I took organic chemistry in college and learned how to make aspirin.  It's easy and I could do it at home in my kitchen.  Based on these arguments, seems to me that I could just name is something else, claim that I'm selling it strictly for muscle pain relief (it's not a blood thinner! it won't help your headaches!) and begin selling it out of my home as a home remedy, bypassing any regulations.

I also took microbiology, so I'm sure I could offer women an examination of their reproductive systems.  I have a microscope.  I'd know cancer if I saw it.  I'm not an OB/GYN, I'm a yoga instructor, but this isn't a PAP smear, it's "cervical health yoga," I'll need to use that same brush and a speculum, but it's NOT A PAP.  Trust me, I know what I'm doing.  I took a class.  Regulations won't apply.

This is precisely what PTs are doing when they take an acupuncture needle, stick it in an acupuncture point and call it "dry needling."  You're not fooling anyone.  It's acupuncture, they should be subject to the same rules and regulations of anyone desiring to practice acupuncture, regardless of what they call it and for what purpose.