Last updated: November 2026
California bans trichloroacetic acid in cosmetic products starting January 1, 2027. If you use a TCA peel in your treatment room, the law reaches you, and it reaches product you already own.
Here is what AB 496 does, what it does not do, and what your options are.
What does California's TCA ban actually say?
AB 496 was signed in October 2023 and amends Section 108980 of the California Health and Safety Code. From January 1, 2027, no person or entity may "manufacture, sell, deliver, hold, or offer for sale in commerce" any cosmetic product containing trichloroacetic acid as an intentionally added ingredient.
TCA is one of 26 ingredients added to the banned list on that date. It appears as entry 8, CAS no. 76-03-9.
Does the ban cover TCA product I already bought?
The word that matters is hold. The prohibition is not limited to selling. It names holding a cosmetic product containing TCA in the state, and the statute's only exemption is for technically unavoidable trace quantities from impurities, manufacturing, storage or packaging.
There is no exemption for product bought before the effective date, for professional use, or for medical practice.
Plan your remaining TCA inventory to run out by the end of December 2026 rather than assuming you can finish a backstock in January.
Does the ban apply if I work under a physician's license?
The law applies to everyone in California. What changes by practice type is not who the law covers, but whether a given product is classified as a cosmetic in the first place. A product regulated as a drug or a medical device sits under different rules.
If you are not certain how a product you use is classified, ask the manufacturer directly how it is labeled and sold in California. That classification is what decides whether the ban reaches it.
What is the difference between TCA and DCA?
Dichloroacetic acid, or DCA, is a close chemical relative of trichloroacetic acid. The difference between the two molecules is one chlorine atom.
DCA does not appear anywhere in AB 496.
Both acids have a long history of use in dermatology. In a peel formulation, the pH of the finished solution is what drives how the treatment behaves, not the raw strength of the acid on its own. A DCA solution formulated to the same pH and the same concentration as a TCA solution is designed to perform the same way in the treatment room.
What are my options before January 2027?
You don’t have to change your treatment. Switch to Renew Dermal Solution formulated with DCA.
- Order the DCA version now. It’s available today, with the same price, protocol and number of treatments per box.
- Keep your client experience. Your clients get the same no-downtime treatment, the same feel and the same post-care. Your service menu doesn’t change.
- Use up your TCA on your schedule. If you’re in California, place your last TCA order by December 23, 2026. Switch to DCA by January 1.
What FACTORFIVE is doing
FACTORFIVE Renew Dermal Solution is a two-step professional treatment. RDS1 is the acid step. RDS2 is a calming step with human stem cell growth factors.
Our science team began work on a DCA formulation when the bill passed. RDS1 is now available in a DCA version at the same 29% concentration and the same pH 2.1 as the TCA version. RDS2 is unchanged.
Same box, same vial, same volume, same shelf life, same protocol. The DCA version carries a "Formulated with DCA" callout on the box and vials.
Outside California, both versions remain available. In California, DCA is the only version from January 1, 2027.
How Do I get the TCA free FACTORFIVE Renewal Dermal Solution?
Renew Dermal Solution is available only to licensed professionals.
If you already have a FACTORFIVE account, your rep can walk you through the switch and what to do with unused TCA product.
If you are not an account yet, applications are reviewed within 72 hours on weekdays.
Apply for a professional account
Learn about the FACTORFIVE professional program
This page describes our understanding of AB 496 and is not legal advice. Confirm your own obligations with counsel.
