Colorado has adopted new legislation requiring warning labels on certain hair products that contain intentionally added carcinogens or reproductive toxicants.
House Bill 26-1135, titled “Transparency of Chemicals Used in Hair Products”, was signed into law by the Governor of Colorado on May 29, 2026. The legislation is intended to increase consumer transparency regarding potentially hazardous chemicals used in hair relaxers, wigs, hair extensions and other covered hairpiece products.
The warning label requirements will apply from July 1, 2027.
Which Hair Products Are Covered?
HB26-1135 applies to specified hair relaxer and hairpiece products sold or distributed in Colorado.
Covered product categories may include:
- Hair relaxers and chemical straightening products
- Hair extensions
- Wigs
- Hairpieces and hair prostheses
- Decorative or synthetic hair products
A warning will be required when a covered product contains an intentionally added carcinogen, an intentionally added reproductive toxicant or substances falling within both categories.
When Will the Warning Requirements Apply?
From July 1, 2027, manufacturers will be prohibited from selling or distributing a covered hair product in Colorado unless the required warning is provided.
The wording of the warning will depend on the type of hazardous chemical contained in the product.
Products containing:
- A carcinogen must display a warning relating to cancer;
- A reproductive toxicant must display a warning relating to birth defects or other reproductive harm;
- Both types of substances must display a combined warning.
The warning must be presented in accordance with the visibility and formatting requirements established by the legislation.
Relevant warnings must also be made available to consumers purchasing covered products through online sales channels.
What Does “Intentionally Added” Mean?
Under the legislation, an intentionally added chemical is a substance deliberately introduced into a product by the manufacturer to provide a specific function or characteristics.
Incidental or unavoidable trace amounts that were not deliberately added may fall outside the scope of the requirement, subject to the definitions and concentration conditions established under the law.
Manufacturers should therefore review not only finished product formulations but also raw material specifications, impurity profiles and supplier documentation.
Exemption for Professional-Use Products
The warning requirement does not apply to covered hair products sold or distributed to a commercial entity exclusively for professional use.
The exemption is relevant where the product is not offered directly to consumers through retail channels.
Companies selling the same product through both professional and consumer channels should not automatically assume that the exemption applies. Distribution and sales models should be assessed on a product-by-product basis.
Non-Compliance May Be a Deceptive Trade Practice
A violation of the warning label requirement may constitute a deceptive trade practice under Colorado law.
Manufacturers and distributors may therefore need to update not only physical product packaging but also e-commerce listings, marketing materials and product information supplied to retailers.
From July 1, 2028, the Colorado Attorney General may adopt rules updating the warning label requirements.
How Should Companies Prepare?
Companies selling hair care or hairpiece products in Colorado should begin reviewing their product portfolios well before the July 1, 2027 implementation date.
Recommended compliance actions include:
- Screening formulations for carcinogens and reproductive toxicants
- Assessing chemicals used in synthetic hair and hairpiece products
- Updating raw material and supplier documentation
- Confirming the concentration of intentionally added chemicals
- Determining whether a warning is required for each product
- Updating packaging and online product pages
- Assessing the professional-use exemption
- Communicating compliance timelines to distributors and retailers
Chemical Transparency Requirements Are Expanding in the U.S.
Colorado’s new legislation reflects the growing focus on chemical transparency in cosmetics and personal care products across the United States.
Ingredient restrictions, warning language, reporting obligations and implementation dates may differ between states. Companies operating nationally should therefore monitor state legislation in addition to federal FDA requirements.
For businesses supplying hair relaxers, wigs, hair extensions and synthetic hair products, HB26-1135 makes early formulation review, supply chain assessment and labelling preparation particularly important.
What Do the 2026 Cosmetic Regulations Mean for Companies?
The regulatory changes implemented in 2026 demonstrate that formulation compliance alone is not sufficient. Product labels, cosmetic notifications, safety assessments and technical documentation must also be updated.
Companies should review:
- Prohibited and restricted ingredients;
- Intentionally added PFAS;
- Fragrance allergen concentrations;
- Formaldehyde-releasing preservative systems;
- Ingredient lists and warning statements;
- Cosmetic product notifications;
- Raw material and supplier documentation;
- Country-specific placement and sell-through deadlines;
- Product safety and technical files.
A formulation or label accepted in one jurisdiction may not necessarily comply with the requirements of another market. Separate regulatory assessments should therefore be completed for each target country.
Why Is Global Cosmetic Regulatory Monitoring Important?
Cosmetic legislation continues to evolve in response to concerns relating to consumer safety, ingredient transparency and environmental protection.
New restrictions may require product reformulation, revised packaging or additional notification activities. Identifying regulatory changes too late may result in delayed market access, product withdrawals, packaging waste and additional compliance costs.
Cosmetic companies should therefore monitor regulatory developments at an early stage, assess their product portfolios according to risk and complete necessary compliance actions before the applicable transitional periods expire.