banking adipose tissue sits separately from all of this: it is a preservation decision, not a treatment decision, and it carries no guarantee of future eligibility, access, or benefit.

Save My Fat operates as a tissue preservation service, not a medical practice or treatment provider. Stem cell and regenerative medicine regulations vary by state, including specific informed-consent and disclosure requirements in Florida, Utah, and Nevada governing tissue and stem cell services. Banking adipose tissue does not connect patients to any treatment pathway, and any future use depends on FDA regulatory status, physician guidance, and the availability of approved or investigational pathways at that time.

Providers and suppliers evaluating a compliant Utah arrangement can contact Save My Fat to discuss how tissue preservation works within these rules. Service and processing details are available at https://savemyfat.com/pricing/.


Save My Fat partners with L2 Bio for laboratory processing and storage.

This article is for educational purposes only and does not constitute medical or legal advice. Legal and medical review including neurology and neurosurgery input is required before publication. Please consult your neurologist or neurosurgeon before making any decisions about neurologic treatment or research participation.