Alberta vs Colorado EPR: Rules Compared
Last verified
Alberta and Colorado both run packaging EPR, but the rules differ. Alberta exempts only producers below the lower revenue floor, CA$1,500,000 against $5,000,000 in Colorado. Alberta publishes the higher per-kilogram fee in 4 of 5 shared material classes. Every figure below links to its primary source.
Alberta and Colorado side by side
3 of 9 rows have a verified figure on each side of Alberta and Colorado; a cell reads “not yet published” when a side has none, and an exemption row reads “none recorded; see thresholds” when no exemption is on record.
| Measure | Alberta | Colorado | Stricter |
|---|---|---|---|
| Registration duty | not yet published | Required | Not comparable |
| Producer organisation | not yet published | more than one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | CA$1,500,000 | $5,000,000 | Alberta |
| Lowest weight exemption | none recorded; see thresholds | 907.2 kg | Not comparable |
| First annual report date | June 30 | not yet published | Not comparable |
| Published penalties | not yet published | 3 published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 48 cents per kilogram | 9.0 cents per pound | Alberta |
| Plastic fee, cheapest matched rate | 176 cents per kilogram | 62.0 cents per pound | Colorado |
The lowest revenue exemption is CA$1,500,000 in Alberta and $5,000,000 in Colorado (CA$6,989,000 at the Bank of Canada 2025 annual average rate). Alberta therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Colorado but still in scope in Alberta.
Across 5 shared material classes, Alberta publishes the higher cheapest per-kilogram fee in 4, and Colorado in 1. A higher fee is not the same as a stricter rule; it is simply a larger published number per kilogram.
Who runs the programme in Alberta and Colorado
Who collects and who the producer files with, in Alberta and then Colorado.
| Aspect | Alberta | Colorado |
|---|---|---|
| Regime | Extended Producer Responsibility Regulation, Environmental Protection and Enhancement Act (packaging, paper products) | Colorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355) |
| Regulator | Alberta Recycling Management Authority (ARMA) | Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program |
| Producers obligated | Yes | Yes |
| Registration | not yet published | Required, Circular Action Alliance producer portal |
| Producer organisation | not yet published | more than one producer responsibility organisation: Circular Action Alliance, Interchange 360 (automotive lubricant packaging, individual programme); membership required |
| Revenue counted as | gross revenue inside the jurisdiction, CAD, year | realised gross total revenue, USD, prior calendar year |
| Who counts as the producer | primary: brand owner, importer, seller; secondary: brand owner, importer, seller; shipping: brand owner, importer, seller; tertiary: brand owner, importer, seller | other: first distributor; primary: manufacturer or brand owner, brand licensee, importer; shipping: packer and shipper |
Where one side has not yet published how its producer organisations work, this page says so rather than assuming it matches the other side. A seller in both should check the open item before relying on the comparison.
What Alberta and Colorado cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Alberta or Colorado has no verified entry for it in the dataset.
| Aspect | Alberta | Colorado |
|---|---|---|
| Producer duty: primary packaging | brand_owner; importer; seller | manufacturer_brand_owner; licensee; importer |
| Producer duty: secondary packaging | brand_owner; importer; seller | not yet published |
| Producer duty: tertiary packaging | brand_owner; importer; seller | not yet published |
| Producer duty: shipping packaging | brand_owner; importer; seller | packer_shipper |
| Reporting categories | 33, material category | 61, covered material type by material class |
| Exemption 1 | Producers under CAD 1,500,000 Alberta revenue are exempt | Exempt from Part 7: revenue under the dollar limit, under one ton of covered materials, state or local government, nonprofit, an agricultural employer with under $5 million in-state consumer sales of its own-brand farm products, a single licensed retail food establishment at a physical location, and builders, construction companies and contractors. |
| Materials covered | not yet published | packaging material, paper products, food serviceware |
| Product classes covered | not yet published | packaging, paper, food serviceware |
| Excluded from scope | not yet published | packaging used solely in transportation to nonconsumers, packaging used solely in business to business sales |
| Sales channels addressed | not yet published | physical retail, internet transaction |
| Producer duty: other packaging | not yet published | first_distributor |
Thresholds and exemptions in Alberta and Colorado
Every verified threshold Alberta and Colorado publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| Alberta | revenue | CA$1,500,000 | exempt below | Alberta revenue |
| Alberta | packaging tonnage | 9 tonnes | reduced duty | residential supply per year (9 t paper; 2 t rigid plastic; 2 t flexible plastic; 1 t glass; 1 t metal) |
| Colorado | revenue | $5,000,000 | exempt below | realized gross total revenue, prior calendar year, excluding on-premises alcohol sales |
| Colorado | packaging tonnage | 1 short ton | exempt below | covered materials used for products sold or distributed in or into Colorado, prior calendar year |
| Colorado | packaging tonnage | 10 short tons | flat-fee band | covered materials supplied into Colorado |
Alberta exemption: Producers under CAD 1,500,000 Alberta revenue are exempt It does not have to be applied for.
Colorado exemption: Exempt from Part 7: revenue under the dollar limit, under one ton of covered materials, state or local government, nonprofit, an agricultural employer with under $5 million in-state consumer sales of its own-brand farm products, a single licensed retail food establishment at a physical location, and builders, construction companies and contractors. It does not have to be applied for.
Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.
The lowest revenue exemption is CA$1,500,000 in Alberta and $5,000,000 in Colorado (CA$6,989,000 at the Bank of Canada 2025 annual average rate). Alberta therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Colorado but still in scope in Alberta.
Fees per kilogram for shared materials
5 material classes have a published rate on both sides; each row shows the cheapest rate that fits the class.
| Material class | Alberta (CAD per kg) | Colorado (USD per kg) | Colorado in CAD, approx. | Higher fee |
|---|---|---|---|---|
| paper and board | 48 cents per kilogram | 9.0 cents per pound | CA$0.2773 | Alberta |
| plastic | 176 cents per kilogram | 62.0 cents per pound | CA$1.9106 | Colorado |
| glass | 41 cents per kilogram | 5.0 cents per pound | CA$0.1541 | Alberta |
| aluminium | 98 cents per kilogram | 5.0 cents per pound | CA$0.1541 | Alberta |
| steel | 62 cents per kilogram | 11.0 cents per pound | CA$0.339 | Alberta |
Scaling the cheapest published rate by weight shows what the gap between Alberta and Colorado amounts to for a given tonnage of one material. The amounts are the rate times the weight, nothing added.
| Material class | Kilograms | Alberta fee (CAD) | Colorado fee (USD) | Colorado in CAD, approx. | Colorado minus Alberta (CAD) |
|---|---|---|---|---|---|
| paper and board | 1 | CA$0.48 | $0.20 | CA$0.28 | -CA$0.20 |
| paper and board | 10 | CA$4.80 | $1.98 | CA$2.77 | -CA$2.03 |
| paper and board | 100 | CA$48.00 | $19.84 | CA$27.73 | -CA$20.27 |
| paper and board | 1,000 | CA$480.00 | $198.42 | CA$277.35 | -CA$202.65 |
| paper and board | 10,000 | CA$4,800.00 | $1,984.16 | CA$2,773.46 | -CA$2,026.54 |
| paper and board | 100,000 | CA$48,000.00 | $19,841.60 | CA$27,734.59 | -CA$20,265.41 |
| plastic | 1 | CA$1.76 | $1.37 | CA$1.91 | +CA$0.15 |
| plastic | 10 | CA$17.60 | $13.67 | CA$19.11 | +CA$1.51 |
| plastic | 100 | CA$176.00 | $136.69 | CA$191.06 | +CA$15.06 |
| plastic | 1,000 | CA$1,760.00 | $1,366.87 | CA$1,910.61 | +CA$150.61 |
| plastic | 10,000 | CA$17,600.00 | $13,668.66 | CA$19,106.05 | +CA$1,506.05 |
| plastic | 100,000 | CA$176,000.00 | $136,686.60 | CA$191,060.53 | +CA$15,060.53 |
| glass | 1 | CA$0.41 | $0.11 | CA$0.15 | -CA$0.26 |
| glass | 10 | CA$4.10 | $1.10 | CA$1.54 | -CA$2.56 |
| glass | 100 | CA$41.00 | $11.02 | CA$15.41 | -CA$25.59 |
| glass | 1,000 | CA$410.00 | $110.23 | CA$154.08 | -CA$255.92 |
| glass | 10,000 | CA$4,100.00 | $1,102.31 | CA$1,540.81 | -CA$2,559.19 |
| glass | 100,000 | CA$41,000.00 | $11,023.11 | CA$15,408.11 | -CA$25,591.89 |
| aluminium | 1 | CA$0.98 | $0.11 | CA$0.15 | -CA$0.83 |
| aluminium | 10 | CA$9.80 | $1.10 | CA$1.54 | -CA$8.26 |
| aluminium | 100 | CA$98.00 | $11.02 | CA$15.41 | -CA$82.59 |
| aluminium | 1,000 | CA$980.00 | $110.23 | CA$154.08 | -CA$825.92 |
| aluminium | 10,000 | CA$9,800.00 | $1,102.31 | CA$1,540.81 | -CA$8,259.19 |
| aluminium | 100,000 | CA$98,000.00 | $11,023.11 | CA$15,408.11 | -CA$82,591.89 |
| steel | 1 | CA$0.62 | $0.24 | CA$0.34 | -CA$0.28 |
| steel | 10 | CA$6.20 | $2.43 | CA$3.39 | -CA$2.81 |
| steel | 100 | CA$62.00 | $24.25 | CA$33.90 | -CA$28.10 |
| steel | 1,000 | CA$620.00 | $242.51 | CA$338.98 | -CA$281.02 |
| steel | 10,000 | CA$6,200.00 | $2,425.08 | CA$3,389.78 | -CA$2,810.22 |
| steel | 100,000 | CA$62,000.00 | $24,250.85 | CA$33,897.84 | -CA$28,102.16 |
Converted from USD to CAD at the Bank of Canada annual average for 2025. A converted figure is approximate and moves with the year of the rate; the published amount is the one in the programme’s own currency.
Colorado: the 2027 fee schedule of Circular Action Alliance (Colorado PRO), effective January 1, 2027, is the source of the per-kilogram rates used on this page.
Alberta: the 2027 fee schedule of Circular Materials Alberta (ARMA PPP), effective January 1, 2027, is the source of the per-kilogram rates used on this page.
Alberta 2027: the category “Boxboard and Other Paper Packaging” is published at 48 cents per kilogram.
Alberta 2027: the category “LDPE/HDPE Film” is published at 176 cents per kilogram.
Alberta 2027: the category “Clear Glass” is published at 41 cents per kilogram.
Alberta 2027: the category “Aluminum Food Containers” is published at 98 cents per kilogram.
Alberta 2027: the category “Other Steel Containers and Packaging” is published at 62 cents per kilogram.
Colorado 2027: the category “Kraft Paper” is published at 9.0 cents per pound.
Colorado 2027: the category “HDPE (#2)/LDPE (#4) Flexible and Film Items” is published at 62.0 cents per pound.
Colorado 2027: the category “Glass Bottles and Jars & Other Containers” is published at 5.0 cents per pound.
Colorado 2027: the category “Aluminum Containers” is published at 5.0 cents per pound.
Colorado 2027: the category “Steel Containers” is published at 11.0 cents per pound.
Real packs usually land in a dearer category, so use the calculator for Alberta and Colorado.
Deadlines in Alberta and Colorado
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| Alberta | report | June 30 | preceding calendar year (January 1 to December 31) |
| Alberta | rate publication | March 8 | current calendar year's ARMA oversight fees (based on supply data from two years earlier) |
| Alberta | payment | April 8 | current calendar year's ARMA oversight fees |
| Alberta | other | October 1, 2026 | not yet published |
| Colorado | payment | January 1, 2026 | program year 2026 |
| Colorado | other | January 1, 2026 | not yet published |
Penalties in Alberta and Colorado
What each side has published; a side without an amount says so.
Colorado penalty for First violation of Part 7 by a producer or producer responsibility organization: up to $5,000 for the first day, then up to $1,500 per day the violation continues.
Colorado penalty for Second violation within twelve months after a prior violation: up to $10,000 for the first day, then up to $3,000 per day the violation continues.
Colorado penalty for Third or later violation within twelve months after two or more prior violations: up to $20,000 for the first day, then up to $6,000 per day the violation continues.
Report formats in Alberta and Colorado
How the report file for Alberta compares with the one for Colorado.
| Aspect | Alberta | Colorado |
|---|---|---|
| Layout | Alberta PPP producer annual report Fee-year categories, reviewed 2026-09-29 | Colorado producer supply report by material category 2026-09-29 (built from CAA Colorado 2026 dues schedule) |
| Recipient | Alberta Recycling Management Authority | Circular Action Alliance (Colorado PRO) |
| How it is submitted | ARMA producer portal | CAA producer portal. The customer signs in and submits. |
| File type | csv | csv |
| Encoding | utf-8 | utf-8 |
| Delimiter | , | , |
| Decimal separator | . | |
| Columns | 4 | 4 |
| Required columns | 4 of 4 | 4 of 4 |
| Weight unit | kg | lb |
| Period basis | calendar year | calendar year |
The two layouts share a file type and a delimiter, but each programme names its own columns and categories, so one file cannot be sent to both programmes. Each report is built from the same underlying measurements and exported separately.
Which to plan for first, Alberta or Colorado
Check the exemption thresholds before anything else. Alberta reaches smaller sellers than Colorado, so a seller that is exempt in Colorado may still have to register in Alberta.
Questions about comparing these two programmes
Is Alberta or Colorado stricter on packaging EPR?
Alberta exempts only producers below the lower revenue floor, CA$1,500,000 against $5,000,000 in Colorado. Alberta publishes the higher per-kilogram fee in 4 of 5 shared material classes.
Do I register in both Alberta and Colorado?
Alberta has not yet published its registration duty. Colorado requires producers to register.
How do the fees per kilogram compare in Alberta and Colorado?
Across 5 shared material classes, Alberta publishes the higher cheapest per-kilogram fee in 4, and Colorado in 1. A higher fee is not the same as a stricter rule; it is simply a larger published number per kilogram.
Which deadline comes first, Alberta or Colorado?
The dataset does not hold a verified annual report date on both sides, so this page does not say which comes first.
How these figures are made
Sources
- albertarecycling.ca retrieved
Original wording: PPP Producers shall submit an annual report to the Authority no later than June 30th each year.
- files.albertarecycling.ca: EPR Single‑Use Products Packaging and Paper Products Bylaws retrieved
Original wording: has an annual gross revenue in Alberta less than one million and five hundred thousand dollars $1,500,000.
Original wording: less than each of the amounts listed for the following materials: (a) 9 tonnes of paper per calendar year; (b) 2 tonnes of rigid plastic
Original wording: PPP Producers shall submit an annual report to the Authority no later than June 30th each year.
Original wording: A PPP Producer must provide, by October 1, 2026, to single-family dwellings in Registered Communities that were not receiving recycling service
- kings-printer.alberta.ca: 2022 194 retrieved
Original wording: the producer is (a) the brand holder of the designated material, if the brand holder is resident in Canada,
- albertarecycling.ca: EPR Oversight Fee Guide retrieved
Original wording: By March 8 Notice of Final Oversight Fees posted (minimum of 30 days prior to invoicing) April 8 Invoicing of Oversight Fees
- circularmaterials.ca: Circular Materials Report to Producers 2025 retrieved
Original wording: Newspapers 83 84 -1.2%
- cdphe.colorado.gov: producer responsibility program retrieved
Original wording: In 2022, Governor Polis signed the Producer Responsibility Program for Statewide Recycling Act into law
Original wording: CDPHE appointed Circular Action Alliance as the designated Producer Responsibility Organization in May 2023.
Original wording: a producer cannot sell or distribute products that use covered materials in Colorado unless they participate in the Producer Responsibility Program
Original wording: All producers of paper products and packaging materials should register with Circular Action Alliance and submit a supply report.
Original wording: Interchange 360 manages the recycling of automotive lubricant packaging, such as motor oil and antifreeze.
- colorado.public.law: crs 25 17 713 retrieved
Original wording: in realized gross total revenue, not including on-premises alcohol sales, during the prior calendar year
Original wording: A person with less than five million dollars in realized gross total revenue, not including on-premises alcohol sales, during the prior calendar year
Original wording: has used less than one ton of covered materials for products sold or distributed within or into the state
Original wording: A producer is exempt from the requirements of this part 7 if the producer is
- colorado.public.law: crs 25 17 703 retrieved
Original wording: the person that is the licensee of a brand or trademark under which a packaged item is sold or distributed in the state
Original wording: means any material, regardless of recyclability, that is intended for single or short-term use
- circularactionalliance.org: CO 2026 Dues Schedule Public retrieved
Original wording: Producers who supply 10 tons or less of covered materials into the state are eligible to pay flat dues according to the following schedule
Original wording: Material Class Covered Material Type Base Dues Detriments Malus Not on MRL Malus High Recycling Rates Bonus Final Dues
- colorado.public.law: crs 25 17 709 retrieved
Original wording: no later than January 1, 2026, and annually thereafter by a date determined by the organization
Original wording: By January 1, 2026, and each year thereafter, the executive director shall develop an eco-modulation bonus schedule
- leg.colorado.gov: 2022a 1355 signed retrieved
Original wording: FIRST VIOLATION, AN INITIAL PENALTY OF FIVE THOUSAND DOLLARS FOR THE FIRST DAY OF EACH VIOLATION AND ONE THOUSAND FIVE HUNDRED DOLLARS PER DAY
- Bank of Canada, FXAUSDCAD (annual average 2025) retrieved
- knowledge.werecycle.ca: Report to Producers 2026 OCT15 retrieved
Original wording: Circular Materials in Alberta Fee Schedule (Cents/Kg)
Original wording: Boxboard and Other Paper Packaging 48 40 20.0%
Original wording: LDPE/HDPE Film 176 198 -11.1%
Original wording: Clear Glass 41 45 -8.9%
Original wording: Aluminum Food Containers 98 77 27 .3%
Original wording: Other Steel Containers and Packaging 62 69 -10.1%
- circularactionalliance.org: CO 2027DuesSchedule 100126 retrieved
Original wording: 2027 Colorado Producer Dues Schedule Dues for Program Year 2027
Original wording: Kraft Paper MRL $0.09 $0.00 $0.00 $0.00 $0.09
Original wording: HDPE (#2)/LDPE (#4) Flexible and Film Items AML $0.62 $0.00 $0.00 $0.00 $0.62
Original wording: Glass Bottles and Jars & Other Containers MRL $0.05 $0.00 $0.00 $0.00 $0.05
Original wording: Aluminum Containers MRL $0.05 $0.00 $0.00 $0.00 $0.05
Original wording: Steel Containers MRL $0.12 $0.00 $0.00 -$0.01 $0.11
The free plan is enough to start. We estimate and prepare; you sign and submit.