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.
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.
| Measure | Colorado | Italy | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | more than one producer responsibility organisation | producer compliance schemes | 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 | June 1 | Not comparable |
| Published penalties | 3 published | 2 published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 9.0 cents per pound | 65.00 EUR/tonne | 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 Italy.
Who runs the programme in Colorado and Italy
Who collects and who the producer files with, in Colorado and then Italy.
| Aspect | Colorado | Italy |
|---|---|---|
| Regime | Colorado 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 |
| Regulator | Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program | Ministry of Environment and Energy Security (MASE); CONAI coordinates the consortium system |
| Producers obligated | Yes | Yes |
| Registration | Required, Circular Action Alliance producer portal | Required, CONAI membership (declaration and contribution to CONAI, then consortium of material) |
| Producer organisation | more than one producer responsibility organisation: Circular Action Alliance, Interchange 360 (automotive lubricant packaging, individual programme); membership required | producer compliance schemes: CONAI, Comieco (paper), Corepla (plastic), Coreve (glass), Rilegno (wood), CiAl (aluminium), Ricrea (steel); 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 | primary: 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.
| Aspect | Colorado | Italy |
|---|---|---|
| Materials covered | packaging material, paper products, food serviceware | paper and cardboard, plastic, glass, wood, steel, aluminium |
| Product classes covered | packaging, paper, food serviceware | primary, secondary and tertiary packaging placed on the Italian market, in proportion to quantity |
| 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 | domestic producers and users, importers |
| Producer duty: primary packaging | manufacturer_brand_owner; licensee; importer | manufacturer_brand_owner; importer; first_distributor |
| Producer duty: shipping packaging | packer_shipper | online_marketplace_seller; manufacturer_brand_owner |
| Producer duty: other packaging | first_distributor | not yet published |
| Reporting categories | 61, covered material type by material class | 6, material, with paper and plastic sub-bands |
| 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 |
| Producer duty: tertiary packaging | not yet published | manufacturer_brand_owner; importer; first_distributor |
| Producer duty: service packaging | not yet published | manufacturer_brand_owner; importer; first_distributor |
| Labelling | not yet published | Required: 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 targets | not yet published | recycling 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.
| 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 |
| Italy | packaging weight | 10 tonnes per calendar year | reduced duty | packaging 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.
| Material class | Colorado (USD per kg) | Italy (EUR per kg) | Italy in USD, approx. | Higher fee |
|---|---|---|---|---|
| paper and board | 9.0 cents per pound | 65.00 EUR/tonne | not yet published | Not 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.
| Material class | Kilograms | Colorado fee (USD) | Italy fee (EUR) | Italy in USD, approx. | Italy minus Colorado (USD) |
|---|---|---|---|---|---|
| paper and board | 1 | $0.20 | €0.07 | not yet published | not yet published |
| paper and board | 10 | $1.98 | €0.65 | not yet published | not yet published |
| paper and board | 100 | $19.84 | €6.50 | not yet published | not yet published |
| paper and board | 1,000 | $198.42 | €65.00 | not yet published | not yet published |
| paper and board | 10,000 | $1,984.16 | €650.00 | not yet published | not yet published |
| paper and board | 100,000 | $19,841.60 | €6,500.00 | not yet published | not 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.
| Place | Kind | Date | Covers |
|---|---|---|---|
| Colorado | payment | January 1, 2026 | program year 2026 |
| Colorado | other | January 1, 2026 | not yet published |
| Italy | report | June 1 | the previous calendar year |
| Italy | other | August 12, 2026 | not 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.
| Aspect | Colorado | Italy |
|---|---|---|
| Layout | Colorado 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 |
| Recipient | Circular Action Alliance (Colorado PRO) | CONAI (Consorzio Nazionale Imballaggi) |
| How it is submitted | CAA producer portal. The customer signs in and submits. | CONAI 'Dichiarazioni on line' service (dichiarazioni.conai.org). The customer signs in and submits. |
| File type | csv | csv |
| Encoding | utf-8 | utf-8 |
| Delimiter | , | , |
| Decimal separator | . | |
| Columns | 4 | 4 |
| Required columns | 4 of 4 | 4 of 4 |
| Weight unit | lb | kg |
| Period basis | calendar year | calendar year |
The two layouts share a file type and a delimiter, but each programme names its own columns and categories, so one file cannot be sent to both programmes. Each report is built from the same underlying measurements and exported separately.
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
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
- 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
- normattiva.it: N2Ls (2006) (uri res) retrieved
Original wording: partecipano in forma paritaria al Consorzio nazionale imballaggi, in seguito denominato CONAI
- normattiva.it: N2Ls (2006) (uri res) retrieved
Original wording: costituiscono un Consorzio per ciascun materiale di imballaggio
- 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
- normattiva.it: N2Ls (2006) (uri res) retrieved
Original wording: sono puniti con la sanzione amministrativa pecuniaria da quindicimilacinquecento euro a quarantaseimilacinquecento euro
- 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
- 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
- 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
The free plan is enough to start. We estimate and prepare; you sign and submit.