Colorado vs Germany EPR: Rules Compared
Last verified
Colorado and Germany both run packaging EPR and line up on the figures compared. Both require producers to register. Every figure below links to its primary source. Instica measures, estimates and prepares; the customer signs and submits. Compare thresholds first, then fees and dates.
Colorado and Germany side by side
1 of 9 rows have a verified figure on each side of Colorado and Germany; 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 | Colorado | Germany | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | more than one producer responsibility organisation | more than one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | $5,000,000 | none recorded; see thresholds | Not comparable |
| Lowest weight exemption | 907.2 kg | none recorded; see thresholds | Not comparable |
| First annual report date | not yet published | May 15 | Not comparable |
| Published penalties | 3 published | not yet published | Not comparable |
| Report file | csv | xml | Not comparable |
| Paper fee, cheapest matched rate | 9.0 cents per pound | not yet published | Not comparable |
| Plastic fee, cheapest matched rate | 62.0 cents per pound | not yet published | Not comparable |
Both programmes require a producer to register, in Colorado and in Germany.
Who runs the programme in Colorado and Germany
Who collects and who the producer files with, in Colorado and then Germany.
| Aspect | Colorado | Germany |
|---|---|---|
| Regime | Colorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355) | Packaging producer responsibility: register in LUCID, participate packaging subject to system participation in a dual system, and report volumes |
| Regulator | Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program | Zentrale Stelle Verpackungsregister (ZSVR), which runs the LUCID Packaging Register; competent state authorities enforce |
| Producers obligated | Yes | Yes |
| Registration | Required, Circular Action Alliance producer portal | Required, LUCID Packaging Register (ZSVR) |
| Producer organisation | more than one producer responsibility organisation: Circular Action Alliance, Interchange 360 (automotive lubricant packaging, individual programme); membership required | more than one producer responsibility organisation; membership optional |
| Transfer of responsibility | not yet published | Allowed |
| Revenue counted as | realised gross total revenue, USD, prior calendar year | not yet published |
| Who counts as the producer | other: first distributor; primary: manufacturer or brand owner, brand licensee, importer; shipping: packer and shipper | other: manufacturer or brand owner, manufacturer, importer, first distributor, authorised representative; primary: manufacturer or brand owner, importer, first distributor, authorised representative; secondary: manufacturer or brand owner, importer, first distributor, authorised representative; service: manufacturer or brand owner, manufacturer, importer, first distributor, authorised representative; shipping: manufacturer or brand owner, packer and shipper, importer, first distributor, online marketplace seller, authorised representative; tertiary: manufacturer or brand owner, manufacturer, importer, first distributor, authorised representative |
Both programmes organise producer responsibility the same way: more than one producer responsibility organisation. The practical differences between Colorado and Germany therefore sit in thresholds, fees, dates and report formats rather than in whom a producer deals with.
What Colorado and Germany cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Colorado or Germany has no verified entry for it in the dataset.
| Aspect | Colorado | Germany |
|---|---|---|
| Materials covered | packaging material, paper products, food serviceware | paper and card, glass, plastic, steel, aluminium, fibre based composite, other |
| Product classes covered | packaging, paper, food serviceware | primary packaging, secondary packaging, shipment packaging, tertiary packaging, reusable packaging |
| Excluded from scope | packaging used solely in transportation to nonconsumers, packaging used solely in business to business sales | not yet published |
| Sales channels addressed | physical retail, internet transaction | retail, wholesale, online, online marketplace |
| Producer duty: primary packaging | manufacturer_brand_owner; licensee; importer | manufacturer_brand_owner; importer; first_distributor; authorised_representative |
| Producer duty: shipping packaging | packer_shipper | manufacturer_brand_owner; packer_shipper; importer; first_distributor; online_marketplace_seller; authorised_representative |
| Producer duty: other packaging | first_distributor | manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative |
| Reporting categories | 61, covered material type by material class | not yet published |
| Exemption 1 | 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. | not yet published |
| Producer duty: secondary packaging | not yet published | manufacturer_brand_owner; importer; first_distributor; authorised_representative |
| Producer duty: tertiary packaging | not yet published | manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative |
| Producer duty: service packaging | not yet published | manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative |
Thresholds and exemptions in Colorado and Germany
Every verified threshold Colorado and Germany publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| 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 |
| Germany | packaging tonnage | 80 tonnes | declaration-of-completeness trigger | glass placed on the German market in the previous calendar year (reached or exceeded) |
| Germany | packaging tonnage | 50 tonnes | declaration-of-completeness trigger | paper, paperboard and cardboard in total, previous calendar year (reached or exceeded) |
| Germany | packaging tonnage | 30 tonnes | declaration-of-completeness trigger | ferrous metals, aluminium, plastics, beverage cartons and other composites in total, previous calendar year (reached or exceeded) |
| Germany | packaging tonnage | 10 tonnes | reduced duty | packaging subject to system participation made available for the first time in the previous calendar year |
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.
Fees per kilogram for shared materials
Colorado publishes per-kilogram rates in the dataset; Germany does not. Reason: Dual-system participation fees are set by each operator's contract and no public tariff has been retrieved; the fee engine asks for the customer's contracted rates instead of estimating. The rows therefore show Colorado only. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Colorado and Germany would mean inventing a figure, and this page does not do that.
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.
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.
Deadlines in Colorado and Germany
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| Colorado | payment | January 1, 2026 | program year 2026 |
| Colorado | other | January 1, 2026 | not yet published |
| Germany | report | June 1, 2027 | calendar year 2026 |
| Germany | report | December 31, 2026 | calendar year 2027 |
| Germany | report | May 15, 2027 | calendar year 2026 |
Penalties in Colorado and Germany
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 Colorado and Germany
How the report file for Colorado compares with the one for Germany.
| Aspect | Colorado | Germany |
|---|---|---|
| Layout | Colorado producer supply report by material category 2026-09-29 (built from CAA Colorado 2026 dues schedule) | LUCID producer volume report (XML upload, section 10 VerpackG) XML interface 1.0, guide version 1.3 (12 August 2026), VerpackG material codes (reports 2019 to 2026) |
| Recipient | Circular Action Alliance (Colorado PRO) | Stiftung Zentrale Stelle Verpackungsregister (ZSVR), LUCID packaging register |
| How it is submitted | CAA producer portal. The customer signs in and submits. | LUCID XML upload. The customer signs in, uploads the file, checks the displayed data and confirms. |
| File type | csv | xml |
| Encoding | utf-8 | utf-8-sig |
| Delimiter | , | not yet published |
| Decimal separator | . | , |
| Columns | 4 | 8 |
| Required columns | 4 of 4 | 8 of 8 |
| Weight unit | lb | kg |
| Period basis | calendar year | calendar year |
Germany report specification: XML producer volume report with elements VersionNoInterface, PackagingTypeCode, TypeOfReportCode, ReportingPeriodFrom, ReportingPeriodTo and one SystemOperator with its SystemOperatorID and a Material list (MaterialCode, Mass).
The two layouts differ in file shape as well as in columns, so a report built for Colorado cannot be sent to Germany unchanged. Each report is built from the same underlying measurements and exported separately.
Questions about comparing these two programmes
Is Colorado or Germany stricter on packaging EPR?
Both require producers to register.
Do I register in both Colorado and Germany?
Colorado requires producers to register. Germany requires producers to register.
How do the fees per kilogram compare in Colorado and Germany?
The dataset does not hold per-kilogram rates for the same material class on both sides, so this page does not compare fees.
Which deadline comes first, Colorado or Germany?
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
- 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
- verpackungsregister.org: system participation retrieved
Original wording: you must finance the recycling of your packaging by participating that packaging in a system.
Original wording: You can conclude your system participation agreement with the system operator of your choice.
Original wording: you are required to conclude a system participation agreement with a system operator.
- verpackungsregister.org: declaration of completeness retrieved
Original wording: The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) and the competent state authorities
Original wording: Glass: 80 tonnes
Original wording: Paper, paperboard, cardboard (PPC) in total: 50 tonnes
Original wording: Ferrous metals + aluminium + plastics + beverage cartons + other composites (lightweight packaging) in total: 30 tonnes
Original wording: by no later than 15 May of any given year for the previous year.
- verpackungsregister.org: find out about registrations retrieved
Original wording: If you are distributing packaged goods in Germany, you have to be registered with the LUCID Packaging Register.
Original wording: you must register with the LUCID Packaging Register. Registering is free of charge.
Original wording: There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
- verpackungsregister.org: distinguishing between manufacturers producers retrieved
Original wording: A producer is every natural or legal person who, as a manufacturer, importer or distributor, makes a unit of packaging available for the first time
- verpackungsregister.org: data reporting retrieved
Original wording: A simplified reporting requirement applies to producers who made available less than 10 tonnes of packaging subject to system participation
Original wording: Year-end volume reports for the previous year (actual volumes) can only be filed up to 1 June.
Original wording: Initial planned volume reports for the following year can only be filed by 31 December of the current year.
- 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
- verpackungsregister.org: Anleitung XML Datenmeldung EN retrieved
Original wording: Mass: packaging material mass in kg to the third decimal place without thousands separators (decimal place demarcated with comma).
The free plan is enough to start. We estimate and prepare; you sign and submit.