British Columbia vs Colorado EPR: Rules Compared
Last verified
British Columbia and Colorado both run packaging EPR, but the rules differ. British Columbia exempts only producers below the lower revenue floor, CA$1,000,000 against $5,000,000 in Colorado. Colorado has the lower weight floor, 907.2 kg against 1 tonne in British Columbia. Both require producers to register.
British Columbia and Colorado side by side
5 of 9 rows have a verified figure on each side of British Columbia 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 | British Columbia | Colorado | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | one producer responsibility organisation | more than one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | CA$1,000,000 | $5,000,000 | British Columbia |
| Lowest weight exemption | 1 tonne | 907.2 kg | Colorado |
| First annual report date | May 31 | not yet published | Not comparable |
| Published penalties | 1 published | 3 published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 81 cents per kilogram | 9.0 cents per pound | British Columbia |
| Plastic fee, cheapest matched rate | 174 cents per kilogram | 62.0 cents per pound | Colorado |
The lowest revenue exemption is CA$1,000,000 in British Columbia and $5,000,000 in Colorado (CA$6,989,000 at the Bank of Canada 2025 annual average rate). British Columbia therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Colorado but still in scope in British Columbia.
The lowest weight exemption is 1 tonne of packaging in British Columbia and 907.2 kg in Colorado, about 1.1 times as much in British Columbia as in Colorado. A seller whose packaging falls between the two lines is exempt in British Columbia but counted in Colorado.
Both programmes require a producer to register, in British Columbia and in Colorado.
Across 5 shared material classes, British Columbia 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 British Columbia and Colorado
Who collects and who the producer files with, in British Columbia and then Colorado.
| Aspect | British Columbia | Colorado |
|---|---|---|
| Regime | Recycling Regulation, B.C. Reg. 449/2004 (packaging and paper product category) | Colorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355) |
| Regulator | not yet published | Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program |
| Producers obligated | Yes | Yes |
| Registration | Required, Recycle BC membership, registered through the WeRecycle Portal | Required, Circular Action Alliance producer portal |
| Producer organisation | one producer responsibility organisation: Recycle BC; membership required | more than one producer responsibility organisation: Circular Action Alliance, Interchange 360 (automotive lubricant packaging, individual programme); membership required |
| Transfer of responsibility | Allowed | not yet published |
| Revenue counted as | gross revenue inside the jurisdiction, CAD, most recent calendar year | realised gross total revenue, USD, prior calendar year |
| Who counts as the producer | other: manufacturer or brand owner, brand licensee, importer; primary: manufacturer or brand owner, brand licensee, importer; secondary: manufacturer or brand owner, brand licensee, importer; service: manufacturer or brand owner, brand licensee, importer; shipping: manufacturer or brand owner, brand licensee, importer; tertiary: manufacturer or brand owner, brand licensee, importer | other: first distributor; primary: manufacturer or brand owner, brand licensee, importer; shipping: packer and shipper |
The two programmes are organised differently. British Columbia uses one producer responsibility organisation; Colorado uses more than one producer responsibility organisation. For a seller in both, that usually means two different counterparties, two different sign-up routes and two different sets of terms to read before the first report is due.
What British Columbia and Colorado cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when British Columbia or Colorado has no verified entry for it in the dataset.
| Aspect | British Columbia | Colorado |
|---|---|---|
| Materials covered | paper, plastic, metal, glass, printed paper, packaging | packaging material, paper products, food serviceware |
| Product classes covered | packaging, paper products | packaging, paper, food serviceware |
| Excluded from scope | liquor containers handled separately, small producers | packaging used solely in transportation to nonconsumers, packaging used solely in business to business sales |
| Sales channels addressed | retail, online, distance sale | physical retail, internet transaction |
| Producer duty: primary packaging | manufacturer_brand_owner; licensee; importer | manufacturer_brand_owner; licensee; importer |
| Producer duty: secondary packaging | manufacturer_brand_owner; licensee; importer | not yet published |
| Producer duty: tertiary packaging | manufacturer_brand_owner; licensee; importer | not yet published |
| Producer duty: shipping packaging | manufacturer_brand_owner; licensee; importer | packer_shipper |
| Producer duty: service packaging | manufacturer_brand_owner; licensee; importer | not yet published |
| Producer duty: other packaging | manufacturer_brand_owner; licensee; importer | first_distributor |
| Reporting categories | 23, material category | 61, covered material type by material class |
| Exemption 1 | Businesses with less than $1 million in annual revenues in BC, or that supply less than 1,000 kg (one tonne) of packaging and paper product to BC residents | 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. |
| Exemption 2 | Businesses that operate as a single point of retail sale and are not supplied or operated as part of a franchise, a chain or under a banner | not yet published |
| Exemption 3 | Businesses that are a registered charity | not yet published |
| Exemption 4 | Recycle BC FAQ states non-resident direct shippers are not obligated (they may elect to become voluntary producers) | not yet published |
Thresholds and exemptions in British Columbia and Colorado
Every verified threshold British Columbia and Colorado publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| British Columbia | revenue | CA$1,000,000 | exempt below | gross revenue in BC, most recent calendar year |
| British Columbia | packaging tonnage | 1 tonne | exempt below | packaging and paper produced in the most recent calendar year |
| British Columbia | packaging weight | 15,000 kg | flat-fee band | packaging and paper supplied to BC residents in a year (flat-fee bands 1,000-2,499; 2,500-4,999; 5,000-9,999; 10,000-15,000 kg) |
| 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 |
British Columbia exemption: Businesses with less than $1 million in annual revenues in BC, or that supply less than 1,000 kg (one tonne) of packaging and paper product to BC residents It does not have to be applied for.
British Columbia exemption: Businesses that operate as a single point of retail sale and are not supplied or operated as part of a franchise, a chain or under a banner It does not have to be applied for.
British Columbia exemption: Businesses that are a registered charity It does not have to be applied for.
British Columbia exemption: Recycle BC FAQ states non-resident direct shippers are not obligated (they may elect to become voluntary producers) 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$1,000,000 in British Columbia and $5,000,000 in Colorado (CA$6,989,000 at the Bank of Canada 2025 annual average rate). British Columbia therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Colorado but still in scope in British Columbia.
The lowest weight exemption is 1 tonne of packaging in British Columbia and 907.2 kg in Colorado, about 1.1 times as much in British Columbia as in Colorado. A seller whose packaging falls between the two lines is exempt in British Columbia but counted in Colorado.
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 | British Columbia (CAD per kg) | Colorado (USD per kg) | Colorado in CAD, approx. | Higher fee |
|---|---|---|---|---|
| paper and board | 81 cents per kilogram | 9.0 cents per pound | CA$0.2773 | British Columbia |
| plastic | 174 cents per kilogram | 62.0 cents per pound | CA$1.9106 | Colorado |
| glass | 61 cents per kilogram | 5.0 cents per pound | CA$0.1541 | British Columbia |
| aluminium | 35 cents per kilogram | 5.0 cents per pound | CA$0.1541 | British Columbia |
| steel | 71 cents per kilogram | 11.0 cents per pound | CA$0.339 | British Columbia |
Scaling the cheapest published rate by weight shows what the gap between British Columbia and Colorado amounts to for a given tonnage of one material. The amounts are the rate times the weight, nothing added.
| Material class | Kilograms | British Columbia fee (CAD) | Colorado fee (USD) | Colorado in CAD, approx. | Colorado minus British Columbia (CAD) |
|---|---|---|---|---|---|
| paper and board | 1 | CA$0.81 | $0.20 | CA$0.28 | -CA$0.53 |
| paper and board | 10 | CA$8.10 | $1.98 | CA$2.77 | -CA$5.33 |
| paper and board | 100 | CA$81.00 | $19.84 | CA$27.73 | -CA$53.27 |
| paper and board | 1,000 | CA$810.00 | $198.42 | CA$277.35 | -CA$532.65 |
| paper and board | 10,000 | CA$8,100.00 | $1,984.16 | CA$2,773.46 | -CA$5,326.54 |
| paper and board | 100,000 | CA$81,000.00 | $19,841.60 | CA$27,734.59 | -CA$53,265.41 |
| plastic | 1 | CA$1.74 | $1.37 | CA$1.91 | +CA$0.17 |
| plastic | 10 | CA$17.40 | $13.67 | CA$19.11 | +CA$1.71 |
| plastic | 100 | CA$174.00 | $136.69 | CA$191.06 | +CA$17.06 |
| plastic | 1,000 | CA$1,740.00 | $1,366.87 | CA$1,910.61 | +CA$170.61 |
| plastic | 10,000 | CA$17,400.00 | $13,668.66 | CA$19,106.05 | +CA$1,706.05 |
| plastic | 100,000 | CA$174,000.00 | $136,686.60 | CA$191,060.53 | +CA$17,060.53 |
| glass | 1 | CA$0.61 | $0.11 | CA$0.15 | -CA$0.46 |
| glass | 10 | CA$6.10 | $1.10 | CA$1.54 | -CA$4.56 |
| glass | 100 | CA$61.00 | $11.02 | CA$15.41 | -CA$45.59 |
| glass | 1,000 | CA$610.00 | $110.23 | CA$154.08 | -CA$455.92 |
| glass | 10,000 | CA$6,100.00 | $1,102.31 | CA$1,540.81 | -CA$4,559.19 |
| glass | 100,000 | CA$61,000.00 | $11,023.11 | CA$15,408.11 | -CA$45,591.89 |
| aluminium | 1 | CA$0.35 | $0.11 | CA$0.15 | -CA$0.20 |
| aluminium | 10 | CA$3.50 | $1.10 | CA$1.54 | -CA$1.96 |
| aluminium | 100 | CA$35.00 | $11.02 | CA$15.41 | -CA$19.59 |
| aluminium | 1,000 | CA$350.00 | $110.23 | CA$154.08 | -CA$195.92 |
| aluminium | 10,000 | CA$3,500.00 | $1,102.31 | CA$1,540.81 | -CA$1,959.19 |
| aluminium | 100,000 | CA$35,000.00 | $11,023.11 | CA$15,408.11 | -CA$19,591.89 |
| steel | 1 | CA$0.71 | $0.24 | CA$0.34 | -CA$0.37 |
| steel | 10 | CA$7.10 | $2.43 | CA$3.39 | -CA$3.71 |
| steel | 100 | CA$71.00 | $24.25 | CA$33.90 | -CA$37.10 |
| steel | 1,000 | CA$710.00 | $242.51 | CA$338.98 | -CA$371.02 |
| steel | 10,000 | CA$7,100.00 | $2,425.08 | CA$3,389.78 | -CA$3,710.22 |
| steel | 100,000 | CA$71,000.00 | $24,250.85 | CA$33,897.84 | -CA$37,102.16 |
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.
British Columbia: the 2027 fee schedule of Recycle BC, effective January 1, 2027, is the source of the per-kilogram rates used on this page.
British Columbia 2027: the category “Kraft Paper” is published at 81 cents per kilogram.
British Columbia 2027: the category “Plastic Film” is published at 174 cents per kilogram.
British Columbia 2027: the category “Clear Glass” is published at 61 cents per kilogram.
British Columbia 2027: the category “Aluminum Food & Other Containers” is published at 35 cents per kilogram.
British Columbia 2027: the category “Other Steel Packaging including Paint Cans” is published at 71 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 British Columbia and Colorado.
Deadlines in British Columbia and Colorado
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| British Columbia | report | May 31 | the previous calendar year |
| British Columbia | payment | January 31 | each quarter |
| Colorado | payment | January 1, 2026 | program year 2026 |
| Colorado | other | January 1, 2026 | not yet published |
Penalties in British Columbia and Colorado
What each side has published; a side without an amount says so.
British Columbia penalty for Offence under the Recycling Regulation: up to CA$200,000 per offence.
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 British Columbia and Colorado
How the report file for British Columbia compares with the one for Colorado.
| Aspect | British Columbia | Colorado |
|---|---|---|
| Layout | Recycle BC annual supply 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 | Recycle BC | Circular Action Alliance (Colorado PRO) |
| How it is submitted | Recycle BC steward 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, British Columbia or Colorado
Check the exemption thresholds before anything else. British Columbia reaches smaller sellers than Colorado, so a seller that is exempt in Colorado may still have to register in British Columbia.
Questions about comparing these two programmes
Is British Columbia or Colorado stricter on packaging EPR?
British Columbia exempts only producers below the lower revenue floor, CA$1,000,000 against $5,000,000 in Colorado. Colorado has the lower weight floor, 907.2 kg against 1 tonne in British Columbia. Both require producers to register. British Columbia publishes the higher per-kilogram fee in 4 of 5 shared material classes.
Do I register in both British Columbia and Colorado?
British Columbia requires producers to register. Colorado requires producers to register.
How do the fees per kilogram compare in British Columbia and Colorado?
Across 5 shared material classes, British Columbia 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, British Columbia 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
- bclaws.gov.bc.ca: 449 2004 retrieved
Original wording: commits an offence and is liable to a fine not exceeding $200 000.
Original wording: if the producer is operating under a franchise agreement, the producer, the franchisor and the other parties with whom the franchisor h
Original wording: gross revenue in the most recent calendar year of less than $1 000 000 in British Columbia
Original wording: if subparagraph (i) does not apply, a person who is not the manufacturer of the product but is the owner or licensee of a trademark
Original wording: the producer had a gross revenue in the most recent calendar year of less than $1 000 000 in British Columbia;
Original wording: the producer produced in the most recent calendar year less than one tonne of products within the packaging and paper product category
Original wording: a person sells the product or offers the product for sale by any means, including
- recyclebc.ca: producer faqs retrieved
Original wording: To become a member of the Recycle BC program please visit the WeRecycle Portal and follow the steps to register as a new producer.
Original wording: Recycle BC is the only organization that businesses can join in order to fulfill the requirements of Schedule 5 of the BC Recycling Regulation
Original wording: Companies that do not have residency in BC but ship products directly to BC residents are not obligated under the BC Recycling Regulation
- recyclebc.ca: small business low volume retrieved
Original wording: Eligible stewards supplying 1,000 to 15,000 kg of PPP annually have the option to file simplified report
Original wording: Businesses that have less than $1 million in annual revenues in BC;
Original wording: operate as a single point of retail sale and are not supplied or operated as part of a franchise, a chain or under a banner
Original wording: Are a registered charity.
- recyclebc.ca: fee schedule retrieved
Original wording: Producers are required to file their reports by May 31 each year, and fees are paid quarterly as follows
Original wording: Newsprint 76
- 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
- recyclebc.ca: Recycle BC 2027 Fee Schedule retrieved
Original wording: RECYCLE BC FEE SCHEDULE (CENTS/KG)
Original wording: Kraft Paper * 81.00 77.00 5.2%
Original wording: Plastic Film 174.00 184.00 -5.4%
Original wording: GLASS Clear Glass 61.00 58.00 5.2%
Original wording: ALUMINUM Aluminum Food & Other Containers 35.00 48.00 -27.1%
Original wording: STEEL Other Steel Packaging including Paint cans ** 71.00 68.00 4.4%
- 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.