Colorado EPR threshold

Packaging EPR in Colorado: what we have verified

This page collects what we have verified about packaging extended producer responsibility (EPR) in Colorado. 11 of 16 core rule fields are published from primary sources and 5 are not yet published. The dataset was last reviewed on September 29, 2026, and the newest source on this page was retrieved on November 5, 2026.

Regime

Colorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355)

Regulator

Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program

Producers obliged

Yes

System

more than one producer responsibility organisation

Registration

Required

Fee schedules

2

Who is the producer in Colorado

In Colorado, packaging EPR obliges producers to organise or fund the collection and recycling of the packaging they place on the market. The sections below set out who counts as the producer, which thresholds decide whether a business is in scope, and what has to be filed.

The producer hierarchy decides who answers for a pack when several businesses touch it. For Colorado, the dataset names the following roles for each packaging level.

Roles matter because an online seller, an importer and a brand owner can each be the producer for the same pack, and a pack is counted once. If you sell into Colorado through a marketplace, check whether the marketplace or you are recorded as the obligated party. Confirm who is responsible for reporting.

Thresholds that apply in Colorado

Thresholds decide whether a business is in scope, whether it pays fees, or whether it can file a simplified report. Colorado publishes 3 verified thresholds.

Basis of the revenue threshold: realized gross total revenue, prior calendar year, excluding on-premises alcohol sales.

Basis of the tonnage threshold: covered materials used for products sold or distributed in or into Colorado, prior calendar year.

Basis of the tonnage threshold: covered materials supplied into Colorado.

Exemptions in Colorado

An exemption removes or reduces a duty for a defined group. Colorado lists 1 exemption in the dataset. Some apply automatically; others only apply if you ask the regulator for them, usually within a window.

Registration and the system in Colorado

Registration is where an obligation becomes visible to the regulator. The records below show whether Colorado asks producers to register, with whom, and which organisation or scheme carries the collection and recycling system.

Who registers: The producer, with CAA. Producers of applicable petroleum and automotive products register with Interchange 360.

Registry (opens the official registry page).

Deadlines in Colorado

Colorado records 4 deadlines, 2 of them verified. This page gives the summary; every date, the period it covers and what it requires are on the deadlines page for Colorado.

Every verified date we hold for Colorado falls on or before November 9, 2026, so none is still ahead. Check the regulator for the next one.

See every deadline for Colorado, with its period and what it requires, on the Colorado deadlines page.

A deadline is a date the regulator published, not a date we set. We can estimate what you may owe and prepare the report file; you sign and submit it in the regulator's own portal.

Fees and reporting in Colorado

Colorado publishes 2 fee schedules, for fee years 2026 and 2027. The schedule sets what each kind of packaging costs; the rates themselves are on the fee pages, not here.

The 2026 schedule is based on packaging placed on the market from January 1, 2024 to December 31, 2024.

The 2027 schedule is based on packaging placed on the market from January 1, 2025 to December 31, 2025.

• Colorado 2026 fees: rates by material for fee year 2026.
• Colorado 2027 fees: rates by material for fee year 2027.

The report you file is a defined file or form. Colorado records 1 format; we prepare the file to that specification and you upload it yourself.

Colorado producer supply report by material category is a csv file submitted through CAA producer portal. The customer signs in and submits. The customer reviews, signs and submits it.

Columns, material mapping and the checks a file must pass are on the Colorado report format page.

Colorado: packaging fees by material

Instica groups the verified rates of the 2027 Circular Action Alliance (Colorado PRO) schedule for Colorado into 6 material classes. For each class the table gives the lowest and highest published rate in US cents per pound and the unweighted mean in USD per tonne, with a link to the source the rates were read from, retrieved October 22, 2026.

Instica holds 2 schedules for Colorado priced in the same currency, from 2026 to 2027. The table gives the unweighted mean per tonne of each material class in each schedule, and the change from the earliest schedule in which the class appears to the latest.

The same material classes in the 3 jurisdictions that publish a per-weight schedule in USD, Colorado included. For each class the table gives the mean here, the median of the other jurisdictions, the rank of Colorado (1 is the highest) and the jurisdiction with the highest mean.

Labelling, languages, targets and penalties in Colorado

Labelling, language, target and penalty rules are the parts of a regime that are easiest to miss. A report filed in the wrong language or a pack without a required mark can cost as much as a late payment, so read each of these against your own products.

Colorado compared with nearby places

Rules do not stop at a border. A business that sells into Colorado usually sells into its neighbours too, and the thresholds and deadlines differ. The table reads Colorado against the places closest to it that have verified data.

Colorado read against each neighbour

Each paragraph reads Colorado against one place from the table above, using only records verified for both. A part is left out when either side is not yet published.

Colorado and Oregon both record an obligation for packaging producers. The regulator is Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program in Colorado and Oregon Department of Environmental Quality (DEQ) next door. Colorado runs more than one producer responsibility organisation, while Oregon runs a single producer responsibility organisation. Registration is required in both. The first threshold is the same in both, $5,000,000.00 of revenue. The earliest recorded deadline is January 1, 2026 in Colorado and July 1, 2025 in Oregon, 184 days later here.

Colorado and California both record an obligation for packaging producers. The regulator is Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program in Colorado and CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal next door. Colorado runs more than one producer responsibility organisation, while California runs a single producer responsibility organisation. Registration is required in both. The first threshold is $5,000,000.00 of revenue in Colorado against $1,000,000.00 of revenue in California, so a small seller can be in scope next door while below the line here. The earliest recorded deadline is January 1, 2026 in Colorado and January 1, 2027 in California, 365 days earlier here.

Colorado and Washington both record an obligation for packaging producers. The regulator is Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program in Colorado and Washington State Department of Ecology next door. Colorado runs more than one producer responsibility organisation, while Washington runs a single producer responsibility organisation. Registration is required in both. The first thresholds are measured differently: $5,000,000.00 of revenue in Colorado and 1 short ton of tonnage in Washington, so the figures cannot be compared directly. The earliest recorded deadline is January 1, 2026 in Colorado and March 1, 2026 in Washington, 59 days earlier here.

Colorado and Maine both record an obligation for packaging producers. The regulator is Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program in Colorado and Maine Department of Environmental Protection next door. Colorado runs more than one producer responsibility organisation, while Maine runs a single producer responsibility organisation. Registration is required in both. The first threshold is $5,000,000.00 of revenue in Colorado against $2,000,000.00 of revenue in Maine, so a small seller can be in scope next door while below the line here. The earliest recorded deadline is January 1, 2026 in Colorado and May 31, 2027 in Maine, 515 days earlier here.

Colorado and Minnesota both record an obligation for packaging producers. The regulator is Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program in Colorado and Minnesota Pollution Control Agency next door. Colorado runs more than one producer responsibility organisation, while Minnesota runs a single producer responsibility organisation. Registration is required in both. The first thresholds are measured differently: $5,000,000.00 of revenue in Colorado and 1 short ton of tonnage in Minnesota, so the figures cannot be compared directly. The earliest recorded deadline is January 1, 2026 in Colorado and May 31, 2026 in Minnesota, 150 days earlier here.

Colorado and Maryland both record an obligation for packaging producers. The regulator is Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program in Colorado and Maryland Department of the Environment next door. Colorado runs more than one producer responsibility organisation, while Maryland runs a single producer responsibility organisation. Registration is required in both. The first thresholds are measured differently: $5,000,000.00 of revenue in Colorado and 1 short ton of tonnage in Maryland, so the figures cannot be compared directly. The earliest recorded deadline is January 1, 2026 in Colorado and May 31, 2026 in Maryland, 150 days earlier here.

Colorado and United Kingdom both record an obligation for packaging producers. The regulator is Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program in Colorado and Four environmental regulators (Environment Agency, Natural Resources Wales, SEPA, NIEA); PackUK is the scheme administrator that sets fees next door. Colorado runs more than one producer responsibility organisation, while United Kingdom runs registered schemes that producers join. Registration is required in both. The first thresholds are measured differently: $5,000,000.00 of revenue in Colorado and 25 tonnes of tonnage in United Kingdom, so the figures cannot be compared directly. The earliest recorded deadline is January 1, 2026 in Colorado and October 1, 2026 in United Kingdom, 273 days earlier here.

Colorado and Belgium both record an obligation for packaging producers. The regulator is Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program in Colorado and Interregional Packaging Commission (IVC-CIE, now EPRiBEL) next door. Both run more than one producer responsibility organisation. Registration is required in both. The first thresholds are measured differently: $5,000,000.00 of revenue in Colorado and 300 tonnes of single-use packaging per year of tonnage in Belgium, so the figures cannot be compared directly. The earliest recorded deadline is January 1, 2026 in Colorado and August 12, 2026 in Belgium, 223 days earlier here.

Where Colorado sits among the places we cover

Counted by verified core records, Colorado holds 11 of 17 and ranks 11 of 53 places in the dataset. The places just ahead of it are Ontario (12), Italy (12), California (12), Austria (11), British Columbia (11) and Switzerland (11). The places just behind it are Bulgaria (10), New Brunswick (10), Québec (10), Spain (10), Croatia (10) and Latvia (10).

Counting every verified record, not only the core fields, Colorado holds 17 and ranks 17 of 53. Ahead of it are Minnesota (19), Germany (18), Maryland (18), Bulgaria (17), Czechia (17) and Denmark (17). Behind it are Maine (17), New Brunswick (16), Nova Scotia (16), Saskatchewan (16), Switzerland (16) and Croatia (16).

All 7 places in this region in the dataset record an obligation, so Colorado is not an outlier among its neighbours.

Ordered by earliest verified deadline, Colorado comes 6 of 41, on January 1, 2026. Before it come Austria (January 1, 2023, 1096 days earlier), Czechia (January 1, 2023, 1096 days earlier), Nova Scotia (January 1, 2024, 731 days earlier), New Brunswick (June 30, 2025, 185 days earlier) and Oregon (July 1, 2025, 184 days earlier). After it come Washington (March 1, 2026, 59 days later), Ontario (May 31, 2026, 150 days later), Québec (May 31, 2026, 150 days later), Maryland (May 31, 2026, 150 days later), Minnesota (May 31, 2026, 150 days later) and Belgium (August 12, 2026, 223 days later).

Among places whose first threshold is also counted in revenue, Colorado sits 3 of 4 from the lowest. The table sets it beside the places just below and just above.

What is still open for Colorado

Colorado has 5 of 16 core fields still open, and the reason recorded for each is below.

Transfer of the obligation

Reason recorded: The sections read (703, 709, 710, 713) do not say whether obligations can be assigned by contract. Sections 25-17-705 to 708 were not read.

Treatment of affiliates

Reason recorded: The exemption text does not say whether affiliate revenue aggregates. CAA asks producers to list affiliated producers in the supply report, which suggests it matters, but no rule text was found.

Labelling

Reason recorded: Statute sections other than 703, 709, 710 and 713 were not read, so a marking rule, if any, is unconfirmed.

Targets

Reason recorded: CDPHE gives a projection for the approved plan, not a statutory producer target. The statutory targets in the sections not read are unconfirmed.

Filing languages

Reason recorded: No page states a filing language. English is the working assumption.