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 Color Up: Integrity, Science and Compliance

Professional Regulatory & Scientific Update

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 have always valued truth over marketing. In the current regulatory landscape, a "Full Spectrum" product under the new 0.4 mg THC container cap would contain such a negligible amount of THC—even in a one-ounce container—that it would offer no physiological "entourage effect". 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. We refuse to sell a label that doesn't deliver on its promise.

Why We Support the 0.4 mg Limit
With the data we’ve gathered over the last 11 years, we fully support the ruling to dramatically lower allowable THC content in hemp products. This new limit closes the loopholes that allowed for the creation of intoxicating products under the guise of hemp. We pioneered cannabis wellness by growing our own plants long before it was legal; we have seen firsthand the supportive benefits of the Hemp plant. Since 2015, we have faced the trials every small business must endure: gaining experience, testing stability, and choosing sustainability over shortcuts.

"State-Proofing" Your Business


Because our founding principles are rooted in science, almost our entire line is already aligned with the federal regulations taking effect in November 2026. For the small portion of our line that is not yet there, we are making a strategic transition to Broad Spectrum formulations.

What Stays & What's Changing

Category Status The Bottom Line
Topicals and Internals with Pure CBD ✔ Fully Compliant NOW Non-Detectable THC. No changes needed.
Topicals with Full Spectrum (Sensation Salves / Rub, Full Spectrum Salves & Massage Oils) ⟳ Reformulation Planned Will transition to Broad Spectrum by Nov 2026.
Internal Wellness with Full Spectrum (Human and Pet Tinctures) ⟳ Reformulation Planned Will transition to Broad Spectrum by Nov 2026.

The Science of Topical Cannabinoids

At Color Up, 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. 

Receptor Distribution: The Facial "CB2 Advantage"

While both CB1 and CB2 receptors exist throughout the skin, their distribution is highly specialized. 

  • CB2 Dominance in Inflammation: CB2 receptors are prominently expressed in the basal layer of the epidermis, sebaceous glands, and immune cells like mast cells. They are responsible for suppressing the release of pro-inflammatory cytokines, making them the primary target for treating acne, rosacea, and eczema.
  • CBD vs. THC Binding: While THC binds directly to both CB1 and CB2 receptors, it primarily targets CB1 receptors (often associated with sensory/nerve input) and is a weaker antagonist of CB2.
  • Modulating Homeostasis: CBD is a potent regulator of the cutaneous endocannabinoid system (ECS), effectively modulating CB2 to suppress inflammatory cytokines that cause redness and breakouts. CBD also inhibits the enzyme FAAH, which breaks down anandamide, enhancing the skin's natural homeostatic balance.

Pure CBD Isolate: Clinical Advantages for Pros

For sensitive skin conditions, Pure CBD Isolate offers distinct clinical advantages:

  • Acne & Sebum Regulation: CBD isolate has been shown to inhibit sebocyte proliferation (the cells that produce oil), normalize excessive oil production and reduce inflammation in human sebocytes, making it a superior non-comedogenic option for acne-prone skin compared to many other compounds.
  • Rosacea and Redness: CBD interacts with the immune system to inhibit the "flushing" response associated with rosacea. Clinical studies show that 1% topical CBD significantly reduces erythema (redness) and inhibits epidermal thickness by suppressing multiple inflammatory pathways like MAPK signaling.
  • Anti-Aging & Antioxidant Power: CBD helps reduce oxidative stress and significantly improves wound healing in human dermal fibroblasts, performing better in some assays than traditional anti-aging ingredients like resveratrol.Topical CBD has antioxidant capabilities that actually outstrip Vitamin C and E, making it ideal for treating hyperpigmentation and signs of aging.

Your Retail and Backbar is Safe and Compliant

As a licensed professional, you take on responsibility when you place a product on your shelf. As the ones making the product in our eco-system, we know it's our responsibility to see around corners in the Hemp and Cannabis industry, so you don’t have to. And so we do. Here's what's real for you now and will keep you in compliance moving forward. 

Result-Driven: You still receive the beneficial minor cannabinoids (CBG, CBN, CBC) and terpenes that drive clinical results. We will also be launching new products in 2026 that will contain combinations of these different cannabinoids that we have been studying and understanding over the years. 

✔ Batch-Specific COAs: Every Color Up product will have a Certificate of Analysis Per Batch. These lab tests include the amount of CBD, THC, and other cannabinoids present in the full batch of the Full Spectrum, Distillate, or Pure CBD Isolate we use in our Color Up products, as well as any contaminants or impurities. The COA will also indicate if the product has been tested for potency and if the results match the labeling claims, as you'll see on both our Full Spectrum and Pure CBD Isolate COAs.

✔ State-Proof: Because we will be following Federal rulings, Color Up TOPICAL products will remain legal in all 50 states. The environment around INTERNAL products continues to change based on state – if you want support navigating whether or not you can sell in your state, reach out and we'll do some research for you. 

✔ No Gray Areas: We never sell Delta-8 or synthetic highs and we have never used loopholes to get you high. We'll leave that right there.  

Cannabinoid Glossary for Professionals

Cannabinoid Primary Research Focus & Topical Application
CBD (Cannabidiol)

Focus: Multi-targeted anti-inflammatory and antioxidant.


Topical Use: Treats acne (sebostatic), rosacea (anti-redness), and eczema (barrier support).

CBG (Cannabigerol)

Focus: Antibacterial and anti-inflammatory.


Topical Use: Most effective for psoriasis and reducing redness; it regulates sebum production to prevent acne flare-ups.

CBC (Cannabichromene)

Focus: Antimicrobial and analgesic.


Topical Use: Shows immense promise for acne treatment due to its ability to reduce excess sebum and its significant anti-inflammatory profile.

CBN (Cannabinol)

Focus: Antibacterial and neuroprotective.


Topical Use: Often paired with CBD to soothe highly irritated or itchy skin; it exhibits powerful antimicrobial activity against various pathogens.

CBDV (Cannabidivarin)

Focus: Barrier repair and anticonvulsant.


Topical Use: Studied for its potential to manage symptoms associated with extreme skin sensitivity and barrier dysfunction.

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 within a licensed facility with a strict testing infrastructure.

“Should I be worried?”

No. We have survived 11 years of regulatory changes. We are stable, woman-owned, and compliant. We are still making the products by hand, now with more measures around us to protect you, and Color Up.

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 Ellen (Shauna's Mom who's helping us out) at 720-420-1734