On May 12, 2026, the Governor of Colorado signed HB26-1135, the Transparency of Chemicals Used in Hair Products, which aims to increase transparency regarding chemicals used in hair products, protecting consumers' right to know, with particular attention to communities that have historically faced elevated exposure to harmful chemicals.
On and after July 1, 2027, a manufacturer shall not sell, offer for sale, or distribute a “covered hair product” (hair relaxers, hairpieces, etc.) in Colorado that contains an “intentionally added” carcinogen or reproductive toxicant. CIRS Group has compiled and summarized the main contents below for your reference.
Key Contents
1. Covered Products and Key Definitions
Carcinogen: a chemical identified as a "Group 1 carcinogen" or "Group 2A carcinogen" by the International Agency for Research on Cancer (WHO); a "known to be a human carcinogen" or "reasonably anticipated to be a human carcinogen" by the Secretary of the federal Department of Health and Human Services pursuant to the federal Public Health Service Act (42 U.S.C. § 241(b)(4)); or a "Group A carcinogen" or "Group B carcinogen" by the U.S. Environmental Protection Agency.
Reproductive toxicant: a chemical identified as a reproductive or a developmental toxicant by the Center for the Evaluation of Risks to Human Reproduction established by the National Toxicology Program.
Chemical: a substance with a distinct molecular composition or a group of structurally related substances and includes the breakdown products of the substance or substances that form through decomposition, degradation, or metabolism.
Covered hair product: a hair relaxer product or a hairpiece product.
Hairpiece product: a hair extension, a wig, or other hairpiece product, including decorative hair adornments.
Hair relaxer product: a product topically applied to hair for the purposes of weakening the structure and curliness of the hair fiber and allowing for a straightening of the hair.
Intentionally added: a chemical that is purposefully introduced to a covered hair product by a manufacturer and that remains in the product as sold, offered for sale, or distributed in the state in a concentration greater than 100 ppm or above a threshold identified by an entity described in subsection (2)(a) or (2)(i) of this section as injurious to human health, whichever is lower.
Note: "Intentionally added" does not include the incidental presence of a chemical.
Manufacturer: a person that manufactures a covered hair product or whose brand name is affixed to a covered hair product. "Manufacturer" includes, in the case of a covered hair product that is imported into the United States, the importer or first domestic distributor of the covered hair product if the person that manufactures the covered hair product or whose brand name is affixed to the covered hair product does not have a presence in the United States.
2. Warning Label Requirement and Statutory Wording
On and after July 1, 2027, a manufacturer shall not sell, offer for sale, or distribute in Colorado (including through an internet transaction) a covered hair product that contains an “intentionally added” carcinogen or reproductive toxicant, unless the covered hair product includes a clear and conspicuous warning label (or, in the case of an internet transaction, a clear and conspicuous online warning statement). The warning label must be printed in no less than size twelve-point font and must state the following, depending on the type of substance contained:
- Carcinogen only: “This product contains a chemical known to cause cancer”.
- Reproductive toxicant only: “This product contains a chemical known to cause birth defects or other reproductive harm”.
- Both: “This product contains chemicals known to cause cancer and birth defects or other reproductive harm”.
3. Exemptions and Violation Consequences
Exemption: the warning label requirement does not apply to a covered hair product that is sold or distributed to a commercial entity for professional use and is not offered for retail sale to a consumer in the state.
Violation: a violation of this section by a manufacturer constitutes a deceptive trade practice.
4. Rulemaking Authority and Timeline for Warning Label Updates
On and after July 1, 2028, the Attorney General may adopt rules updating the warning label requirement.
CIRS Reminder
- Confirm whether your products are in scope: hair relaxers and hairpiece products (including hair extensions, wigs, and decorative hair adornments) are all covered; companies must determine whether their products contain an “intentionally added” carcinogen or reproductive toxicant.
- Prepare warning labels in advance: before July 1, 2027, companies should complete formula screening, carcinogen/reproductive-toxicant identification, warning-label design (≥ 12-point font, statutory wording), and deployment of online warning statements.
- Note the professional-use exemption: products sold/distributed only to commercial entities for professional use and not offered for retail sale to consumers are exempt; products also involving retail are not exempt.
- Coordinate across states: California (Prop 65), Minnesota, Washington, and other states already have similar warning/ban requirements; companies selling across multiple states should compare and coordinate compliance.
About CIRS
Established in 2007, the CIRS Group is a leading product safety and regulatory consulting firm. CIRS has branch offices in the Republic of Ireland, South Korea, the United States, the United Kingdom, Japan and China. CIRS Group utilizes its technical expertise, various resources, and international network to provide one-stop compliance services from regulatory compliance, laboratory testing, R&D to data services across multiple industries. This includes chemicals, cosmetics, food and food beverages, medical devices, agrochemical products, disinfectants, and consumer goods. It helps clients gain a competitive advantage by reducing business risks associated with regulatory affairs.
The CIRS cosmetic team provides expert support to ensure that cosmetic products meet stringent global cosmetic regulations and safety standards.
We offer comprehensive, lifecycle-based solutions for personal care products, from early-stage cosmetic ingredient development through to final product registration. Our services include:
- Cosmetic ingredient development and regulatory strategy,
- Physical/chemical and analytical tests,
- Toxicological tests (in vivo & in vitro),
- Efficacy and claim substantiation studies (in vivo & in vitro), and
- Ingredient and product registration across global markets.
With deep expertise in cosmetic regulatory compliance and safety evaluations, our team enables brands to bring products to market efficiently and with confidence.
Our Services
- The United States Agent
- The United States FDA Cosmetic Facility Registration
- The United States FDA Cosmetic Product Listing
- The United States FDA OTC Drug Registration
- The United States Color Additive Batch Certification
- The United States Cosmetic/OTC Drug Labeling Review
- International Cosmetic Ingredient Name (INCI) Application
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
Further information
