Terpene Regulations in Colorado: Are Your Products Compliant?
Scott Holden
|
June 2, 2025
No items found
All Articles
Terpene Regulations in Colorado: Are Your Products Compliant?
Scott Holden
|
September 5, 2025
For cannabis brands working in Colorado, recent guidance from the Colorado Marijuana Enforcement Division (MED) is essential reading. In August 2025, they published an alert reminding producers that they “may only use Botanically Derived Compounds as ingredients in Vaporizer Delivery Devices, and the use of any artificial ingredients … is prohibited.”
In Colorado, terpene regulation has always been strict, and this latest announcement takes explicit aim at the use of synthetic terpenes in cannabis products. This issue has garnered attention in many states over recent years and now affects all terpenes for sale in Colorado.
Synthetic compounds are not an option anymore. The only Colorado terpenes legally allowed are from botanical sources. Lab Effects specializes in providing premium all natural terpenes to help you meet evolving regulations while achieving the flavor, aroma, and effects that consumers are after.
How Does Colorado Classify Terpenes Within the Cannabis Industry?
In Colorado, any “non-marijuana derived substance” incorporated into a cannabis product for any purpose qualifies as an additive, whether intentionally added or present only in trace amounts. The regulations specify that:
“botanically derived compounds which have been isolated or enriched and subsequently added back into cannabis products are additives.”
This means both botanical and synthetic terpenes are considered additives in Colorado. Cannabis-derived terpenes, because they’re derived directly from the cannabis plant, are exempt from this restriction.
Compliant Terpenes for Sale in Colorado
To comply with Colorado’s terpenes regulations, it’s essential to source only terpenes that meet strict food safety standards and fulfill all state reporting requirements. Lab Effects offers the most comprehensive portfolio of botanically derived and cannabis-derived terpenes in the industry, all produced to the highest standards set by the FDA.
We also provide comprehensive compliance documentation that goes far beyond Colorado’s regulatory framework, giving manufacturers extra confidence in both quality and compliance. We’re proud of the terpene reviews from our customers. Request samples of our fully compliant terpenes today to see for yourself.
Special Regulations for Vape Carts, Dabs, and Other Inhalables in Colorado
As the first state to permit recreational cannabis use back in 2012, Colorado lawmakers have been at the forefront of the national dialogue about cannabis safety.
Over the last decade, the MED has introduced a series of targeted regulations informed by emerging data on product safety, including acting quickly in response to growing concerns about EVALI in the early 2020s.
For Colorado cannabis manufacturers, understanding these evolving mandates is essential, not only for compliance but for product integrity and brand trust. Below are the key special regulations to consider when formulating and marketing vapes, carts, and other inhalable products in the state.
Vaporizer additive bans
In 2021, Colorado strengthened inhalable product safety regulations in direct response to concerns about EVALI, prohibiting high-risk additives such as polyethylene glycol (PEG), vitamin E acetate, and medium-chain triglyceride (MCT) oil, each of which were allegedly linked to vaping-related lung injuries (though this was actually never proven).
The rules also banned synthetic terpenes and other potentially toxic compounds, requiring that any additive used in inhalable products appear on the FDA Inactive Ingredient list or undergo rigorous MED pre-approvals before inclusion.
Concentration of terpenes & additives
Colorado does not impose fixed concentration limits on terpenes, but products — including terpenes — may be deemed “adulterated” if additive levels pose potential health risks.
Naturally occurring terpene concentrations in cannabis average 1–5%, a range considered acceptable under state law. Formulations that significantly exceed this threshold may be subject to regulatory rejection.
Emissions and hardware testing
Since 2022, all inhalable cannabis products in Colorado must undergo emissions testing in addition to analysis of the original vape oil or cartridge.
This process identifies harmful byproducts generated during heating, such as degradation compounds from terpenes, as well as heavy metals in the hardware and volatile organic compounds (VOCs) linked to respiratory damage.
The regulations also require vape cartridges to display an expiration date aligned with the proven shelf life of the oil.
Colorado’s Label & Packaging Requirements for Terpenes
Colorado’s packaging regulations are far-reaching; every cannabis product must disclose all ingredients, including added terpenes, and identify any major allergens.
While not legally required, many brands take it a step further by publishing complete terpene profiles with percentages, and some link directly to Certificates of Analysis (COAs) via QR codes. In Colorado, as in states like Nevada and California, COAs are already mandatory for all products, so providing consumer access is a low-effort way to increase trust and transparency.
The MED actively enforces these standards and issues public notifications when violations occur. Recent examples include mislabeled THC/CBD potency or products containing excessive pesticide levels.
Rules in Colorado for Marketing with Terpenes & Flavors
Colorado’s strict “no kid-appeal” legislation prohibits cannabis products from mimicking candy in both formulation and packaging. Regulations specifically state:
“Licensees shall not use the word(s) "candy" and/or "candies" on the label of any Container holding Regulated Marijuana, or of any Marketing Layer.”
“A Regulated Marijuana Business shall not place any content on a Container or the Marketing Layer in a manner that reasonably appears to target individuals under the age of 21, including but not limited to, cartoon characters or similar images.”
For manufacturers, this is particularly relevant when formulating sweet-flavored products and edibles. Incorporating terpenes solely to imitate candy flavors can risk rejection by the MED, even if the strain profile is popular among adult consumers.
Recommendations for Manufacturers in Colorado
Terpene compliance in Colorado involves multiple considerations, but the following four best practices form a strong foundation for meeting state standards and demonstrating compliance when required.
- Keep an SDS and CoA for each botanical terpene.
Colorado requires a Safety Data Sheet (SDS) and Certificate of Analysis (CoA) for every terpene used. These documents collectively detail product quality, analytical test results, potential hazards, and safe handling procedures. Lab Effects provides customers with a complete library of compliance documentation for all terpene products, including SDSs and CoAs.
- File accurate Ingredient Lists with the MED.
All manufacturers must submit a complete list of ingredients for each product to the MED. Any formulation change or change in the source of an ingredient requires an updated filing to remain compliant.
- List all terpenes in the ingredient panel on the packaging.
Packaging must disclose every terpene present in the product. Including terpene concentrations, while not required, can further enhance transparency and consumer trust.
- Provide additive information to retailers.
Share complete ingredients and additive lists for every product with your retail partners. Regulations require you to share accurate information with retailers so they can meet labelling and compliance obligations.
The Future of Terpenes in Colorado’s Cannabis Market
In recent years, Colorado has intensified its regulatory focus on consumer safety, joining states like Missouri, Michigan, and New York in cracking down on synthetic terpenes with unverified safety profiles.
Early in 2025, lawmakers floated a bill to restrict cannabis sales to adults 25 and older, ban “inhaled retail marijuana that contains an added flavor ingredient,” and mandate smaller serving sizes with clearer THC labeling.
The proposal was withdrawn at the last minute amid criticism that it could push younger adults to turn to illicit markets. No alternative bill has since emerged, leaving the next policy move uncertain.
Given Colorado’s track record as a compliance leader, manufacturers should anticipate that the state will continue to respond quickly and decisively to evolving health and safety concerns.
Stay Compliant: Buy Terpenes in Colorado with Lab Effects
Navigating cannabis compliance across multiple states is complex. Each market has its own rules, and staying current can feel like a full-time job. Lab Effects makes it simple. Our botanically derived, food-grade terpenes come with complete compliance documentation and are formulated to meet Colorado’s rigorous standards.
Choose from our extensive portfolio of cannabis-derived and botanical terpenes, and bring your products to market with confidence.
Connect with our team to find the perfect profiles for your next formulation.