# Colorado vs Manitoba EPR: Rules Compared

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

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

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.

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

## 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.

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

| 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 |

<a id="calc-revenue"></a>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.

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

<a id="calc-rates"></a>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.

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

## Who runs the programme in Colorado and Manitoba

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

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

| 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 |

> **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 Manitoba: the regulator. Reason: Regulator naming from program pages.

> **Not yet published**: Not yet published for Manitoba: the rules on transferring responsibility. Reason: Transfer rules not read.

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.

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

## 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.

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

| 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 |

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

## Thresholds and exemptions in Colorado and Manitoba

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

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

| 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. |

<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.

<a id="b-exemption-below-revenue"></a>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.

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

## 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.

<a id="rates-table"></a>**Cheapest published rate per kilogram by material class, Colorado and Manitoba**

| 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.

<a id="rates-scale"></a>**Fee at the cheapest published rate for 1 to 100,000 kilograms, Colorado and Manitoba**

| 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.

<a id="b-fee-source"></a>Manitoba: the 2027 fee schedule of Recycle Manitoba, effective January 1, 2027, is the source of the per-kilogram rates used on this page.

<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="a-rate-co-steel-containers"></a>Colorado 2027: the category “Steel Containers” is published at 11.0 cents per pound.

<a id="b-rate-mb-boxboard"></a>Manitoba 2027: the category “Boxboard” is published at 18.23 cents per kilogram.

<a id="b-rate-mb-plastic-film"></a>Manitoba 2027: the category “Plastic Film” is published at 79.03 cents per kilogram.

<a id="b-rate-mb-coloured-glass"></a>Manitoba 2027: the category “Coloured Glass” is published at 22.41 cents per kilogram.

<a id="b-rate-mb-steel-food-beverage-cans"></a>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.

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

## Deadlines in Colorado and Manitoba

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

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

| 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 |

> **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 Manitoba

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 Manitoba: penalty amounts. Reason: Penalties were not read.

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

## Report formats in Colorado and Manitoba

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

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

> **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.

> **Not yet published**: Manitoba: the programme’s own report specification is not yet published. The layout above is Instica’s working layout.

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.

<a id="choose"></a>

## 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.

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

## Questions about comparing these two programmes

### <a id="q1"></a>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.

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

Colorado requires producers to register. Manitoba requires producers to register.

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

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

<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>Manitoba: the packaging rules sit in Packaging and Printed Paper Stewardship Regulation, M.R. 195/2008. [#b-regime](#b-regime)
  Value: Packaging and Printed Paper Stewardship Regulation, M.R. 195/2008 · Source: https://recyclemanitoba.ca/wp-content/uploads/2026/08/195.08.pdf · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: Packaging and Printed Paper Stewardship Regulation
- <a id="b-obligated"></a>Manitoba places an obligation on packaging producers. [#b-obligated](#b-obligated)
  Value: yes · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: had gross revenues of more than $750,000 from the combined sale of all its products and services in Manitoba
- <a id="b-registration"></a>Manitoba: producers must register through WeRecycle Portal. [#b-registration](#b-registration)
  Value: yes · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Does your company have a gross Manitoba revenue greater than $750,000 in a given year?
- <a id="b-organisation"></a>Manitoba organises producer responsibility through a single producer responsibility organisation: Recycle Manitoba (MMSM); membership is required. [#b-organisation](#b-organisation)
  Value: one producer responsibility organisation · Source: https://recyclemanitoba.ca/for-producers/epr-transition/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Communities run or contract collection services and are funded for up to 80% of eligible net costs.
- <a id="b-revenue-scope"></a>Manitoba measures revenue as gross revenue inside the jurisdiction in CAD, over the given year. [#b-revenue-scope](#b-revenue-scope)
  Value: in_jurisdiction · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Does your company have a gross Manitoba revenue greater than $750,000 in a given year?
- <a id="b-hierarchy-other"></a>Manitoba: at the other packaging level the producer hierarchy names the brand owner and importer. [#b-hierarchy-other](#b-hierarchy-other)
  Value: brand_owner > importer · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: Is your company a Brand Owner, First Importer or Franchisor?
- <a id="b-hierarchy-primary"></a>Manitoba: at the primary packaging level the producer hierarchy names the brand owner and importer. [#b-hierarchy-primary](#b-hierarchy-primary)
  Value: brand_owner > importer · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: Is your company a Brand Owner, First Importer or Franchisor?
- <a id="b-hierarchy-secondary"></a>Manitoba: at the secondary packaging level the producer hierarchy names the brand owner and importer. [#b-hierarchy-secondary](#b-hierarchy-secondary)
  Value: brand_owner > importer · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: Is your company a Brand Owner, First Importer or Franchisor?
- <a id="b-hierarchy-service"></a>Manitoba: at the service packaging level the producer hierarchy names the brand owner and importer. [#b-hierarchy-service](#b-hierarchy-service)
  Value: brand_owner > importer · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: Is your company a Brand Owner, First Importer or Franchisor?
- <a id="b-hierarchy-shipping"></a>Manitoba: at the shipping packaging level the producer hierarchy names the brand owner and importer. [#b-hierarchy-shipping](#b-hierarchy-shipping)
  Value: brand_owner > importer · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: Is your company a Brand Owner, First Importer or Franchisor?
- <a id="b-hierarchy-tertiary"></a>Manitoba: at the tertiary packaging level the producer hierarchy names the brand owner and importer. [#b-hierarchy-tertiary](#b-hierarchy-tertiary)
  Value: brand_owner > importer · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: Is your company a Brand Owner, First Importer or Franchisor?
- <a id="b-threshold-obligation-revenue"></a>Manitoba threshold on revenue: CA$750,000; effect: exempt below the threshold. [#b-threshold-obligation-revenue](#b-threshold-obligation-revenue)
  Value: CA$750,000 · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: had gross revenues of more than $750,000 from the combined sale of all its products and services in Manitoba
- <a id="b-threshold-flat-fee-band"></a>Manitoba threshold on packaging weight: 5,000 kg; effect: flat fee band. [#b-threshold-flat-fee-band](#b-threshold-flat-fee-band)
  Value: 5,000 kg · Source: https://recyclemanitoba.ca/wp-content/uploads/2026/08/Circular_Materials-Report_to_Producers-2025.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: eligible stewards (supplying less than 5,000 kg annually), can continue filing their detailed reports and paying material fee rates
- Manitoba exemption: Under CAD 750,000 gross Manitoba revenue, including affiliates and franchisees It does not have to be applied for. [#b-exemption-below-revenue](#b-exemption-below-revenue)
  Value: below_revenue · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: A Producer is “obligated” if it and/or its Affiliates and Franchisees had gross revenues of more than $750,000
- <a id="b-deadline-annual-report"></a>Manitoba: report date May 31, covering the previous calendar year. [#b-deadline-annual-report](#b-deadline-annual-report)
  Value: May 31 · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Registered producers file an annual report of the packaging and printed paper they supplied into Manitoba during the previous calendar year.
- <a id="b-deadline-quarterly-payments"></a>Manitoba: payment date January 31, covering each quarter. [#b-deadline-quarterly-payments](#b-deadline-quarterly-payments)
  Value: January 31 · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: Quarterly payment dates Q1 January 31 Q2 April 30 Q3 July 31 Q4 October 31
- <a id="b-deadline-voluntary-agreement"></a>Manitoba: registration date December 1, covering voluntary producer agreement. [#b-deadline-voluntary-agreement](#b-deadline-voluntary-agreement)
  Value: December 1 · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 3, 2026 · Status: verified
  Verbatim quote: Submit by December 1 Cancel by December 1 Voluntary Producer Agreement
- <a id="b-scope-ph-primary"></a>Manitoba: producer duty: primary packaging is brand_owner; importer. [#b-scope-ph-primary](#b-scope-ph-primary)
  Value: brand owner and importer · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: Is your company a Brand Owner, First Importer or Franchisor?
- <a id="b-scope-ph-secondary"></a>Manitoba: producer duty: secondary packaging is brand_owner; importer. [#b-scope-ph-secondary](#b-scope-ph-secondary)
  Value: brand owner and importer · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: Is your company a Brand Owner, First Importer or Franchisor?
- <a id="b-scope-ph-tertiary"></a>Manitoba: producer duty: tertiary packaging is brand_owner; importer. [#b-scope-ph-tertiary](#b-scope-ph-tertiary)
  Value: brand owner and importer · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: Is your company a Brand Owner, First Importer or Franchisor?
- <a id="b-scope-ph-shipping"></a>Manitoba: producer duty: shipping packaging is brand_owner; importer. [#b-scope-ph-shipping](#b-scope-ph-shipping)
  Value: brand owner and importer · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: Is your company a Brand Owner, First Importer or Franchisor?
- <a id="b-scope-ph-service"></a>Manitoba: producer duty: service packaging is brand_owner; importer. [#b-scope-ph-service](#b-scope-ph-service)
  Value: brand owner and importer · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: Is your company a Brand Owner, First Importer or Franchisor?
- <a id="b-scope-ph-other"></a>Manitoba: producer duty: other packaging is brand_owner; importer. [#b-scope-ph-other](#b-scope-ph-other)
  Value: brand owner and importer · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: November 4, 2026 · Status: verified
  Verbatim quote: Is your company a Brand Owner, First Importer or Franchisor?
- <a id="b-scope-categories"></a>Manitoba: reporting categories is 23, material category. [#b-scope-categories](#b-scope-categories)
  Value: 23 · Source: https://recyclemanitoba.ca/wp-content/uploads/2026/08/2026CauseOfChange_FeeSchedule-MMSM.pdf · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: 2026 Cause of Change Fee Schedule
- <a id="b-scope-ex1"></a>Manitoba: exemption 1 is Under CAD 750,000 gross Manitoba revenue, including affiliates and franchisees. [#b-scope-ex1](#b-scope-ex1)
  Value: Under CAD 750,000 gross Manitoba revenue, including affiliates and franchisees · Source: https://recyclemanitoba.ca/for-producers/ · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: A Producer is “obligated” if it and/or its Affiliates and Franchisees had gross revenues of more than $750,000
- 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. [#calc-revenue](#calc-revenue)
  Value: CA-MB · 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
- Both programmes require a producer to register, in Colorado and in Manitoba. [#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
- Colorado 2027: the category “Steel Containers” is published at 11.0 cents per pound. [#a-rate-co-steel-containers](#a-rate-co-steel-containers)
  Value: 11.0 cents_per_lb · Source: https://circularactionalliance.org/s/CO-2027DuesSchedule_100126.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: Steel Containers MRL $0.12 $0.00 $0.00 -$0.01 $0.11
- Manitoba: the 2027 fee schedule of Recycle Manitoba, effective January 1, 2027, is the source of the per-kilogram rates used on this page. [#b-fee-source](#b-fee-source)
  Value: Recycle Manitoba 2027 fee schedule · Source: https://recyclemanitoba.ca/wp-content/uploads/2026/10/2027CauseOfChange_FeeSchedule-RecycleManitoba.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: RECYCLE MANITOBA FEE SCHEDULE (CENTS/KG)
- Manitoba 2027: the category “Boxboard” is published at 18.23 cents per kilogram. [#b-rate-mb-boxboard](#b-rate-mb-boxboard)
  Value: 18.23 cents_per_kg · Source: https://recyclemanitoba.ca/wp-content/uploads/2026/10/2027CauseOfChange_FeeSchedule-RecycleManitoba.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: PAPER Boxboard 18.23 15.65 16.5%
- Manitoba 2027: the category “Plastic Film” is published at 79.03 cents per kilogram. [#b-rate-mb-plastic-film](#b-rate-mb-plastic-film)
  Value: 79.03 cents_per_kg · Source: https://recyclemanitoba.ca/wp-content/uploads/2026/10/2027CauseOfChange_FeeSchedule-RecycleManitoba.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: Plastic Film 79.03 73.04 8.2%
- Manitoba 2027: the category “Coloured Glass” is published at 22.41 cents per kilogram. [#b-rate-mb-coloured-glass](#b-rate-mb-coloured-glass)
  Value: 22.41 cents_per_kg · Source: https://recyclemanitoba.ca/wp-content/uploads/2026/10/2027CauseOfChange_FeeSchedule-RecycleManitoba.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: Coloured Glass 22.41 21.66 3.5%
- Manitoba 2027: the category “Steel Food & Beverage Cans” is published at 30.96 cents per kilogram. [#b-rate-mb-steel-food-beverage-cans](#b-rate-mb-steel-food-beverage-cans)
  Value: 30.96 cents_per_kg · Source: https://recyclemanitoba.ca/wp-content/uploads/2026/10/2027CauseOfChange_FeeSchedule-RecycleManitoba.pdf · Retrieved: October 22, 2026 · Status: verified
  Verbatim quote: Steel Food & Beverage Cans 30.96 27.88 11.0%
- 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. [#calc-rates](#calc-rates)
  Value: US-CO · 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

## 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

- [Manitoba extended producer responsibility](https://instica.com/epr/manitoba)

### Related pages

- [Colorado vs Minnesota EPR: Rules Compared](https://instica.com/epr/compare/colorado-vs-minnesota)
- [Colorado vs New Brunswick EPR: Rules Compared](https://instica.com/epr/compare/colorado-vs-new-brunswick)
- [Colorado vs Nova Scotia EPR: Rules Compared](https://instica.com/epr/compare/colorado-vs-nova-scotia)
- [Colorado vs Yukon EPR: Rules Compared](https://instica.com/epr/compare/colorado-vs-yukon)
- [France vs Minnesota EPR: Rules Compared](https://instica.com/epr/compare/france-vs-minnesota)
- [France vs Oregon EPR: Rules Compared](https://instica.com/epr/compare/france-vs-oregon)

## 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. recyclemanitoba.ca: 195.08 (https://recyclemanitoba.ca/wp-content/uploads/2026/08/195.08.pdf), Retrieved: November 3, 2026, Status: verified
   > Packaging and Printed Paper Stewardship Regulation
19. recyclemanitoba.ca: for producers (https://recyclemanitoba.ca/for-producers/), Retrieved: November 3, 2026, Status: verified
   > had gross revenues of more than $750,000 from the combined sale of all its products and services in Manitoba
20. recyclemanitoba.ca: for producers (https://recyclemanitoba.ca/for-producers/), Retrieved: September 29, 2026, Status: verified
   > Does your company have a gross Manitoba revenue greater than $750,000 in a given year?
21. recyclemanitoba.ca: epr transition (https://recyclemanitoba.ca/for-producers/epr-transition/), Retrieved: September 29, 2026, Status: verified
   > Communities run or contract collection services and are funded for up to 80% of eligible net costs.
22. recyclemanitoba.ca: for producers (https://recyclemanitoba.ca/for-producers/), Retrieved: November 4, 2026, Status: verified
   > Is your company a Brand Owner, First Importer or Franchisor?
23. recyclemanitoba.ca: Circular Materials Report to Producers 2025 (https://recyclemanitoba.ca/wp-content/uploads/2026/08/Circular_Materials-Report_to_Producers-2025.pdf), Retrieved: October 22, 2026, Status: verified
   > eligible stewards (supplying less than 5,000 kg annually), can continue filing their detailed reports and paying material fee rates
24. recyclemanitoba.ca: for producers (https://recyclemanitoba.ca/for-producers/), Retrieved: September 29, 2026, Status: verified
   > A Producer is “obligated” if it and/or its Affiliates and Franchisees had gross revenues of more than $750,000
25. recyclemanitoba.ca: for producers (https://recyclemanitoba.ca/for-producers/), Retrieved: September 29, 2026, Status: verified
   > Registered producers file an annual report of the packaging and printed paper they supplied into Manitoba during the previous calendar year.
26. recyclemanitoba.ca: for producers (https://recyclemanitoba.ca/for-producers/), Retrieved: November 3, 2026, Status: verified
   > Quarterly payment dates Q1 January 31 Q2 April 30 Q3 July 31 Q4 October 31
27. recyclemanitoba.ca: for producers (https://recyclemanitoba.ca/for-producers/), Retrieved: November 3, 2026, Status: verified
   > Submit by December 1 Cancel by December 1 Voluntary Producer Agreement
28. recyclemanitoba.ca: 2026CauseOfChange FeeSchedule MMSM (https://recyclemanitoba.ca/wp-content/uploads/2026/08/2026CauseOfChange_FeeSchedule-MMSM.pdf), Retrieved: September 29, 2026, Status: verified
   > 2026 Cause of Change Fee Schedule
29. Bank of Canada, FXAUSDCAD (annual average 2025) (https://www.bankofcanada.ca/valet/observations/FXAUSDCAD/json), Retrieved: October 22, 2026, Status: verified
30. 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
31. 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
32. 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
33. 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
34. circularactionalliance.org: CO 2027DuesSchedule 100126 (https://circularactionalliance.org/s/CO-2027DuesSchedule_100126.pdf), Retrieved: October 22, 2026, Status: verified
   > Steel Containers MRL $0.12 $0.00 $0.00 -$0.01 $0.11
35. recyclemanitoba.ca: 2027CauseOfChange FeeSchedule RecycleManitoba (https://recyclemanitoba.ca/wp-content/uploads/2026/10/2027CauseOfChange_FeeSchedule-RecycleManitoba.pdf), Retrieved: October 22, 2026, Status: verified
   > RECYCLE MANITOBA FEE SCHEDULE (CENTS/KG)
36. recyclemanitoba.ca: 2027CauseOfChange FeeSchedule RecycleManitoba (https://recyclemanitoba.ca/wp-content/uploads/2026/10/2027CauseOfChange_FeeSchedule-RecycleManitoba.pdf), Retrieved: October 22, 2026, Status: verified
   > PAPER Boxboard 18.23 15.65 16.5%
37. recyclemanitoba.ca: 2027CauseOfChange FeeSchedule RecycleManitoba (https://recyclemanitoba.ca/wp-content/uploads/2026/10/2027CauseOfChange_FeeSchedule-RecycleManitoba.pdf), Retrieved: October 22, 2026, Status: verified
   > Plastic Film 79.03 73.04 8.2%
38. recyclemanitoba.ca: 2027CauseOfChange FeeSchedule RecycleManitoba (https://recyclemanitoba.ca/wp-content/uploads/2026/10/2027CauseOfChange_FeeSchedule-RecycleManitoba.pdf), Retrieved: October 22, 2026, Status: verified
   > Coloured Glass 22.41 21.66 3.5%
39. recyclemanitoba.ca: 2027CauseOfChange FeeSchedule RecycleManitoba (https://recyclemanitoba.ca/wp-content/uploads/2026/10/2027CauseOfChange_FeeSchedule-RecycleManitoba.pdf), Retrieved: October 22, 2026, Status: verified
   > Steel Food & Beverage Cans 30.96 27.88 11.0%

## Cite this page

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

- Canonical URL: https://instica.com/epr/compare/colorado-vs-manitoba
- Last verified: November 5, 2026
- Last changed: November 5, 2026
- Dataset version: v1-281284b7e7c1
- Licence: Reuse is allowed under CC-BY-4.0 with credit to Instica and a link to this page.
- Machine-readable versions: https://instica.com/epr/compare/colorado-vs-manitoba.md · https://instica.com/epr/compare/colorado-vs-manitoba.json