# Colorado vs Germany EPR: Rules Compared

Last verified: November 5, 2026 · https://instica.com/epr/compare/colorado-vs-germany

<a id="answer"></a>

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.

<a id="glance"></a>

## 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.

<a id="glance-table"></a>**Colorado and Germany: the measures both programmes publish**

| 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 |

<a id="calc-registration"></a>Both programmes require a producer to register, in Colorado and in Germany.

<a id="programme"></a>

## Who runs the programme in Colorado and Germany

Who collects and who the producer files with, in Colorado and then Germany.

<a id="programme-table"></a>**Colorado and Germany: how each programme is set up**

| 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 |

> **Not yet published**: Not yet published for Colorado: the rules on transferring responsibility. Reason: 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.

> **Not yet published**: Not yet published for Germany: how revenue is counted. Reason: No revenue test appears on the pages read. The value records that none was found, which is not proof that none exists.

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.

<a id="scope"></a>

## 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.

<a id="scope-table"></a>**Scope, producer duties, categories, labelling and targets, Colorado and Germany**

| 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 |

<a id="thresholds"></a>

## Thresholds and exemptions in Colorado and Germany

Every verified threshold Colorado and Germany publish, as each states it.

<a id="thresholds-table"></a>**Verified thresholds in Colorado and Germany**

| 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 |

<a id="a-exemption-statutory-exemptions"></a>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.

<a id="rates"></a>

## 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.

> **Not yet published**: Germany: no verified per-kilogram fee schedule is in the dataset yet. 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.

<a id="a-fee-source"></a>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.

<a id="a-rate-co-kraft-paper"></a>Colorado 2027: the category “Kraft Paper” is published at 9.0 cents per pound.

<a id="a-rate-co-hdpe-2-ldpe-4-flexible-and-film-items"></a>Colorado 2027: the category “HDPE (#2)/LDPE (#4) Flexible and Film Items” is published at 62.0 cents per pound.

<a id="a-rate-co-glass-bottles-and-jars-and-other-containers"></a>Colorado 2027: the category “Glass Bottles and Jars & Other Containers” is published at 5.0 cents per pound.

<a id="deadlines"></a>

## Deadlines in Colorado and Germany

Each verified date, with the period it covers when one is given.

<a id="deadlines-table"></a>**Verified deadlines in Colorado and Germany**

| 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 |

> **Not yet published**: Not yet published for Colorado: the supply report date. Reason: No Colorado report date was on the CAA or CDPHE pages read.

> **Not yet published**: Not yet published for Colorado: the plan implementation date. Reason: CDPHE gives a season, not a date.

<a id="penalties"></a>

## Penalties in Colorado and Germany

What each side has published; a side without an amount says so.

<a id="a-penalty-0"></a>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.

<a id="a-penalty-1"></a>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.

<a id="a-penalty-2"></a>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.

> **Not yet published**: Not yet published for Germany: penalty amounts. Reason: The fine amounts sit in the statute, which was not readable. Nothing is recorded rather than guessed.

<a id="formats"></a>

## Report formats in Colorado and Germany

How the report file for Colorado compares with the one for Germany.

<a id="formats-table"></a>**Report file layouts for Colorado and 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 |

> **Not yet published**: Colorado: the programme’s own report specification is not yet published. Reason: CAA retired its public Colorado guidance page on Aug 10, 2026; the reporting categories and tools are now only inside the Producer Portal, behind registration. The layout above is Instica’s working layout.

<a id="b-format-spec"></a>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.

<a id="faq"></a>

## Questions about comparing these two programmes

### <a id="q1"></a>Is Colorado or Germany stricter on packaging EPR?

Both require producers to register.

### <a id="q2"></a>Do I register in both Colorado and Germany?

Colorado requires producers to register. Germany requires producers to register.

### <a id="q3"></a>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.

### <a id="q4"></a>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.

<a id="estimate"></a>

## How these figures are made

> **Estimate**: Instica measures, estimates and prepares. Every figure on this page is read from a sourced record or computed from one, and each carries its data quality. Converted amounts are approximate and name the exchange rate used. The customer signs and submits each report; Instica never stores regulator login details and never files on your behalf. This page is general information about published rules; confirm your own position with a qualified adviser.

<a id="epr-cite-facts"></a>

## Facts on this page

Each fact is a self-contained sentence with its source. Link to a fact with its anchor.

- <a id="a-regime"></a>Colorado: the packaging rules sit in Colorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355). [#a-regime](#a-regime)
  Value: Colorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355) · Source: https://cdphe.colorado.gov/producer-responsibility-program · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: In 2022, Governor Polis signed the Producer Responsibility Program for Statewide Recycling Act into law
- <a id="a-regulator"></a>Colorado: the regulator is Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program. [#a-regulator](#a-regulator)
  Value: Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program · Source: https://cdphe.colorado.gov/producer-responsibility-program · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: CDPHE appointed Circular Action Alliance as the designated Producer Responsibility Organization in May 2023.
- <a id="a-obligated"></a>Colorado places an obligation on packaging producers. [#a-obligated](#a-obligated)
  Value: yes · Source: https://cdphe.colorado.gov/producer-responsibility-program · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: a producer cannot sell or distribute products that use covered materials in Colorado unless they participate in the Producer Responsibility Program
- <a id="a-registration"></a>Colorado: producers must register through Circular Action Alliance producer portal. [#a-registration](#a-registration)
  Value: yes · Source: https://cdphe.colorado.gov/producer-responsibility-program · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: All producers of paper products and packaging materials should register with Circular Action Alliance and submit a supply report.
- <a id="a-organisation"></a>Colorado organises producer responsibility through more than one producer responsibility organisation: Circular Action Alliance and Interchange 360 (automotive lubricant packaging, individual programme); membership is required. [#a-organisation](#a-organisation)
  Value: several competing organisations · Source: https://cdphe.colorado.gov/producer-responsibility-program · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Interchange 360 manages the recycling of automotive lubricant packaging, such as motor oil and antifreeze.
- <a id="a-revenue-scope"></a>Colorado measures revenue as realised gross total revenue in USD, over the prior calendar year. [#a-revenue-scope](#a-revenue-scope)
  Value: realized_gross_total_revenue · Source: https://colorado.public.law/statutes/crs_25-17-713 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: in realized gross total revenue, not including on-premises alcohol sales, during the prior calendar year
- <a id="a-hierarchy-other"></a>Colorado: at the other packaging level the producer hierarchy names the first distributor (2025). [#a-hierarchy-other](#a-hierarchy-other)
  Value: first distributor · Source: https://colorado.public.law/statutes/crs_25-17-703 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the person that is the licensee of a brand or trademark under which a packaged item is sold or distributed in the state
- <a id="a-hierarchy-primary"></a>Colorado: at the primary packaging level the producer hierarchy names the manufacturer or brand owner, brand licensee and importer (2025). [#a-hierarchy-primary](#a-hierarchy-primary)
  Value: manufacturer_brand_owner > licensee > importer · Source: https://colorado.public.law/statutes/crs_25-17-703 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the person that is the licensee of a brand or trademark under which a packaged item is sold or distributed in the state
- <a id="a-hierarchy-shipping"></a>Colorado: at the shipping packaging level the producer hierarchy names the packer and shipper (2025). [#a-hierarchy-shipping](#a-hierarchy-shipping)
  Value: packer or shipper · Source: https://colorado.public.law/statutes/crs_25-17-703 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the person that is the licensee of a brand or trademark under which a packaged item is sold or distributed in the state
- <a id="a-threshold-small-producer-revenue"></a>Colorado threshold on revenue: $5,000,000; effect: exempt below the threshold. [#a-threshold-small-producer-revenue](#a-threshold-small-producer-revenue)
  Value: $5,000,000 · Source: https://colorado.public.law/statutes/crs_25-17-713 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: A person with less than five million dollars in realized gross total revenue, not including on-premises alcohol sales, during the prior calendar year
- <a id="a-threshold-small-producer-tonnage"></a>Colorado threshold on tonnage: 1 short ton; effect: exempt below the threshold. [#a-threshold-small-producer-tonnage](#a-threshold-small-producer-tonnage)
  Value: 1 short ton · Source: https://colorado.public.law/statutes/crs_25-17-713 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: has used less than one ton of covered materials for products sold or distributed within or into the state
- <a id="a-threshold-flat-dues-ceiling"></a>Colorado threshold on tonnage: 10 short tons; effect: flat fee band. [#a-threshold-flat-dues-ceiling](#a-threshold-flat-dues-ceiling)
  Value: 10 short tons · Source: https://circularactionalliance.org/s/CO-2026-Dues-Schedule-Public.pdf · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Producers who supply 10 tons or less of covered materials into the state are eligible to pay flat dues according to the following schedule
- 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. [#a-exemption-statutory-exemptions](#a-exemption-statutory-exemptions)
  Value: statutory_exemptions · Source: https://colorado.public.law/statutes/crs_25-17-713 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: A producer is exempt from the requirements of this part 7 if the producer is
- <a id="a-deadline-dues-2026"></a>Colorado: payment date January 1, 2026, covering program year 2026. [#a-deadline-dues-2026](#a-deadline-dues-2026)
  Value: January 1, 2026 · Source: https://colorado.public.law/statutes/crs_25-17-709 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: no later than January 1, 2026, and annually thereafter by a date determined by the organization
- <a id="a-deadline-eco-modulation-bonus-schedule"></a>Colorado: other date January 1, 2026. [#a-deadline-eco-modulation-bonus-schedule](#a-deadline-eco-modulation-bonus-schedule)
  Value: January 1, 2026 · Source: https://colorado.public.law/statutes/crs_25-17-709 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: By January 1, 2026, and each year thereafter, the executive director shall develop an eco-modulation bonus schedule
- 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. [#a-penalty-0](#a-penalty-0)
  Value: up to 5000 for the first day, then up to 1500 per day the violation continues · Source: https://leg.colorado.gov/sites/default/files/2022a_1355_signed.pdf · Retrieved: November 5, 2026 · Status: verified
  Verbatim quote: FIRST VIOLATION, AN INITIAL PENALTY OF FIVE THOUSAND DOLLARS FOR THE FIRST DAY OF EACH VIOLATION AND ONE THOUSAND FIVE HUNDRED DOLLARS PER DAY
- 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. [#a-penalty-1](#a-penalty-1)
  Value: up to 10000 for the first day, then up to 3000 per day the violation continues · Source: https://leg.colorado.gov/sites/default/files/2022a_1355_signed.pdf · Retrieved: November 5, 2026 · Status: verified
- 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. [#a-penalty-2](#a-penalty-2)
  Value: up to 20000 for the first day, then up to 6000 per day the violation continues · Source: https://leg.colorado.gov/sites/default/files/2022a_1355_signed.pdf · Retrieved: November 5, 2026 · Status: verified
- <a id="a-scope-materials"></a>Colorado: materials covered is packaging material, paper products, food serviceware. [#a-scope-materials](#a-scope-materials)
  Value: packaging_material,paper_products,food_serviceware · Source: https://colorado.public.law/statutes/crs_25-17-703 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: means any material, regardless of recyclability, that is intended for single or short-term use
- <a id="a-scope-products"></a>Colorado: product classes covered is packaging, paper, food serviceware. [#a-scope-products](#a-scope-products)
  Value: packaging,paper,food_serviceware · Source: https://colorado.public.law/statutes/crs_25-17-703 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: means any material, regardless of recyclability, that is intended for single or short-term use
- <a id="a-scope-excluded"></a>Colorado: excluded from scope is packaging used solely in transportation to nonconsumers, packaging used solely in business to business sales. [#a-scope-excluded](#a-scope-excluded)
  Value: packaging_used_solely_in_transportation_to_nonconsumers,packaging_used_solely_in_business_to_business_sales · Source: https://colorado.public.law/statutes/crs_25-17-703 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: means any material, regardless of recyclability, that is intended for single or short-term use
- <a id="a-scope-channels"></a>Colorado: sales channels addressed is physical retail, internet transaction. [#a-scope-channels](#a-scope-channels)
  Value: physical_retail,internet_transaction · Source: https://colorado.public.law/statutes/crs_25-17-703 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: means any material, regardless of recyclability, that is intended for single or short-term use
- <a id="a-scope-ph-primary"></a>Colorado: producer duty: primary packaging is manufacturer_brand_owner; licensee; importer. [#a-scope-ph-primary](#a-scope-ph-primary)
  Value: manufacturer or brand owner, licensee, and importer · Source: https://colorado.public.law/statutes/crs_25-17-703 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the person that is the licensee of a brand or trademark under which a packaged item is sold or distributed in the state
- <a id="a-scope-ph-shipping"></a>Colorado: producer duty: shipping packaging is packer_shipper. [#a-scope-ph-shipping](#a-scope-ph-shipping)
  Value: packer or shipper · Source: https://colorado.public.law/statutes/crs_25-17-703 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the person that is the licensee of a brand or trademark under which a packaged item is sold or distributed in the state
- <a id="a-scope-ph-other"></a>Colorado: producer duty: other packaging is first_distributor. [#a-scope-ph-other](#a-scope-ph-other)
  Value: first distributor · Source: https://colorado.public.law/statutes/crs_25-17-703 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the person that is the licensee of a brand or trademark under which a packaged item is sold or distributed in the state
- <a id="a-scope-categories"></a>Colorado: reporting categories is 61, covered material type by material class. [#a-scope-categories](#a-scope-categories)
  Value: 61 · Source: https://circularactionalliance.org/s/CO-2026-Dues-Schedule-Public.pdf · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Material Class Covered Material Type Base Dues Detriments Malus Not on MRL Malus High Recycling Rates Bonus Final Dues
- <a id="a-scope-ex1"></a>Colorado: exemption 1 is 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. [#a-scope-ex1](#a-scope-ex1)
  Value: 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. · Source: https://colorado.public.law/statutes/crs_25-17-713 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: A producer is exempt from the requirements of this part 7 if the producer is
- <a id="b-regime"></a>Germany: the packaging rules sit in Packaging producer responsibility: register in LUCID, participate packaging subject to system participation in a dual system, and report volumes. [#b-regime](#b-regime)
  Value: Packaging producer responsibility: register in LUCID, participate packaging subject to system participation in a dual system, and report volumes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: you must finance the recycling of your packaging by participating that packaging in a system.
- <a id="b-regulator"></a>Germany: the regulator is Zentrale Stelle Verpackungsregister (ZSVR), which runs the LUCID Packaging Register; competent state authorities enforce. [#b-regulator](#b-regulator)
  Value: Zentrale Stelle Verpackungsregister (ZSVR), which runs the LUCID Packaging Register; competent state authorities enforce · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) and the competent state authorities
- <a id="b-obligated"></a>Germany places an obligation on packaging producers. [#b-obligated](#b-obligated)
  Value: yes · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: If you are distributing packaged goods in Germany, you have to be registered with the LUCID Packaging Register.
- <a id="b-registration"></a>Germany: producers must register through LUCID Packaging Register (ZSVR). [#b-registration](#b-registration)
  Value: yes · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: you must register with the LUCID Packaging Register. Registering is free of charge.
- <a id="b-organisation"></a>Germany organises producer responsibility through more than one producer responsibility organisation; membership is not required. [#b-organisation](#b-organisation)
  Value: several competing organisations · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: You can conclude your system participation agreement with the system operator of your choice.
- <a id="b-transfer"></a>Germany allows a producer’s obligation to be transferred to another party. [#b-transfer](#b-transfer)
  Value: yes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: you are required to conclude a system participation agreement with a system operator.
- <a id="b-hierarchy-other"></a>Germany: at the other packaging level the producer hierarchy names the manufacturer or brand owner, manufacturer, importer, first distributor and authorised representative (2026). [#b-hierarchy-other](#b-hierarchy-other)
  Value: manufacturer_brand_owner > manufacturer > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="b-hierarchy-primary"></a>Germany: at the primary packaging level the producer hierarchy names the manufacturer or brand owner, importer, first distributor and authorised representative (2026). [#b-hierarchy-primary](#b-hierarchy-primary)
  Value: manufacturer_brand_owner > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="b-hierarchy-secondary"></a>Germany: at the secondary packaging level the producer hierarchy names the manufacturer or brand owner, importer, first distributor and authorised representative (2026). [#b-hierarchy-secondary](#b-hierarchy-secondary)
  Value: manufacturer_brand_owner > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="b-hierarchy-service"></a>Germany: at the service packaging level the producer hierarchy names the manufacturer or brand owner, manufacturer, importer, first distributor and authorised representative (2026). [#b-hierarchy-service](#b-hierarchy-service)
  Value: manufacturer_brand_owner > manufacturer > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="b-hierarchy-shipping"></a>Germany: at the shipping packaging level the producer hierarchy names the manufacturer or brand owner, packer and shipper, importer, first distributor, online marketplace seller and authorised representative (2026). [#b-hierarchy-shipping](#b-hierarchy-shipping)
  Value: manufacturer_brand_owner > packer_shipper > importer > first_distributor > online_marketplace_seller > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="b-hierarchy-tertiary"></a>Germany: at the tertiary packaging level the producer hierarchy names the manufacturer or brand owner, manufacturer, importer, first distributor and authorised representative (2026). [#b-hierarchy-tertiary](#b-hierarchy-tertiary)
  Value: manufacturer_brand_owner > manufacturer > importer > first_distributor > authorised_representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="b-threshold-declaration-of-completeness-glass"></a>Germany threshold on tonnage: 80 tonnes; effect: triggers a declaration of completeness. [#b-threshold-declaration-of-completeness-glass](#b-threshold-declaration-of-completeness-glass)
  Value: 80 tonnes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Glass: 80 tonnes
- <a id="b-threshold-declaration-of-completeness-paper"></a>Germany threshold on tonnage: 50 tonnes; effect: triggers a declaration of completeness. [#b-threshold-declaration-of-completeness-paper](#b-threshold-declaration-of-completeness-paper)
  Value: 50 tonnes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Paper, paperboard, cardboard (PPC) in total: 50 tonnes
- <a id="b-threshold-declaration-of-completeness-lightweight"></a>Germany threshold on tonnage: 30 tonnes; effect: triggers a declaration of completeness. [#b-threshold-declaration-of-completeness-lightweight](#b-threshold-declaration-of-completeness-lightweight)
  Value: 30 tonnes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Ferrous metals + aluminium + plastics + beverage cartons + other composites (lightweight packaging) in total: 30 tonnes
- <a id="b-threshold-simplified-reporting"></a>Germany threshold on tonnage: 10 tonnes; effect: reduced duties. [#b-threshold-simplified-reporting](#b-threshold-simplified-reporting)
  Value: 10 tonnes · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: A simplified reporting requirement applies to producers who made available less than 10 tonnes of packaging subject to system participation
- <a id="b-deadline-year-end-volume-report"></a>Germany: report date June 1, 2027, covering calendar year 2026. [#b-deadline-year-end-volume-report](#b-deadline-year-end-volume-report)
  Value: June 1, 2027 · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Year-end volume reports for the previous year (actual volumes) can only be filed up to 1 June.
- <a id="b-deadline-planned-volume-report"></a>Germany: report date December 31, 2026, covering calendar year 2027. [#b-deadline-planned-volume-report](#b-deadline-planned-volume-report)
  Value: December 31, 2026 · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Initial planned volume reports for the following year can only be filed by 31 December of the current year.
- <a id="b-deadline-declaration-of-completeness"></a>Germany: report date May 15, 2027, covering calendar year 2026. [#b-deadline-declaration-of-completeness](#b-deadline-declaration-of-completeness)
  Value: May 15, 2027 · Source: https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: by no later than 15 May of any given year for the previous year.
- <a id="b-scope-materials"></a>Germany: materials covered is paper and card, glass, plastic, steel, aluminium, fibre based composite, other. [#b-scope-materials](#b-scope-materials)
  Value: paper_and_card,glass,plastic,steel,aluminium,fibre_based_composite,other · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
- <a id="b-scope-products"></a>Germany: product classes covered is primary packaging, secondary packaging, shipment packaging, tertiary packaging, reusable packaging. [#b-scope-products](#b-scope-products)
  Value: primary_packaging,secondary_packaging,shipment_packaging,tertiary_packaging,reusable_packaging · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
- <a id="b-scope-channels"></a>Germany: sales channels addressed is retail, wholesale, online, online marketplace. [#b-scope-channels](#b-scope-channels)
  Value: retail,wholesale,online,online_marketplace · Source: https://www.verpackungsregister.org/en/registration/find-out-about-registrations · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
- <a id="b-scope-ph-primary"></a>Germany: producer duty: primary packaging is manufacturer_brand_owner; importer; first_distributor; authorised_representative. [#b-scope-ph-primary](#b-scope-ph-primary)
  Value: manufacturer or brand owner, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="b-scope-ph-secondary"></a>Germany: producer duty: secondary packaging is manufacturer_brand_owner; importer; first_distributor; authorised_representative. [#b-scope-ph-secondary](#b-scope-ph-secondary)
  Value: manufacturer or brand owner, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="b-scope-ph-tertiary"></a>Germany: producer duty: tertiary packaging is manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative. [#b-scope-ph-tertiary](#b-scope-ph-tertiary)
  Value: manufacturer or brand owner, manufacturer, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="b-scope-ph-shipping"></a>Germany: producer duty: shipping packaging is manufacturer_brand_owner; packer_shipper; importer; first_distributor; online_marketplace_seller; authorised_representative. [#b-scope-ph-shipping](#b-scope-ph-shipping)
  Value: manufacturer or brand owner, packer or shipper, importer, first distributor, seller on an online marketplace, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="b-scope-ph-service"></a>Germany: producer duty: service packaging is manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative. [#b-scope-ph-service](#b-scope-ph-service)
  Value: manufacturer or brand owner, manufacturer, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- <a id="b-scope-ph-other"></a>Germany: producer duty: other packaging is manufacturer_brand_owner; manufacturer; importer; first_distributor; authorised_representative. [#b-scope-ph-other](#b-scope-ph-other)
  Value: manufacturer or brand owner, manufacturer, importer, first distributor, and authorized representative · Source: https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: 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
- Both programmes require a producer to register, in Colorado and in Germany. [#calc-registration](#calc-registration)
  Value: same · Source: https://cdphe.colorado.gov/producer-responsibility-program · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: All producers of paper products and packaging materials should register with Circular Action Alliance and submit a supply report.
- 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. [#a-fee-source](#a-fee-source)
  Value: CAA Colorado 2027 Producer Dues Schedule (public) · Source: https://circularactionalliance.org/s/CO-2027DuesSchedule_100126.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: 2027 Colorado Producer Dues Schedule Dues for Program Year 2027
- Colorado 2027: the category “Kraft Paper” is published at 9.0 cents per pound. [#a-rate-co-kraft-paper](#a-rate-co-kraft-paper)
  Value: 9.0 cents_per_lb · Source: https://circularactionalliance.org/s/CO-2027DuesSchedule_100126.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: Kraft Paper MRL $0.09 $0.00 $0.00 $0.00 $0.09
- Colorado 2027: the category “HDPE (#2)/LDPE (#4) Flexible and Film Items” is published at 62.0 cents per pound. [#a-rate-co-hdpe-2-ldpe-4-flexible-and-film-items](#a-rate-co-hdpe-2-ldpe-4-flexible-and-film-items)
  Value: 62.0 cents_per_lb · Source: https://circularactionalliance.org/s/CO-2027DuesSchedule_100126.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: HDPE (#2)/LDPE (#4) Flexible and Film Items AML $0.62 $0.00 $0.00 $0.00 $0.62
- Colorado 2027: the category “Glass Bottles and Jars & Other Containers” is published at 5.0 cents per pound. [#a-rate-co-glass-bottles-and-jars-and-other-containers](#a-rate-co-glass-bottles-and-jars-and-other-containers)
  Value: 5.0 cents_per_lb · Source: https://circularactionalliance.org/s/CO-2027DuesSchedule_100126.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: Glass Bottles and Jars & Other Containers MRL $0.05 $0.00 $0.00 $0.00 $0.05
- 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). [#b-format-spec](#b-format-spec)
  Value: XML producer volume report with elements VersionNoInterface, PackagingTypeCode, TypeOfReportCode, ReportingPeriodFrom, ReportingPeriodTo and one SystemOperator with its SystemOperatorID and a Material list (MaterialCode, Mass). · Source: https://www.verpackungsregister.org/fileadmin/files/LUCID/Anleitung_XML_Datenmeldung_EN.pdf · Retrieved: September 30, 2026 · Status: verified
  Verbatim quote: Mass: packaging material mass in kg to the third decimal place without thousands separators (decimal place demarcated with comma).

## Related pages

### Part of

- [Colorado EPR threshold](https://instica.com/epr/colorado)

### Explore packaging EPR

- [United States packaging EPR: 7 jurisdictions](https://instica.com/epr/united-states)

### More for this jurisdiction

- [Germany EPR](https://instica.com/epr/germany)

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## Sources

1. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > In 2022, Governor Polis signed the Producer Responsibility Program for Statewide Recycling Act into law
2. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > CDPHE appointed Circular Action Alliance as the designated Producer Responsibility Organization in May 2023.
3. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > a producer cannot sell or distribute products that use covered materials in Colorado unless they participate in the Producer Responsibility Program
4. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > All producers of paper products and packaging materials should register with Circular Action Alliance and submit a supply report.
5. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > Interchange 360 manages the recycling of automotive lubricant packaging, such as motor oil and antifreeze.
6. colorado.public.law: crs 25 17 713 (https://colorado.public.law/statutes/crs_25-17-713), Retrieved: September 29, 2026, Status: verified
   > in realized gross total revenue, not including on-premises alcohol sales, during the prior calendar year
7. colorado.public.law: crs 25 17 703 (https://colorado.public.law/statutes/crs_25-17-703), Retrieved: September 29, 2026, Status: verified
   > the person that is the licensee of a brand or trademark under which a packaged item is sold or distributed in the state
8. colorado.public.law: crs 25 17 713 (https://colorado.public.law/statutes/crs_25-17-713), Retrieved: September 29, 2026, Status: verified
   > A person with less than five million dollars in realized gross total revenue, not including on-premises alcohol sales, during the prior calendar year
9. colorado.public.law: crs 25 17 713 (https://colorado.public.law/statutes/crs_25-17-713), Retrieved: September 29, 2026, Status: verified
   > has used less than one ton of covered materials for products sold or distributed within or into the state
10. circularactionalliance.org: CO 2026 Dues Schedule Public (https://circularactionalliance.org/s/CO-2026-Dues-Schedule-Public.pdf), Retrieved: September 29, 2026, Status: verified
   > Producers who supply 10 tons or less of covered materials into the state are eligible to pay flat dues according to the following schedule
11. colorado.public.law: crs 25 17 713 (https://colorado.public.law/statutes/crs_25-17-713), Retrieved: September 29, 2026, Status: verified
   > A producer is exempt from the requirements of this part 7 if the producer is
12. colorado.public.law: crs 25 17 709 (https://colorado.public.law/statutes/crs_25-17-709), Retrieved: September 29, 2026, Status: verified
   > no later than January 1, 2026, and annually thereafter by a date determined by the organization
13. colorado.public.law: crs 25 17 709 (https://colorado.public.law/statutes/crs_25-17-709), Retrieved: September 29, 2026, Status: verified
   > By January 1, 2026, and each year thereafter, the executive director shall develop an eco-modulation bonus schedule
14. leg.colorado.gov: 2022a 1355 signed (https://leg.colorado.gov/sites/default/files/2022a_1355_signed.pdf), Retrieved: November 5, 2026, Status: verified
   > FIRST VIOLATION, AN INITIAL PENALTY OF FIVE THOUSAND DOLLARS FOR THE FIRST DAY OF EACH VIOLATION AND ONE THOUSAND FIVE HUNDRED DOLLARS PER DAY
15. leg.colorado.gov: 2022a 1355 signed (https://leg.colorado.gov/sites/default/files/2022a_1355_signed.pdf), Retrieved: November 5, 2026, Status: verified
16. colorado.public.law: crs 25 17 703 (https://colorado.public.law/statutes/crs_25-17-703), Retrieved: September 29, 2026, Status: verified
   > means any material, regardless of recyclability, that is intended for single or short-term use
17. circularactionalliance.org: CO 2026 Dues Schedule Public (https://circularactionalliance.org/s/CO-2026-Dues-Schedule-Public.pdf), Retrieved: September 29, 2026, Status: verified
   > Material Class Covered Material Type Base Dues Detriments Malus Not on MRL Malus High Recycling Rates Bonus Final Dues
18. verpackungsregister.org: system participation (https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation), Retrieved: September 29, 2026, Status: verified
   > you must finance the recycling of your packaging by participating that packaging in a system.
19. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register – ZSVR) and the competent state authorities
20. verpackungsregister.org: find out about registrations (https://www.verpackungsregister.org/en/registration/find-out-about-registrations), Retrieved: September 29, 2026, Status: verified
   > If you are distributing packaged goods in Germany, you have to be registered with the LUCID Packaging Register.
21. verpackungsregister.org: find out about registrations (https://www.verpackungsregister.org/en/registration/find-out-about-registrations), Retrieved: September 29, 2026, Status: verified
   > you must register with the LUCID Packaging Register. Registering is free of charge.
22. verpackungsregister.org: system participation (https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation), Retrieved: September 29, 2026, Status: verified
   > You can conclude your system participation agreement with the system operator of your choice.
23. verpackungsregister.org: system participation (https://www.verpackungsregister.org/en/system-participation-data-reporting/system-participation), Retrieved: September 29, 2026, Status: verified
   > you are required to conclude a system participation agreement with a system operator.
24. verpackungsregister.org: distinguishing between manufacturers producers (https://www.verpackungsregister.org/en/first-steps/distinguishing-between-manufacturers-producers), Retrieved: November 4, 2026, Status: verified
   > 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
25. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > Glass: 80 tonnes
26. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > Paper, paperboard, cardboard (PPC) in total: 50 tonnes
27. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > Ferrous metals + aluminium + plastics + beverage cartons + other composites (lightweight packaging) in total: 30 tonnes
28. verpackungsregister.org: data reporting (https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting), Retrieved: September 29, 2026, Status: verified
   > A simplified reporting requirement applies to producers who made available less than 10 tonnes of packaging subject to system participation
29. verpackungsregister.org: data reporting (https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting), Retrieved: September 29, 2026, Status: verified
   > Year-end volume reports for the previous year (actual volumes) can only be filed up to 1 June.
30. verpackungsregister.org: data reporting (https://www.verpackungsregister.org/en/system-participation-data-reporting/data-reporting), Retrieved: September 29, 2026, Status: verified
   > Initial planned volume reports for the following year can only be filed by 31 December of the current year.
31. verpackungsregister.org: declaration of completeness (https://www.verpackungsregister.org/en/system-participation-data-reporting/declaration-of-completeness), Retrieved: September 29, 2026, Status: verified
   > by no later than 15 May of any given year for the previous year.
32. verpackungsregister.org: find out about registrations (https://www.verpackungsregister.org/en/registration/find-out-about-registrations), Retrieved: September 29, 2026, Status: verified
   > There are two different packaging categories: packaging subject to system participation and packaging not subject to system participation.
33. circularactionalliance.org: CO 2027DuesSchedule 100126 (https://circularactionalliance.org/s/CO-2027DuesSchedule_100126.pdf), Retrieved: October 22, 2026, Status: verified
   > 2027 Colorado Producer Dues Schedule Dues for Program Year 2027
34. circularactionalliance.org: CO 2027DuesSchedule 100126 (https://circularactionalliance.org/s/CO-2027DuesSchedule_100126.pdf), Retrieved: October 22, 2026, Status: verified
   > Kraft Paper MRL $0.09 $0.00 $0.00 $0.00 $0.09
35. circularactionalliance.org: CO 2027DuesSchedule 100126 (https://circularactionalliance.org/s/CO-2027DuesSchedule_100126.pdf), Retrieved: October 22, 2026, Status: verified
   > HDPE (#2)/LDPE (#4) Flexible and Film Items AML $0.62 $0.00 $0.00 $0.00 $0.62
36. circularactionalliance.org: CO 2027DuesSchedule 100126 (https://circularactionalliance.org/s/CO-2027DuesSchedule_100126.pdf), Retrieved: October 22, 2026, Status: verified
   > Glass Bottles and Jars & Other Containers MRL $0.05 $0.00 $0.00 $0.00 $0.05
37. verpackungsregister.org: Anleitung XML Datenmeldung EN (https://www.verpackungsregister.org/fileadmin/files/LUCID/Anleitung_XML_Datenmeldung_EN.pdf), Retrieved: September 30, 2026, Status: verified
   > Mass: packaging material mass in kg to the third decimal place without thousands separators (decimal place demarcated with comma).

## Cite this page

Instica, “Colorado vs Germany EPR: Rules Compared”, https://instica.com/epr/compare/colorado-vs-germany, last verified 2026-11-05, dataset v1-281284b7e7c1, CC-BY-4.0.

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