REGULATORY UPDATE: P.L. 119-37

The Future of Hemp Regulation

Navigating the November 12, 2026 Enforcement Deadline with Science and Compliance.

The Federal Shift

Public Law 119-37, enacted in November 2025, eliminates the use of "serving sizes" to bypass THC limits. The old 0.3% rule is being replaced by a strict per-container cap.

"Total THC" Defined

Compliance is now measured by Total THC, including Delta-9, Delta-8, and THCA. This national standard overrides state-level permissions (including Colorado).

The 0.4 mg "Sledgehammer"

The most significant change is that the 0.4 mg limit is per container, regardless of size. This makes current "Full Spectrum" formulations for bulk or large topicals federally non-compliant.

Product Type Current THC Levels New Limit (Nov 2026) Likely Efficacy
4oz Topical Lotion 100mg – 500mg+ 0.4 mg Negligible
32oz Massage Oil 500mg – 2000mg+ 0.4 mg Negligible
30ct Gummy Bag Total bag weight x 0.3% 0.4 mg (Total Bag) Ineffective

The Science of Efficacy

Why Concentration Matters for Professionals

The Dilution Effect in Topicals

Topical efficacy is heavily dependent on concentration (mg/ml). In a 4oz (118ml) bottle, 0.4 mg of THC results in a concentration of 0.003 mg/ml. In a 32oz container, that drops to 0.0004 mg/ml—levels considered therapeutically invisible.

Experts note that chronic pain relief requires 500mg to 2000mg+ per jar. The new law removes 98% of the THC currently used to trigger the "Entourage Effect."

Receptor Distribution: The Face is a "CB2 Stronghold"

CB2 Dominance: These receptors are primarily in the basal layer of the epidermis and oil glands, making them the target for acne, rosacea, and eczema.

Broad Spectrum Wins: By removing THC and maximizing minors like CBG (anti-inflammatory) and CBC (sebum regulation), we maintain healing potential without the regulatory risk of Schedule I classification.

The Clinical Advantage of Pure CBD Isolate
  • Sebum Regulation: Inhibits oil-producing cell proliferation for superior acne care.
  • Redness (Erythema): Inhibits the "flushing" response in rosacea.
  • Antioxidant Power: Outstrips Vitamin C and E for anti-aging and hyperpigmentation.
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The Future of Hemp: Integrity, Science and Compliance

While the federal government is enacting strict new limits, Color Up has proactively operated above these standards since 2015. 

Our Promise: Your safety, your license, and your access to high-quality, non-intoxicating products is our foremost responsibility.

Our "North Star"

At Color Up, we value truth over marketing. Under the new 0.4 mg THC cap, a "Full Spectrum" product would contain such a negligible amount of THC that it would offer no physiological "entourage effect" from the THC itself. To continue marketing a product as "Full Spectrum" when it has been stripped of virtually all THC would be, in our view, out of integrity.

Therefore, we are making a strategic, science-backed shift: By November 2026, we will transition our remaining Full Spectrum topicals to Broad Spectrum formulations.

This ensures you get the beneficial minor cannabinoids (CBG, CBN, CBC) and terpenes that drive results, without the legal liability or physiological risks of THC. It effectively "State-Proofs" your business against Zero-Tolerance laws.

Products Transitioning (Safe until Nov 2026)

  • Sensation Salve (Current: Full Spectrum ➝ Future: Broad Spectrum)
  • Sensation Rub (Current: Full Spectrum ➝ Future: Broad Spectrum)
  • Full Spectrum Salve & Massage Oil

*These products remain compliant and available in their current form until the deadline.

Compliance Roadmap:

What Stays & What Changes

Category Status The Bottom Line
Skincare & Broad Spectrum ✔ Fully Compliant NOW Non-Detectable THC. No changes needed.
Full Spectrum Topicals ⟳ Reformulation Planned Will transition to Broad Spectrum by Nov 2026.
Internal Wellness (Tinctures/Gummies) ✔ Relaunching THC-Free Only Broad Spectrum & Isolate offered. Zero risk.

Protecting Our Professional Partners

Why CBD Skincare Excels

Our focus has always been science-backed skincare that supports whole-body health without the high. Science shows that THC has no consistent topical benefit compared to the anti-inflammatory power of CBD and minor cannabinoids. By removing THC, we increase safety without sacrificing results.

Your "Defensible" Backbar

As a licensed professional, you take on responsibility when you place a product on your shelf. Our job is to see around corners so you don’t have to.

  • ✔ Batch-Specific COAs: Proof of safety for every bottle.
  • ✔ State-Proof: Legal in all 50 states (even strict ones like Idaho).
  • ✔ No Gray Areas: We never sell Delta-8 or synthetic highs.

Common Questions

“Are these products legal?”

Yes. Color Up has always led with Isolate and Broad Spectrum. We are already compliant with the 2026 laws.

“Why pause Internals?”

We paused to await federal clarity. Now that we have it, we are relaunching with a licensed facility and strict testing infrastructure.

“Should I be worried?”

No. We have survived 11 years of regulatory changes. We are stable, woman-owned, and compliant.

Have questions about compliance or your account?

We’re here to answer everything — for both professional partners and individual customers.

Email Support

or call/text 720-420-1734