# Colorado vs Minnesota EPR: Rules Compared

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

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

Colorado and Minnesota both run packaging EPR, but the rules differ. Minnesota exempts only producers below the lower revenue floor, $2,000,000 against $5,000,000 in Colorado. Both set the lowest weight exemption at 907.2 kg. Both require producers to register. Every figure below links to its primary source.

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

## Colorado and Minnesota side by side

3 of 9 rows have a verified figure on each side of Colorado and Minnesota; 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 Minnesota: the measures both programmes publish**

| Measure | Colorado | Minnesota | 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 | $2,000,000 | Minnesota |
| Lowest weight exemption | 907.2 kg | 907.2 kg | Same |
| First annual report date | not yet published | May 31 | Not comparable |
| Published penalties | 3 published | 1 published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 9.0 cents per pound | not yet published | Not comparable |
| Plastic fee, cheapest matched rate | 62.0 cents per pound | not yet published | Not comparable |

<a id="calc-revenue"></a>The lowest revenue exemption is $5,000,000 in Colorado and $2,000,000 in Minnesota. Minnesota therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Colorado but still in scope in Minnesota.

<a id="calc-mass"></a>The lowest weight exemption is the same on both sides: 907.2 kg of packaging.

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

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

## Who runs the programme in Colorado and Minnesota

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

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

| Aspect | Colorado | Minnesota |
| --- | --- | --- |
| Regime | Colorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355) | Minnesota packaging EPR law, Minnesota Statutes sections 115A.144 to 115A.1463 |
| Regulator | Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program | Minnesota Pollution Control Agency |
| Producers obligated | Yes | Yes |
| Registration | Required, Circular Action Alliance producer portal | Required, Producer joins a PRO; the PRO registers with the MPCA |
| Producer organisation | more than one producer responsibility organisation: Circular Action Alliance, Interchange 360 (automotive lubricant packaging, individual programme); membership required | one producer responsibility organisation: Circular Action Alliance; membership required |
| 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, brand licensee, 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 Minnesota: the rules on transferring responsibility. Reason: No transfer or delegation rule was found in the definition read.

> **Not yet published**: Not yet published for Minnesota: how revenue is counted. Reason: Revenue scope for the producer threshold was not read beyond the de minimis definition.

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

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

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

| Aspect | Colorado | Minnesota |
| --- | --- | --- |
| Materials covered | packaging material, paper products, food serviceware | packaging, paper products |
| Product classes covered | packaging, paper, food serviceware | packaging, paper |
| Excluded from scope | packaging used solely in transportation to nonconsumers, packaging used solely in business to business sales | exempt materials |
| Sales channels addressed | physical retail, internet transaction | physical retail, remote sale, other distribution |
| Producer duty: primary packaging | manufacturer_brand_owner; licensee; importer | manufacturer; licensee; brand_owner; importer |
| Producer duty: shipping packaging | packer_shipper | not yet published |
| Producer duty: other packaging | first_distributor | not yet published |
| Reporting categories | 61, covered material type by material class | not yet published |
| Exemption 1 | Exempt from Part 7: revenue under the dollar limit, under one ton of covered materials, state or local government, nonprofit, an agricultural employer with under $5 million in-state consumer sales of its own-brand farm products, a single licensed retail food establishment at a physical location, and builders, construction companies and contractors. | A de minimis producer introduced under one ton or earned under $2,000,000 in global gross revenue in its most recent fiscal year. |

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

## Thresholds and exemptions in Colorado and Minnesota

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

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

| 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 |
| Minnesota | packaging tonnage | 1 short ton | exempt below | covered material introduced, most recent fiscal year |
| Minnesota | revenue | $2,000,000 | exempt below | global gross revenue, most recent fiscal year |

<a id="a-exemption-statutory-exemptions"></a>Colorado exemption: Exempt from Part 7: revenue under the dollar limit, under one ton of covered materials, state or local government, nonprofit, an agricultural employer with under $5 million in-state consumer sales of its own-brand farm products, a single licensed retail food establishment at a physical location, and builders, construction companies and contractors. It does not have to be applied for.

<a id="b-exemption-de-minimis-producer"></a>Minnesota exemption: A de minimis producer introduced under one ton or earned under $2,000,000 in global gross revenue in its most recent fiscal year. 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 $2,000,000 in Minnesota. Minnesota therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Colorado but still in scope in Minnesota.

The lowest weight exemption is the same on both sides: 907.2 kg of packaging.

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

## Fees per kilogram for shared materials

Colorado publishes per-kilogram rates in the dataset; Minnesota does not. The rows therefore show Colorado only. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Colorado and Minnesota would mean inventing a figure, and this page does not do that.

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

<a id="a-fee-source"></a>Colorado: the 2027 fee schedule of Circular Action Alliance (Colorado PRO), effective January 1, 2027, is the source of the per-kilogram rates used on this page.

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

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

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

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

## Deadlines in Colorado and Minnesota

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

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

| Place | Kind | Date | Covers |
| --- | --- | --- | --- |
| Colorado | payment | January 1, 2026 | program year 2026 |
| Colorado | other | January 1, 2026 | not yet published |
| Minnesota | registration | July 1, 2026 | not yet published |
| Minnesota | report | May 31, 2026 | not yet published |
| Minnesota | other | December 31, 2026 | not yet published |
| Minnesota | other | October 1, 2028 | not yet published |
| Minnesota | payment | February 1, 2029 | not yet published |
| Minnesota | payment | February 1, 2030 | not yet published |
| Minnesota | payment | February 1, 2031 | not yet published |

> **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 Minnesota

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.

<a id="b-penalty-0"></a>Minnesota penalty for violation of sections 115A.144 to 115A.1463: up to $25,000 per day.

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

## Report formats in Colorado and Minnesota

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

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

| Aspect | Colorado | Minnesota |
| --- | --- | --- |
| Layout | Colorado producer supply report by material category 2026-09-29 (built from CAA Colorado 2026 dues schedule) | Minnesota interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance) |
| Recipient | Circular Action Alliance (Colorado PRO) | Circular Action Alliance (Minnesota PRO) |
| How it is submitted | CAA producer portal. The customer signs in and submits. | CAA producer portal. 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 | lb |
| 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**: Minnesota: the programme’s own report specification is not yet published. Reason: The PRO says Minnesota material reporting categories are not defined, and the draft plan is not expected until 2027. Only the simplified interim reporting exists, and it is portal-only. 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 Minnesota

Check the exemption thresholds before anything else. Minnesota reaches smaller sellers than Colorado, so a seller that is exempt in Colorado may still have to register in Minnesota.

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

## Questions about comparing these two programmes

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

Minnesota exempts only producers below the lower revenue floor, $2,000,000 against $5,000,000 in Colorado. Both set the lowest weight exemption at 907.2 kg. Both require producers to register.

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

Colorado requires producers to register. Minnesota requires producers to register.

### <a id="q3"></a>How do the fees per kilogram compare in Colorado and Minnesota?

The dataset does not hold per-kilogram rates for the same material class on both sides, so this page does not compare fees.

### <a id="q4"></a>Which deadline comes first, Colorado or Minnesota?

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>Minnesota: the packaging rules sit in Minnesota packaging EPR law, Minnesota Statutes sections 115A.144 to 115A.1463. [#b-regime](#b-regime)
  Value: Minnesota packaging EPR law, Minnesota Statutes sections 115A.144 to 115A.1463 · Source: https://www.revisor.mn.gov/statutes/cite/115A.1441 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: requirements under sections 115A.144 to 115A.1463
- <a id="b-regulator"></a>Minnesota: the regulator is Minnesota Pollution Control Agency. [#b-regulator](#b-regulator)
  Value: Minnesota Pollution Control Agency · Source: https://circularactionalliance.org/minnesota · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: the Minnesota Pollution Control Agency (MPCA) confirmed CAA’s registration to implement the state’s EPR program.
- <a id="b-obligated"></a>Minnesota places an obligation on packaging producers. [#b-obligated](#b-obligated)
  Value: yes · Source: https://circularactionalliance.org/minnesota · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Producers must be a member of a PRO that is registered with MPCA by July 1, 2025.
- <a id="b-registration"></a>Minnesota: producers must register through Producer joins a PRO; the PRO registers with the MPCA. [#b-registration](#b-registration)
  Value: yes · Source: https://circularactionalliance.org/minnesota · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Producers must be a member of a PRO that is registered with MPCA by July 1, 2025.
- <a id="b-organisation"></a>Minnesota organises producer responsibility through a single producer responsibility organisation: Circular Action Alliance; membership is required. [#b-organisation](#b-organisation)
  Value: one producer responsibility organisation · Source: https://web.archive.org/web/20261016213413/https://www.pca.state.mn.us/news-and-stories/mpca-confirms-registration-of-minnesotas-initial-packaging-producer-responsibility-organization · Retrieved: November 5, 2026 · Status: verified
  Verbatim quote: the MPCA confirmed Circular Action Alliance (CAA) — a 501(c)(3) nonprofit, producer-led organization — as Minnesota’s initial PRO.
- <a id="b-hierarchy-primary"></a>Minnesota: at the primary packaging level the producer hierarchy names the manufacturer, brand licensee, brand owner and importer (2024). [#b-hierarchy-primary](#b-hierarchy-primary)
  Value: manufacturer > licensee > brand_owner > importer · Source: https://www.revisor.mn.gov/statutes/cite/115A.1441 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: "Producer" means the following person responsible for compliance with requirements
- <a id="b-threshold-de-minimis-tonnage"></a>Minnesota threshold on tonnage: 1 short ton; effect: exempt below the threshold. [#b-threshold-de-minimis-tonnage](#b-threshold-de-minimis-tonnage)
  Value: 1 short ton · Source: https://www.revisor.mn.gov/statutes/cite/115A.1441 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: introduced less than one ton of covered material into this state
- <a id="b-threshold-de-minimis-revenue"></a>Minnesota threshold on revenue: $2,000,000; effect: exempt below the threshold. [#b-threshold-de-minimis-revenue](#b-threshold-de-minimis-revenue)
  Value: $2,000,000 · Source: https://www.revisor.mn.gov/statutes/cite/115A.1441 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: earned global gross revenues of less than $2,000,000
- Minnesota exemption: A de minimis producer introduced under one ton or earned under $2,000,000 in global gross revenue in its most recent fiscal year. It does not have to be applied for. [#b-exemption-de-minimis-producer](#b-exemption-de-minimis-producer)
  Value: de_minimis_producer · Source: https://www.revisor.mn.gov/statutes/cite/115A.1441 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: "De minimis producer" means a person that in their most recent fiscal year
- <a id="b-deadline-pro-registration-first"></a>Minnesota: registration date July 1, 2026. [#b-deadline-pro-registration-first](#b-deadline-pro-registration-first)
  Value: July 1, 2026 · Source: https://www.revisor.mn.gov/statutes/cite/115A.1443 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: The producer responsibility organization must register with the commissioner by July 1, 2026, and each January 1 thereafter
- <a id="b-deadline-simplified-report-2026"></a>Minnesota: report date May 31, 2026. [#b-deadline-simplified-report-2026](#b-deadline-simplified-report-2026)
  Value: May 31, 2026 · Source: https://circularactionalliance.org/minnesota · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: CAA requires producers to provide simplified reporting by May 31, 2026
- <a id="b-deadline-needs-assessment"></a>Minnesota: other date December 31, 2026. [#b-deadline-needs-assessment](#b-deadline-needs-assessment)
  Value: December 31, 2026 · Source: https://circularactionalliance.org/minnesota · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: December 31, 2026 Full Needs Assessment Due.
- <a id="b-deadline-plan-due"></a>Minnesota: other date October 1, 2028. [#b-deadline-plan-due](#b-deadline-plan-due)
  Value: October 1, 2028 · Source: https://www.revisor.mn.gov/statutes/cite/115A.1451 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: By October 1, 2028, and every five years thereafter, a producer responsibility organization must submit a stewardship plan
- <a id="b-deadline-net-cost-50"></a>Minnesota: payment date February 1, 2029. [#b-deadline-net-cost-50](#b-deadline-net-cost-50)
  Value: February 1, 2029 · Source: https://www.revisor.mn.gov/statutes/cite/115A.1455 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: no less than 50 percent of the net cost by February 1, 2029
- <a id="b-deadline-net-cost-75"></a>Minnesota: payment date February 1, 2030. [#b-deadline-net-cost-75](#b-deadline-net-cost-75)
  Value: February 1, 2030 · Source: https://www.revisor.mn.gov/statutes/cite/115A.1455 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: no less than 75 percent of the net cost by February 1, 2030
- <a id="b-deadline-net-cost-90"></a>Minnesota: payment date February 1, 2031. [#b-deadline-net-cost-90](#b-deadline-net-cost-90)
  Value: February 1, 2031 · Source: https://www.revisor.mn.gov/statutes/cite/115A.1455 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: no less than 90 percent of the net cost by February 1, 2031, and each year thereafter
- Minnesota penalty for violation of sections 115A.144 to 115A.1463: up to $25,000 per day. [#b-penalty-0](#b-penalty-0)
  Value: $25,000 · Source: https://www.revisor.mn.gov/statutes/cite/115A.1462 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: civil penalty not to exceed $25,000 per day of violation
- <a id="b-scope-materials"></a>Minnesota: materials covered is packaging, paper products. [#b-scope-materials](#b-scope-materials)
  Value: packaging,paper_products · Source: https://www.revisor.mn.gov/statutes/cite/115A.1441 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Packaging does not include exempt materials.
- <a id="b-scope-products"></a>Minnesota: product classes covered is packaging, paper. [#b-scope-products](#b-scope-products)
  Value: packaging,paper · Source: https://www.revisor.mn.gov/statutes/cite/115A.1441 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Packaging does not include exempt materials.
- <a id="b-scope-excluded"></a>Minnesota: excluded from scope is exempt materials. [#b-scope-excluded](#b-scope-excluded)
  Value: exempt_materials · Source: https://www.revisor.mn.gov/statutes/cite/115A.1441 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Packaging does not include exempt materials.
- <a id="b-scope-channels"></a>Minnesota: sales channels addressed is physical retail, remote sale, other distribution. [#b-scope-channels](#b-scope-channels)
  Value: physical_retail,remote_sale,other_distribution · Source: https://www.revisor.mn.gov/statutes/cite/115A.1441 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: Packaging does not include exempt materials.
- <a id="b-scope-ph-primary"></a>Minnesota: producer duty: primary packaging is manufacturer; licensee; brand_owner; importer. [#b-scope-ph-primary](#b-scope-ph-primary)
  Value: manufacturer, licensee, brand owner, and importer · Source: https://www.revisor.mn.gov/statutes/cite/115A.1441 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: "Producer" means the following person responsible for compliance with requirements
- <a id="b-scope-ex1"></a>Minnesota: exemption 1 is A de minimis producer introduced under one ton or earned under $2,000,000 in global gross revenue in its most recent fiscal year. [#b-scope-ex1](#b-scope-ex1)
  Value: A de minimis producer introduced under one ton or earned under $2,000,000 in global gross revenue in its most recent fiscal year. · Source: https://www.revisor.mn.gov/statutes/cite/115A.1441 · Retrieved: September 29, 2026 · Status: verified
  Verbatim quote: "De minimis producer" means a person that in their most recent fiscal year
- The lowest revenue exemption is $5,000,000 in Colorado and $2,000,000 in Minnesota. Minnesota therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Colorado but still in scope in Minnesota. [#calc-revenue](#calc-revenue)
  Value: US-MN · 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
- The lowest weight exemption is the same on both sides: 907.2 kg of packaging. [#calc-mass](#calc-mass)
  Value: same kg · 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
- Both programmes require a producer to register, in Colorado and in Minnesota. [#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

## 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

- [Minnesota EPR](https://instica.com/epr/minnesota)

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## Sources

1. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > In 2022, Governor Polis signed the Producer Responsibility Program for Statewide Recycling Act into law
2. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > CDPHE appointed Circular Action Alliance as the designated Producer Responsibility Organization in May 2023.
3. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > a producer cannot sell or distribute products that use covered materials in Colorado unless they participate in the Producer Responsibility Program
4. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > All producers of paper products and packaging materials should register with Circular Action Alliance and submit a supply report.
5. cdphe.colorado.gov: producer responsibility program (https://cdphe.colorado.gov/producer-responsibility-program), Retrieved: September 29, 2026, Status: verified
   > Interchange 360 manages the recycling of automotive lubricant packaging, such as motor oil and antifreeze.
6. colorado.public.law: crs 25 17 713 (https://colorado.public.law/statutes/crs_25-17-713), Retrieved: September 29, 2026, Status: verified
   > in realized gross total revenue, not including on-premises alcohol sales, during the prior calendar year
7. colorado.public.law: crs 25 17 703 (https://colorado.public.law/statutes/crs_25-17-703), Retrieved: September 29, 2026, Status: verified
   > the person that is the licensee of a brand or trademark under which a packaged item is sold or distributed in the state
8. colorado.public.law: crs 25 17 713 (https://colorado.public.law/statutes/crs_25-17-713), Retrieved: September 29, 2026, Status: verified
   > A person with less than five million dollars in realized gross total revenue, not including on-premises alcohol sales, during the prior calendar year
9. colorado.public.law: crs 25 17 713 (https://colorado.public.law/statutes/crs_25-17-713), Retrieved: September 29, 2026, Status: verified
   > has used less than one ton of covered materials for products sold or distributed within or into the state
10. circularactionalliance.org: CO 2026 Dues Schedule Public (https://circularactionalliance.org/s/CO-2026-Dues-Schedule-Public.pdf), Retrieved: September 29, 2026, Status: verified
   > Producers who supply 10 tons or less of covered materials into the state are eligible to pay flat dues according to the following schedule
11. colorado.public.law: crs 25 17 713 (https://colorado.public.law/statutes/crs_25-17-713), Retrieved: September 29, 2026, Status: verified
   > A producer is exempt from the requirements of this part 7 if the producer is
12. colorado.public.law: crs 25 17 709 (https://colorado.public.law/statutes/crs_25-17-709), Retrieved: September 29, 2026, Status: verified
   > no later than January 1, 2026, and annually thereafter by a date determined by the organization
13. colorado.public.law: crs 25 17 709 (https://colorado.public.law/statutes/crs_25-17-709), Retrieved: September 29, 2026, Status: verified
   > By January 1, 2026, and each year thereafter, the executive director shall develop an eco-modulation bonus schedule
14. leg.colorado.gov: 2022a 1355 signed (https://leg.colorado.gov/sites/default/files/2022a_1355_signed.pdf), Retrieved: November 5, 2026, Status: verified
   > FIRST VIOLATION, AN INITIAL PENALTY OF FIVE THOUSAND DOLLARS FOR THE FIRST DAY OF EACH VIOLATION AND ONE THOUSAND FIVE HUNDRED DOLLARS PER DAY
15. leg.colorado.gov: 2022a 1355 signed (https://leg.colorado.gov/sites/default/files/2022a_1355_signed.pdf), Retrieved: November 5, 2026, Status: verified
16. colorado.public.law: crs 25 17 703 (https://colorado.public.law/statutes/crs_25-17-703), Retrieved: September 29, 2026, Status: verified
   > means any material, regardless of recyclability, that is intended for single or short-term use
17. circularactionalliance.org: CO 2026 Dues Schedule Public (https://circularactionalliance.org/s/CO-2026-Dues-Schedule-Public.pdf), Retrieved: September 29, 2026, Status: verified
   > Material Class Covered Material Type Base Dues Detriments Malus Not on MRL Malus High Recycling Rates Bonus Final Dues
18. revisor.mn.gov: 115A.1441 (https://www.revisor.mn.gov/statutes/cite/115A.1441), Retrieved: September 29, 2026, Status: verified
   > requirements under sections 115A.144 to 115A.1463
19. circularactionalliance.org: minnesota (https://circularactionalliance.org/minnesota), Retrieved: September 29, 2026, Status: verified
   > the Minnesota Pollution Control Agency (MPCA) confirmed CAA’s registration to implement the state’s EPR program.
20. circularactionalliance.org: minnesota (https://circularactionalliance.org/minnesota), Retrieved: September 29, 2026, Status: verified
   > Producers must be a member of a PRO that is registered with MPCA by July 1, 2025.
21. web.archive.org (https://web.archive.org/web/20261016213413/https://www.pca.state.mn.us/news-and-stories/mpca-confirms-registration-of-minnesotas-initial-packaging-producer-responsibility-organization), Retrieved: November 5, 2026, Status: verified
   > the MPCA confirmed Circular Action Alliance (CAA) — a 501(c)(3) nonprofit, producer-led organization — as Minnesota’s initial PRO.
22. revisor.mn.gov: 115A.1441 (https://www.revisor.mn.gov/statutes/cite/115A.1441), Retrieved: September 29, 2026, Status: verified
   > "Producer" means the following person responsible for compliance with requirements
23. revisor.mn.gov: 115A.1441 (https://www.revisor.mn.gov/statutes/cite/115A.1441), Retrieved: September 29, 2026, Status: verified
   > introduced less than one ton of covered material into this state
24. revisor.mn.gov: 115A.1441 (https://www.revisor.mn.gov/statutes/cite/115A.1441), Retrieved: September 29, 2026, Status: verified
   > earned global gross revenues of less than $2,000,000
25. revisor.mn.gov: 115A.1441 (https://www.revisor.mn.gov/statutes/cite/115A.1441), Retrieved: September 29, 2026, Status: verified
   > "De minimis producer" means a person that in their most recent fiscal year
26. revisor.mn.gov: 115A.1443 (https://www.revisor.mn.gov/statutes/cite/115A.1443), Retrieved: September 29, 2026, Status: verified
   > The producer responsibility organization must register with the commissioner by July 1, 2026, and each January 1 thereafter
27. circularactionalliance.org: minnesota (https://circularactionalliance.org/minnesota), Retrieved: September 29, 2026, Status: verified
   > CAA requires producers to provide simplified reporting by May 31, 2026
28. circularactionalliance.org: minnesota (https://circularactionalliance.org/minnesota), Retrieved: September 29, 2026, Status: verified
   > December 31, 2026 Full Needs Assessment Due.
29. revisor.mn.gov: 115A.1451 (https://www.revisor.mn.gov/statutes/cite/115A.1451), Retrieved: September 29, 2026, Status: verified
   > By October 1, 2028, and every five years thereafter, a producer responsibility organization must submit a stewardship plan
30. revisor.mn.gov: 115A.1455 (https://www.revisor.mn.gov/statutes/cite/115A.1455), Retrieved: September 29, 2026, Status: verified
   > no less than 50 percent of the net cost by February 1, 2029
31. revisor.mn.gov: 115A.1455 (https://www.revisor.mn.gov/statutes/cite/115A.1455), Retrieved: September 29, 2026, Status: verified
   > no less than 75 percent of the net cost by February 1, 2030
32. revisor.mn.gov: 115A.1455 (https://www.revisor.mn.gov/statutes/cite/115A.1455), Retrieved: September 29, 2026, Status: verified
   > no less than 90 percent of the net cost by February 1, 2031, and each year thereafter
33. revisor.mn.gov: 115A.1462 (https://www.revisor.mn.gov/statutes/cite/115A.1462), Retrieved: September 29, 2026, Status: verified
   > civil penalty not to exceed $25,000 per day of violation
34. revisor.mn.gov: 115A.1441 (https://www.revisor.mn.gov/statutes/cite/115A.1441), Retrieved: September 29, 2026, Status: verified
   > Packaging does not include exempt materials.
35. 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
36. 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
37. 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
38. 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

## Cite this page

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

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