Colorado vs Manitoba EPR: Rules Compared
Last verified
Colorado and Manitoba both run packaging EPR, but the rules differ. Manitoba exempts only producers below the lower revenue floor, CA$750,000 against $5,000,000 in Colorado. Both require producers to register. Colorado publishes the higher per-kilogram fee in 3 of 4 shared material classes.
Colorado and Manitoba side by side
4 of 9 rows have a verified figure on each side of Colorado and Manitoba; 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 | Manitoba | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | more than one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | $5,000,000 | CA$750,000 | Manitoba |
| Lowest weight exemption | 907.2 kg | none recorded; see thresholds | Not comparable |
| First annual report date | not yet published | May 31 | Not comparable |
| Published penalties | 3 published | not yet published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 9.0 cents per pound | 18.23 cents per kilogram | Colorado |
| Plastic fee, cheapest matched rate | 62.0 cents per pound | 79.03 cents per kilogram | Colorado |
The lowest revenue exemption is $5,000,000 in Colorado and CA$750,000 in Manitoba ($536,557 at the Bank of Canada 2025 annual average rate). Manitoba therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Colorado but still in scope in Manitoba.
Both programmes require a producer to register, in Colorado and in Manitoba.
Across 4 shared material classes, Colorado publishes the higher cheapest per-kilogram fee in 3, and Manitoba in 1. A higher fee is not the same as a stricter rule; it is simply a larger published number per kilogram.
Who runs the programme in Colorado and Manitoba
Who collects and who the producer files with, in Colorado and then Manitoba.
| Aspect | Colorado | Manitoba |
|---|---|---|
| Regime | Colorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355) | Packaging and Printed Paper Stewardship Regulation, M.R. 195/2008 |
| Regulator | Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program | not yet published |
| Producers obligated | Yes | Yes |
| Registration | Required, Circular Action Alliance producer portal | Required, WeRecycle Portal |
| Producer organisation | more than one producer responsibility organisation: Circular Action Alliance, Interchange 360 (automotive lubricant packaging, individual programme); membership required | one producer responsibility organisation: Recycle Manitoba (MMSM); membership required |
| Revenue counted as | realised gross total revenue, USD, prior calendar year | gross revenue inside the jurisdiction, CAD, given year |
| Who counts as the producer | other: first distributor; primary: manufacturer or brand owner, brand licensee, importer; shipping: packer and shipper | other: brand owner, importer; primary: brand owner, importer; secondary: brand owner, importer; service: brand owner, importer; shipping: brand owner, importer; tertiary: brand owner, importer |
The two programmes are organised differently. Colorado uses more than one producer responsibility organisation; Manitoba uses one producer responsibility organisation. For a seller in both, that usually means two different counterparties, two different sign-up routes and two different sets of terms to read before the first report is due.
What Colorado and Manitoba cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Colorado or Manitoba has no verified entry for it in the dataset.
| Aspect | Colorado | Manitoba |
|---|---|---|
| Materials covered | packaging material, paper products, food serviceware | not yet published |
| Product classes covered | packaging, paper, food serviceware | not yet published |
| 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 | not yet published |
| Producer duty: primary packaging | manufacturer_brand_owner; licensee; importer | brand_owner; importer |
| Producer duty: shipping packaging | packer_shipper | brand_owner; importer |
| Producer duty: other packaging | first_distributor | brand_owner; importer |
| Reporting categories | 61, covered material type by material class | 23, material category |
| 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. | Under CAD 750,000 gross Manitoba revenue, including affiliates and franchisees |
| Producer duty: secondary packaging | not yet published | brand_owner; importer |
| Producer duty: tertiary packaging | not yet published | brand_owner; importer |
| Producer duty: service packaging | not yet published | brand_owner; importer |
Thresholds and exemptions in Colorado and Manitoba
Every verified threshold Colorado and Manitoba 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 |
| Manitoba | revenue | CA$750,000 | exempt below | gross Manitoba revenue including affiliates and franchisees |
| Manitoba | packaging weight | 5,000 kg | flat-fee band | A steward supplying under 5,000 kg a year may pay a flat fee instead of material fees, in two bands: 1,000 to 2,499 kg and 2,500 to 5,000 kg. The amounts are published each year and are on that year's fee 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.
Manitoba exemption: Under CAD 750,000 gross Manitoba revenue, including affiliates and franchisees It does not have to be applied for.
Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.
The lowest revenue exemption is $5,000,000 in Colorado and CA$750,000 in Manitoba ($536,557 at the Bank of Canada 2025 annual average rate). Manitoba therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Colorado but still in scope in Manitoba.
Fees per kilogram for shared materials
4 material classes have a published rate on both sides; each row shows the cheapest rate that fits the class.
| Material class | Colorado (USD per kg) | Manitoba (CAD per kg) | Manitoba in USD, approx. | Higher fee |
|---|---|---|---|---|
| paper and board | 9.0 cents per pound | 18.23 cents per kilogram | $0.1304 | Colorado |
| plastic | 62.0 cents per pound | 79.03 cents per kilogram | $0.5654 | Colorado |
| glass | 5.0 cents per pound | 22.41 cents per kilogram | $0.1603 | Manitoba |
| steel | 11.0 cents per pound | 30.96 cents per kilogram | $0.2215 | Colorado |
Scaling the cheapest published rate by weight shows what the gap between Colorado and Manitoba 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) | Manitoba fee (CAD) | Manitoba in USD, approx. | Manitoba minus Colorado (USD) |
|---|---|---|---|---|---|
| paper and board | 1 | $0.20 | CA$0.18 | $0.13 | -$0.07 |
| paper and board | 10 | $1.98 | CA$1.82 | $1.30 | -$0.68 |
| paper and board | 100 | $19.84 | CA$18.23 | $13.04 | -$6.80 |
| paper and board | 1,000 | $198.42 | CA$182.30 | $130.42 | -$68.00 |
| paper and board | 10,000 | $1,984.16 | CA$1,823.00 | $1,304.19 | -$679.97 |
| paper and board | 100,000 | $19,841.60 | CA$18,230.00 | $13,041.92 | -$6,799.68 |
| plastic | 1 | $1.37 | CA$0.79 | $0.57 | -$0.80 |
| plastic | 10 | $13.67 | CA$7.90 | $5.65 | -$8.01 |
| plastic | 100 | $136.69 | CA$79.03 | $56.54 | -$80.15 |
| plastic | 1,000 | $1,366.87 | CA$790.30 | $565.39 | -$801.48 |
| plastic | 10,000 | $13,668.66 | CA$7,903.00 | $5,653.88 | -$8,014.78 |
| plastic | 100,000 | $136,686.60 | CA$79,030.00 | $56,538.85 | -$80,147.76 |
| glass | 1 | $0.11 | CA$0.22 | $0.16 | +$0.05 |
| glass | 10 | $1.10 | CA$2.24 | $1.60 | +$0.50 |
| glass | 100 | $11.02 | CA$22.41 | $16.03 | +$5.01 |
| glass | 1,000 | $110.23 | CA$224.10 | $160.32 | +$50.09 |
| glass | 10,000 | $1,102.31 | CA$2,241.00 | $1,603.23 | +$500.92 |
| glass | 100,000 | $11,023.11 | CA$22,410.00 | $16,032.34 | +$5,009.22 |
| steel | 1 | $0.24 | CA$0.31 | $0.22 | -$0.02 |
| steel | 10 | $2.43 | CA$3.10 | $2.21 | -$0.21 |
| steel | 100 | $24.25 | CA$30.96 | $22.15 | -$2.10 |
| steel | 1,000 | $242.51 | CA$309.60 | $221.49 | -$21.02 |
| steel | 10,000 | $2,425.08 | CA$3,096.00 | $2,214.91 | -$210.18 |
| steel | 100,000 | $24,250.85 | CA$30,960.00 | $22,149.09 | -$2,101.76 |
Converted from CAD to USD at the Bank of Canada annual average for 2025. A converted figure is approximate and moves with the year of the rate; the published amount is the one in the programme’s own currency.
Manitoba: the 2027 fee schedule of Recycle Manitoba, effective January 1, 2027, 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.
Colorado 2027: the category “HDPE (#2)/LDPE (#4) Flexible and Film Items” is published at 62.0 cents per pound.
Colorado 2027: the category “Glass Bottles and Jars & Other Containers” is published at 5.0 cents per pound.
Colorado 2027: the category “Steel Containers” is published at 11.0 cents per pound.
Manitoba 2027: the category “Boxboard” is published at 18.23 cents per kilogram.
Manitoba 2027: the category “Plastic Film” is published at 79.03 cents per kilogram.
Manitoba 2027: the category “Coloured Glass” is published at 22.41 cents per kilogram.
Manitoba 2027: the category “Steel Food & Beverage Cans” is published at 30.96 cents per kilogram.
Real packs usually land in a dearer category, so use the calculator for Colorado and Manitoba.
Deadlines in Colorado and Manitoba
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 |
| Manitoba | report | May 31 | the previous calendar year |
| Manitoba | payment | January 31 | each quarter |
| Manitoba | registration | December 1 | voluntary producer agreement |
Penalties in Colorado and Manitoba
What each side has published; a side without an amount says so.
Colorado penalty for First violation of Part 7 by a producer or producer responsibility organization: up to $5,000 for the first day, then up to $1,500 per day the violation continues.
Colorado penalty for Second violation within twelve months after a prior violation: up to $10,000 for the first day, then up to $3,000 per day the violation continues.
Colorado penalty for Third or later violation within twelve months after two or more prior violations: up to $20,000 for the first day, then up to $6,000 per day the violation continues.
Report formats in Colorado and Manitoba
How the report file for Colorado compares with the one for Manitoba.
| Aspect | Colorado | Manitoba |
|---|---|---|
| Layout | Colorado producer supply report by material category 2026-09-29 (built from CAA Colorado 2026 dues schedule) | Recycle Manitoba annual report Fee-year categories, reviewed 2026-09-29 |
| Recipient | Circular Action Alliance (Colorado PRO) | Recycle Manitoba (MMSM) |
| How it is submitted | CAA producer portal. The customer signs in and submits. | WeRecycle Portal |
| 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.
Which to plan for first, Colorado or Manitoba
Check the exemption thresholds before anything else. Manitoba reaches smaller sellers than Colorado, so a seller that is exempt in Colorado may still have to register in Manitoba.
Questions about comparing these two programmes
Is Colorado or Manitoba stricter on packaging EPR?
Manitoba exempts only producers below the lower revenue floor, CA$750,000 against $5,000,000 in Colorado. Both require producers to register. Colorado publishes the higher per-kilogram fee in 3 of 4 shared material classes.
Do I register in both Colorado and Manitoba?
Colorado requires producers to register. Manitoba requires producers to register.
How do the fees per kilogram compare in Colorado and Manitoba?
Across 4 shared material classes, Colorado publishes the higher cheapest per-kilogram fee in 3, and Manitoba in 1. A higher fee is not the same as a stricter rule; it is simply a larger published number per kilogram.
Which deadline comes first, Colorado or Manitoba?
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
- recyclemanitoba.ca: 195.08 retrieved
Original wording: Packaging and Printed Paper Stewardship Regulation
- recyclemanitoba.ca: for producers retrieved
Original wording: had gross revenues of more than $750,000 from the combined sale of all its products and services in Manitoba
Original wording: Does your company have a gross Manitoba revenue greater than $750,000 in a given year?
Original wording: Is your company a Brand Owner, First Importer or Franchisor?
Original wording: A Producer is “obligated” if it and/or its Affiliates and Franchisees had gross revenues of more than $750,000
Original wording: Registered producers file an annual report of the packaging and printed paper they supplied into Manitoba during the previous calendar year.
Original wording: Quarterly payment dates Q1 January 31 Q2 April 30 Q3 July 31 Q4 October 31
Original wording: Submit by December 1 Cancel by December 1 Voluntary Producer Agreement
- recyclemanitoba.ca: epr transition retrieved
Original wording: Communities run or contract collection services and are funded for up to 80% of eligible net costs.
- recyclemanitoba.ca: Circular Materials Report to Producers 2025 retrieved
Original wording: eligible stewards (supplying less than 5,000 kg annually), can continue filing their detailed reports and paying material fee rates
- recyclemanitoba.ca: 2026CauseOfChange FeeSchedule MMSM retrieved
Original wording: 2026 Cause of Change Fee Schedule
- Bank of Canada, FXAUSDCAD (annual average 2025) retrieved
- circularactionalliance.org: CO 2027DuesSchedule 100126 retrieved
Original wording: 2027 Colorado Producer Dues Schedule Dues for Program Year 2027
Original wording: Kraft Paper MRL $0.09 $0.00 $0.00 $0.00 $0.09
Original wording: HDPE (#2)/LDPE (#4) Flexible and Film Items AML $0.62 $0.00 $0.00 $0.00 $0.62
Original wording: Glass Bottles and Jars & Other Containers MRL $0.05 $0.00 $0.00 $0.00 $0.05
Original wording: Steel Containers MRL $0.12 $0.00 $0.00 -$0.01 $0.11
- recyclemanitoba.ca: 2027CauseOfChange FeeSchedule RecycleManitoba retrieved
Original wording: RECYCLE MANITOBA FEE SCHEDULE (CENTS/KG)
Original wording: PAPER Boxboard 18.23 15.65 16.5%
Original wording: Plastic Film 79.03 73.04 8.2%
Original wording: Coloured Glass 22.41 21.66 3.5%
Original wording: Steel Food & Beverage Cans 30.96 27.88 11.0%
The free plan is enough to start. We estimate and prepare; you sign and submit.