HB22-1355 · enacted 2022

Colorado packaging EPR: what you owe and when

Producer Responsibility Program for Statewide Recycling Act. Current phase: Operating: first year of producer dues, 2026.

Facts last verified 14 September 2026.

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Am I covered

The producer is the brand owner, then the brand or trademark licensee, then the manufacturer if the product is unbranded, then the importer bringing it into the United States for sale in Colorado. For internet sales, the producer of the packaging that holds the product and whoever packs or ships it to the consumer are both obligated. A franchisor is the producer for Colorado franchisees.

Source: Code of Colorado Regulations, 6 CCR 1007-2 Part 1 , C.R.S. 25-17-703(30); 6 CCR 1007-2 Part 1, section 18.2.2. Verified 14 September 2026.

The exemption

A producer is exempt if it had less than $5,779,297 in realized gross total revenue in the prior calendar year (excluding on-premises alcohol sales), or used less than one ton of covered materials for products sold into Colorado in the prior calendar year. The revenue limit is set by rule and adjusted for inflation every July 1; it was $5,632,843 before July 1, 2026. Governments, nonprofits, single licensed retail food establishments, builders and contractors, and some agricultural producers are also exempt.

Source: Code of Colorado Regulations, 6 CCR 1007-2 Part 1 , C.R.S. 25-17-713; 6 CCR 1007-2 Part 1, sections 1.8.2 and 18.2.3. Verified 14 September 2026.

What the threshold is measured against

Either test is enough. The revenue test uses realized gross total revenue; since the rule version effective July 15, 2026 it says global revenue, although the statute does not use that word. The tonnage test counts covered materials for products sold or distributed into Colorado.

Source: Code of Colorado Regulations, 6 CCR 1007-2 Part 1 , C.R.S. 25-17-713(1); 6 CCR 1007-2 Part 1, section 1.8.2. Verified 14 September 2026.

What you owe

Registration

Register with the producer responsibility organization, Circular Action Alliance. Producers selling in Colorado had to register by October 1, 2024, and a new producer must register before it starts selling or distributing covered products in Colorado. A producer may not sell or distribute covered products in Colorado unless it participates in the program.

Source: Code of Colorado Regulations, 6 CCR 1007-2 Part 1 , 6 CCR 1007-2 Part 1, section 18.2.4; C.R.S. 25-17-708(1). Verified 14 September 2026.

Who runs the program

Circular Action Alliance, the single designated producer responsibility organization, selected on May 1, 2023. Colorado's health department approved its final program plan on December 9, 2025.

Source: Circular Action Alliance, Colorado , C.R.S. 25-17-705. Verified 14 September 2026.

Reporting

Producers report the types and quantities of covered materials they supply into Colorado to the producer responsibility organization, and to the state health department if it asks. Prorated national data may be used where Colorado data is not available. Records of how dues were calculated and paid must be kept for inspection.

Source: Code of Colorado Regulations, 6 CCR 1007-2 Part 1 , C.R.S. 25-17-708(1); 6 CCR 1007-2 Part 1, section 18.2.5. Verified 14 September 2026.

Fee schedule

Actual rates for program year 2026, per category, as published. Not a range and not an average.

Source: Circular Action Alliance, "2026 Colorado Producer Dues Schedule", originally published 2025-10-13, retrieved 2026-07-12, https://circularactionalliance.org/s/CO-2026-Dues-Schedule-Public.pdf (Final rate for 'Newspapers') . Program year 2026. Verified 12 July 2026.

Eco-modulation

The rules are final. The Solid and Hazardous Waste Commission adopted the eco-modulation bonus schedule on November 18, 2025, with a hearing process for contesting eco-modulation on invoices. Bonuses are applied to invoices by January 31, 2028. The 2026 dues already include a 5 percent increase for materials that disrupt recycling and a 5 percent reduction for materials with high recycling rates.

Source: Code of Colorado Regulations, 6 CCR 1007-2 Part 1 , 6 CCR 1007-2 Part 1, sections 18.2.7 and 18.9. Verified 14 September 2026.

Timing: the year you sell is not the year you pay

This is the part that catches people out. Packaging you sell in one year is reported the next and invoiced after that, so the cost lands in a later budget than the sales that created it.

• 2024 You sell packaging into Colorado. This is the data year.
• 2025 You report that year's supply.
• 2026 You are invoiced for it. Budget the cost here, not against the year you sold.

Source: Circular Action Alliance, "2026 Colorado Producer Dues Schedule", originally published 2025-10-13: dues for the 2026 program year were calculated from 2024 supply data reported to CAA by 31 July 2025 (two-year lag; first dues invoiced January 2026)..

If you do not comply

Administrative penalties of up to $5,000 for the first day and $1,500 per day after that for a first violation; up to $10,000 and $3,000 per day for a second violation within 12 months; and up to $20,000 and $6,000 per day for a third or later violation within 12 months. A penalty order can be contested within 35 calendar days.

Source: Colorado Revised Statutes, Title 25, Article 17, Part 7 , C.R.S. 25-17-710. Verified 14 September 2026.

Recent changes

July 15, 2026: the small producer revenue limit rose to $5,779,297 in the annual inflation update, and the rule now says global revenue.

Source: Colorado Secretary of State, rulemaking docket 2026-00169 , 6 CCR 1007-2 Part 1, section 1.8.2. Verified 14 September 2026.

December 9, 2025: Colorado's health department approved Circular Action Alliance's final program plan.

Source: CDPHE press release (December 10, 2025) , C.R.S. 25-17-705. Verified 14 September 2026.

Other state guides

• California packaging EPR
• Oregon packaging EPR
• Washington packaging EPR
• Minnesota packaging EPR
• Maryland packaging EPR
• Maine packaging EPR

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Run your own numbers

Enter what you supply into Colorado, in pounds, against this state's own reporting categories. You get a fee with the public document behind every rate it used.

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