Basically either works… but the latter is preferred simply because the deep retinacula cutis fibers tend to lack exposed nociceptors (for pain) and tend to encapsulate the implant pretty well. Of course it’s very difficult to determine this while placing the needle, so either is fine. As mentioned, depth also increases the distance any reader antenna coil will have between it and the implant, making getting reads with certain devices more difficult… but speaking from a biology perspective, between the superficial and deep facial membrane is preferred.
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