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Colorado vs Italy EPR: Rules Compared

Last verified

Colorado and Italy 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.

Paired bars comparing how many verified thresholds, deadlines and penalties Colorado and Italy publish, and how many columns their report layouts hold.Colorado / Italy (published items): Thresholds: Colorado 3, Italy 1; Deadlines: Colorado 2, Italy 2; Penalties: Colorado 3, Italy 2; Report columns: Colorado 4, Italy 4ColoradoItalypublished items01234Thresholds31Deadlines22Penalties32Report columns44
Source: Colorado and Italy primary sources, retrieved 2026-11-05

Colorado and Italy side by side

1 of 9 rows have a verified figure on each side of Colorado and Italy; 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.

Colorado and Italy: the measures both programmes publish
MeasureColoradoItalyStricter
Registration dutyRequiredRequiredSame
Producer organisationmore than one producer responsibility organisationproducer compliance schemesNot comparable
Lowest revenue exemption$5,000,000none recorded; see thresholdsNot comparable
Lowest weight exemption907.2 kgnone recorded; see thresholdsNot comparable
First annual report datenot yet publishedJune 1Not comparable
Published penalties3 published2 publishedNot comparable
Report filecsvcsvNot comparable
Paper fee, cheapest matched rate9.0 cents per pound65.00 EUR/tonneNot comparable
Plastic fee, cheapest matched rate62.0 cents per poundnot yet publishedNot comparable

Both programmes require a producer to register, in Colorado and in Italy.

Who runs the programme in Colorado and Italy

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

Colorado and Italy: how each programme is set up
AspectColoradoItaly
RegimeColorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355)Legislative Decree 152/2006, Part IV Title II (packaging and packaging waste), CONAI consortium system
RegulatorColorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management ProgramMinistry of Environment and Energy Security (MASE); CONAI coordinates the consortium system
Producers obligatedYesYes
RegistrationRequired, Circular Action Alliance producer portalRequired, CONAI membership (declaration and contribution to CONAI, then consortium of material)
Producer organisationmore than one producer responsibility organisation: Circular Action Alliance, Interchange 360 (automotive lubricant packaging, individual programme); membership requiredproducer compliance schemes: CONAI, Comieco (paper), Corepla (plastic), Coreve (glass), Rilegno (wood), CiAl (aluminium), Ricrea (steel); membership optional
Transfer of responsibilitynot yet publishedAllowed
Revenue counted asrealised gross total revenue, USD, prior calendar yearnot yet published
Who counts as the producerother: first distributor; primary: manufacturer or brand owner, brand licensee, importer; shipping: packer and shipperprimary: manufacturer or brand owner, importer, first distributor; secondary: manufacturer or brand owner, importer, first distributor; service: manufacturer or brand owner, importer, first distributor; shipping: online marketplace seller, manufacturer or brand owner; tertiary: manufacturer or brand owner, importer, first distributor

The two programmes are organised differently. Colorado uses more than one producer responsibility organisation; Italy uses producer compliance schemes. 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 Colorado and Italy cover, side by side

Each row below is one published feature of the two programmes; a cell reads “not yet published” when Colorado or Italy has no verified entry for it in the dataset.

Scope, producer duties, categories, labelling and targets, Colorado and Italy
AspectColoradoItaly
Materials coveredpackaging material, paper products, food servicewarepaper and cardboard, plastic, glass, wood, steel, aluminium
Product classes coveredpackaging, paper, food servicewareprimary, secondary and tertiary packaging placed on the Italian market, in proportion to quantity
Excluded from scopepackaging used solely in transportation to nonconsumers, packaging used solely in business to business salesnot yet published
Sales channels addressedphysical retail, internet transactiondomestic producers and users, importers
Producer duty: primary packagingmanufacturer_brand_owner; licensee; importermanufacturer_brand_owner; importer; first_distributor
Producer duty: shipping packagingpacker_shipperonline_marketplace_seller; manufacturer_brand_owner
Producer duty: other packagingfirst_distributornot yet published
Reporting categories61, covered material type by material class6, material, with paper and plastic sub-bands
Exemption 1Exempt 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 packagingnot yet publishedmanufacturer_brand_owner; importer; first_distributor
Producer duty: tertiary packagingnot yet publishedmanufacturer_brand_owner; importer; first_distributor
Producer duty: service packagingnot yet publishedmanufacturer_brand_owner; importer; first_distributor
Labellingnot yet publishedRequired: UNI technical standards for labelling; MASE technical guidelines: All packaging must be labelled per UNI standards to aid collection, reuse and recycling and inform consumers on final destinations.
Published targetsnot yet publishedrecycling rate, all packaging waste 65% by 2025-12-31; recycling rate, all packaging waste 70% by 2030-12-31

Thresholds and exemptions in Colorado and Italy

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

Verified thresholds in Colorado and Italy
PlaceMeasureAmountEffectBasis as published
Coloradorevenue$5,000,000exempt belowrealized gross total revenue, prior calendar year, excluding on-premises alcohol sales
Coloradopackaging tonnage1 short tonexempt belowcovered materials used for products sold or distributed in or into Colorado, prior calendar year
Coloradopackaging tonnage10 short tonsflat-fee bandcovered materials supplied into Colorado
Italypackaging weight10 tonnes per calendar yearreduced dutypackaging made available for the first time in the Member State

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

One material class has a published rate on both sides; each row shows the cheapest rate that fits the class.

Cheapest published rate per kilogram by material class, Colorado and Italy
Material classColorado (USD per kg)Italy (EUR per kg)Italy in USD, approx.Higher fee
paper and board9.0 cents per pound65.00 EUR/tonnenot yet publishedNot comparable

Scaling the cheapest published rate by weight shows what the gap between Colorado and Italy amounts to for a given tonnage of one material. The amounts are the rate times the weight, nothing added.

Fee at the cheapest published rate for 1 to 100,000 kilograms, Colorado and Italy
Material classKilogramsColorado fee (USD)Italy fee (EUR)Italy in USD, approx.Italy minus Colorado (USD)
paper and board1$0.20€0.07not yet publishednot yet published
paper and board10$1.98€0.65not yet publishednot yet published
paper and board100$19.84€6.50not yet publishednot yet published
paper and board1,000$198.42€65.00not yet publishednot yet published
paper and board10,000$1,984.16€650.00not yet publishednot yet published
paper and board100,000$19,841.60€6,500.00not yet publishednot yet published

The two schedules are in different currencies (USD and EUR) and the dataset holds no published exchange rate between them, so this page does not rank the fees. Compare them in your own currency before you decide.

Italy: the 2026 fee schedule of CONAI (Comieco and other consortia), effective July 1, 2025, is the source of the per-kilogram rates used on this page.

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.

Italy 2026: the category “Paper, monomaterial (band 1)” is published at 65.00 EUR/tonne.

Real packs usually land in a dearer category, so use the calculator for Colorado and Italy.

Deadlines in Colorado and Italy

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

Verified deadlines in Colorado and Italy
PlaceKindDateCovers
ColoradopaymentJanuary 1, 2026program year 2026
ColoradootherJanuary 1, 2026not yet published
ItalyreportJune 1the previous calendar year
ItalyotherAugust 12, 2026not yet published

Penalties in Colorado and Italy

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.

Italy penalty for producer that does not organise a system, join a consortium or adopt a return system: €15,500 to €46,500 per administrative fine.

Italy penalty for placing packaging on the market without the Art. 219(5) labelling: €5,000 to €25,000 per administrative fine.

Report formats in Colorado and Italy

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

Report file layouts for Colorado and Italy
AspectColoradoItaly
LayoutColorado producer supply report by material category 2026-09-29 (built from CAA Colorado 2026 dues schedule)Italy packaging declaration (working layout) Working layout, sources reviewed 2026-11-04
RecipientCircular Action Alliance (Colorado PRO)CONAI (Consorzio Nazionale Imballaggi)
How it is submittedCAA producer portal. The customer signs in and submits.CONAI 'Dichiarazioni on line' service (dichiarazioni.conai.org). The customer signs in and submits.
File typecsvcsv
Encodingutf-8utf-8
Delimiter,,
Decimal separator.
Columns44
Required columns4 of 44 of 4
Weight unitlbkg
Period basiscalendar yearcalendar 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.

Questions about comparing these two programmes

Is Colorado or Italy stricter on packaging EPR?

Both require producers to register.

Do I register in both Colorado and Italy?

Colorado requires producers to register. Italy requires producers to register.

How do the fees per kilogram compare in Colorado and Italy?

The two schedules share material classes but the dataset holds no published exchange rate between USD and EUR, so the fees are shown in each currency without a ranking.

Which deadline comes first, Colorado or Italy?

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

Our reviewers.

Sources

  1. 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.
  2. 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
  3. 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
  4. 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
  5. 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
  6. 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
  7. normattiva.it: N2Ls (2006) (uri res) retrieved
    Original wording: I produttori e gli utilizzatori sono responsabili della corretta ed efficace gestione ambientale degli imballaggi e dei rifiuti di imballaggio
    Original wording: I produttori e gli utilizzatori sono responsabili della corretta ed efficace gestione ambientale degli imballaggi
    Original wording: aderire ad uno dei consorzi di cui all'articolo 223;
    Original wording: in proporzione alla quantità di imballaggi immessi sul mercato nazionale
  8. normattiva.it: N2Ls (2006) (uri res) retrieved
    Original wording: partecipano in forma paritaria al Consorzio nazionale imballaggi, in seguito denominato CONAI
  9. normattiva.it: N2Ls (2006) (uri res) retrieved
    Original wording: costituiscono un Consorzio per ciascun materiale di imballaggio
  10. eur-lex.europa.eu: oj retrieved
    Original wording: makes available for the first time on the territory of another Member State, directly to end users
    Original wording: a quantity of packaging, including packaging of packaged products, of less than 10 tonnes during one calendar year
    Original wording: of Annex IX to the competent authority responsible for the register, by 1 June for each full preceding calendar year.
    Original wording: It shall apply from 12 August 2026.
    Original wording: by 31 December 2030, a minimum of 70 % by weight of all packaging waste generated
  11. normattiva.it: N2Ls (2006) (uri res) retrieved
    Original wording: sono puniti con la sanzione amministrativa pecuniaria da quindicimilacinquecento euro a quarantaseimilacinquecento euro
  12. comieco.org retrieved
    Original wording: i consorzi Rilegno , Corepla e Coreve hanno aggiornato le stime
    Original wording: Tutte le variazioni decorreranno dal 1° luglio 2025 , con un secondo aumento previsto per il contributo ambientale vetro
    Original wording: Fascia 1 - Monomateriale Base 65,00 65,00
  13. normattiva.it: N2Ls (2006) (uri res) retrieved
    Original wording: Tutti gli imballaggi devono essere opportunamente etichettati secondo le modalità stabilite dalle norme tecniche UNI applicabili
  14. 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
Model both: Colorado and ItalyCompare another pair

The free plan is enough to start. We estimate and prepare; you sign and submit.