Colorado vs New Brunswick EPR: Rules Compared
Last verified
Colorado and New Brunswick both run packaging EPR, but the rules differ. New Brunswick exempts only producers below the lower revenue floor, CA$2,000,000 against $5,000,000 in Colorado. Colorado has the lower weight floor, 907.2 kg against 1 tonne in New Brunswick. Both require producers to register.
Colorado and New Brunswick side by side
5 of 9 rows have a verified figure on each side of Colorado and New Brunswick; a cell reads “not yet published” when a side has none, and an exemption row reads “none recorded; see thresholds” when no exemption is on record.
| Measure | Colorado | New Brunswick | 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$2,000,000 | New Brunswick |
| Lowest weight exemption | 907.2 kg | 1 tonne | Colorado |
| 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 | 68 cents per kilogram | New Brunswick |
| Plastic fee, cheapest matched rate | 62.0 cents per pound | 195 cents per kilogram | New Brunswick |
The lowest revenue exemption is $5,000,000 in Colorado and CA$2,000,000 in New Brunswick ($1,430,820 at the Bank of Canada 2025 annual average rate). New Brunswick therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Colorado but still in scope in New Brunswick.
The lowest weight exemption is 907.2 kg of packaging in Colorado and 1 tonne in New Brunswick, about 1.1 times as much in New Brunswick as in Colorado. A seller whose packaging falls between the two lines is exempt in New Brunswick but counted in Colorado.
Both programmes require a producer to register, in Colorado and in New Brunswick.
Across 5 shared material classes, New Brunswick publishes the higher cheapest per-kilogram fee in 5, and Colorado in 0. A higher fee is not the same as a stricter rule; it is simply a larger published number per kilogram.
Who runs the programme in Colorado and New Brunswick
Who collects and who the producer files with, in Colorado and then New Brunswick.
| Aspect | Colorado | New Brunswick |
|---|---|---|
| Regime | Colorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355) | Designated Materials Regulation, N.B. Reg. 2024-37 (Clean Environment Act) |
| Regulator | Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program | Recycle New Brunswick (stewardship board) |
| Producers obligated | Yes | Yes |
| Registration | Required, Circular Action Alliance producer portal | Required, Recycle New Brunswick (stewardship board) |
| 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 Materials; membership required |
| Transfer of responsibility | not yet published | Allowed |
| Revenue counted as | realised gross total revenue, USD, prior calendar year | gross revenue inside the jurisdiction, CAD, 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, seller, online marketplace; primary: brand owner, importer, seller, online marketplace; secondary: brand owner, importer, seller, online marketplace; service: brand owner, importer, seller, online marketplace; shipping: brand owner, importer, seller, online marketplace; tertiary: brand owner, importer, seller, online marketplace |
The two programmes are organised differently. Colorado uses more than one producer responsibility organisation; New Brunswick uses one producer responsibility organisation. For a seller in both, that usually means two different counterparties, two different sign-up routes and two different sets of terms to read before the first report is due.
What Colorado and New Brunswick cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Colorado or New Brunswick has no verified entry for it in the dataset.
| Aspect | Colorado | New Brunswick |
|---|---|---|
| Materials covered | packaging material, paper products, food serviceware | paper, plastic, metal, glass, printed paper, packaging |
| Product classes covered | packaging, paper, food serviceware | packaging, paper products |
| Excluded from scope | packaging used solely in transportation to nonconsumers, packaging used solely in business to business sales | small producers |
| Sales channels addressed | physical retail, internet transaction | retail, online, distance sale |
| Producer duty: primary packaging | manufacturer_brand_owner; licensee; importer | brand_owner; importer; seller; marketplace |
| Producer duty: shipping packaging | packer_shipper | brand_owner; importer; seller; marketplace |
| Producer duty: other packaging | first_distributor | brand_owner; importer; seller; marketplace |
| Reporting categories | 61, covered material type by material class | 36, 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 2,000,000 NB revenue, under one tonne, or a registered charity |
| Producer duty: secondary packaging | not yet published | brand_owner; importer; seller; marketplace |
| Producer duty: tertiary packaging | not yet published | brand_owner; importer; seller; marketplace |
| Producer duty: service packaging | not yet published | brand_owner; importer; seller; marketplace |
Thresholds and exemptions in Colorado and New Brunswick
Every verified threshold Colorado and New Brunswick publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| Colorado | revenue | $5,000,000 | exempt below | realized gross total revenue, prior calendar year, excluding on-premises alcohol sales |
| Colorado | packaging tonnage | 1 short ton | exempt below | covered materials used for products sold or distributed in or into Colorado, prior calendar year |
| Colorado | packaging tonnage | 10 short tons | flat-fee band | covered materials supplied into Colorado |
| New Brunswick | revenue | CA$2,000,000 | exempt below | gross annual New Brunswick revenue |
| New Brunswick | packaging tonnage | 1 tonne | exempt below | packaging and paper per year |
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.
New Brunswick exemption: Under CAD 2,000,000 NB revenue, under one tonne, or a registered charity 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$2,000,000 in New Brunswick ($1,430,820 at the Bank of Canada 2025 annual average rate). New Brunswick therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Colorado but still in scope in New Brunswick.
The lowest weight exemption is 907.2 kg of packaging in Colorado and 1 tonne in New Brunswick, about 1.1 times as much in New Brunswick as in Colorado. A seller whose packaging falls between the two lines is exempt in New Brunswick but counted in Colorado.
Fees per kilogram for shared materials
5 material classes have a published rate on both sides; each row shows the cheapest rate that fits the class.
| Material class | Colorado (USD per kg) | New Brunswick (CAD per kg) | New Brunswick in USD, approx. | Higher fee |
|---|---|---|---|---|
| paper and board | 9.0 cents per pound | 68 cents per kilogram | $0.4865 | New Brunswick |
| plastic | 62.0 cents per pound | 195 cents per kilogram | $1.395 | New Brunswick |
| glass | 5.0 cents per pound | 47 cents per kilogram | $0.3362 | New Brunswick |
| aluminium | 5.0 cents per pound | 100 cents per kilogram | $0.7154 | New Brunswick |
| steel | 11.0 cents per pound | 83 cents per kilogram | $0.5938 | New Brunswick |
Scaling the cheapest published rate by weight shows what the gap between Colorado and New Brunswick amounts to for a given tonnage of one material. The amounts are the rate times the weight, nothing added.
| Material class | Kilograms | Colorado fee (USD) | New Brunswick fee (CAD) | New Brunswick in USD, approx. | New Brunswick minus Colorado (USD) |
|---|---|---|---|---|---|
| paper and board | 1 | $0.20 | CA$0.68 | $0.49 | +$0.29 |
| paper and board | 10 | $1.98 | CA$6.80 | $4.86 | +$2.88 |
| paper and board | 100 | $19.84 | CA$68.00 | $48.65 | +$28.81 |
| paper and board | 1,000 | $198.42 | CA$680.00 | $486.48 | +$288.06 |
| paper and board | 10,000 | $1,984.16 | CA$6,800.00 | $4,864.79 | +$2,880.63 |
| paper and board | 100,000 | $19,841.60 | CA$68,000.00 | $48,647.88 | +$28,806.27 |
| plastic | 1 | $1.37 | CA$1.95 | $1.40 | +$0.03 |
| plastic | 10 | $13.67 | CA$19.50 | $13.95 | +$0.28 |
| plastic | 100 | $136.69 | CA$195.00 | $139.50 | +$2.82 |
| plastic | 1,000 | $1,366.87 | CA$1,950.00 | $1,395.05 | +$28.18 |
| plastic | 10,000 | $13,668.66 | CA$19,500.00 | $13,950.49 | +$281.83 |
| plastic | 100,000 | $136,686.60 | CA$195,000.00 | $139,504.94 | +$2,818.33 |
| glass | 1 | $0.11 | CA$0.47 | $0.34 | +$0.23 |
| glass | 10 | $1.10 | CA$4.70 | $3.36 | +$2.26 |
| glass | 100 | $11.02 | CA$47.00 | $33.62 | +$22.60 |
| glass | 1,000 | $110.23 | CA$470.00 | $336.24 | +$226.01 |
| glass | 10,000 | $1,102.31 | CA$4,700.00 | $3,362.43 | +$2,260.12 |
| glass | 100,000 | $11,023.11 | CA$47,000.00 | $33,624.27 | +$22,601.15 |
| aluminium | 1 | $0.11 | CA$1.00 | $0.72 | +$0.61 |
| aluminium | 10 | $1.10 | CA$10.00 | $7.15 | +$6.05 |
| aluminium | 100 | $11.02 | CA$100.00 | $71.54 | +$60.52 |
| aluminium | 1,000 | $110.23 | CA$1,000.00 | $715.41 | +$605.18 |
| aluminium | 10,000 | $1,102.31 | CA$10,000.00 | $7,154.10 | +$6,051.79 |
| aluminium | 100,000 | $11,023.11 | CA$100,000.00 | $71,540.99 | +$60,517.88 |
| steel | 1 | $0.24 | CA$0.83 | $0.59 | +$0.35 |
| steel | 10 | $2.43 | CA$8.30 | $5.94 | +$3.51 |
| steel | 100 | $24.25 | CA$83.00 | $59.38 | +$35.13 |
| steel | 1,000 | $242.51 | CA$830.00 | $593.79 | +$351.28 |
| steel | 10,000 | $2,425.08 | CA$8,300.00 | $5,937.90 | +$3,512.82 |
| steel | 100,000 | $24,250.85 | CA$83,000.00 | $59,379.02 | +$35,128.18 |
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.
New Brunswick: the 2027 fee schedule of Circular Materials New Brunswick (Recycle NB), effective January 1, 2027, is the source of the per-kilogram rates used on this page.
Colorado: the 2027 fee schedule of Circular Action Alliance (Colorado PRO), effective January 1, 2027, is the source of the per-kilogram rates used on this page.
Colorado 2027: the category “Kraft Paper” is published at 9.0 cents per pound.
Colorado 2027: the category “HDPE (#2)/LDPE (#4) Flexible and Film Items” is published at 62.0 cents per pound.
Colorado 2027: the category “Glass Bottles and Jars & Other Containers” is published at 5.0 cents per pound.
Colorado 2027: the category “Aluminum Containers” is published at 5.0 cents per pound.
Colorado 2027: the category “Steel Containers” is published at 11.0 cents per pound.
New Brunswick 2027: the category “Boxboard and Other Paper Packaging” is published at 68 cents per kilogram.
New Brunswick 2027: the category “LDPE/HDPE Film” is published at 195 cents per kilogram.
New Brunswick 2027: the category “Clear Glass” is published at 47 cents per kilogram.
New Brunswick 2027: the category “Aluminum Food Containers” is published at 100 cents per kilogram.
New Brunswick 2027: the category “Other Steel Containers and Packaging” is published at 83 cents per kilogram.
Real packs usually land in a dearer category, so use the calculator for Colorado and New Brunswick.
Deadlines in Colorado and New Brunswick
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| Colorado | payment | January 1, 2026 | program year 2026 |
| Colorado | other | January 1, 2026 | not yet published |
| New Brunswick | report | May 31 | the previous calendar year |
| New Brunswick | registration | June 30, 2025 | not yet published |
| New Brunswick | plan | June 30, 2025 | not yet published |
Penalties in Colorado and New Brunswick
What each side has published; a side without an amount says so.
Colorado penalty for First violation of Part 7 by a producer or producer responsibility organization: up to $5,000 for the first day, then up to $1,500 per day the violation continues.
Colorado penalty for Second violation within twelve months after a prior violation: up to $10,000 for the first day, then up to $3,000 per day the violation continues.
Colorado penalty for Third or later violation within twelve months after two or more prior violations: up to $20,000 for the first day, then up to $6,000 per day the violation continues.
Report formats in Colorado and New Brunswick
How the report file for Colorado compares with the one for New Brunswick.
| Aspect | Colorado | New Brunswick |
|---|---|---|
| Layout | Colorado producer supply report by material category 2026-09-29 (built from CAA Colorado 2026 dues schedule) | New Brunswick producer annual report Fee-year categories, reviewed 2026-09-29 |
| Recipient | Circular Action Alliance (Colorado PRO) | Recycle NB / Circular Materials |
| How it is submitted | CAA producer portal. The customer signs in and submits. | WeRecycle Portal |
| File type | csv | csv |
| Encoding | utf-8 | utf-8 |
| Delimiter | , | , |
| Decimal separator | . | |
| Columns | 4 | 4 |
| Required columns | 4 of 4 | 4 of 4 |
| Weight unit | lb | kg |
| Period basis | calendar year | calendar year |
The two layouts share a file type and a delimiter, but each programme names its own columns and categories, so one file cannot be sent to both programmes. Each report is built from the same underlying measurements and exported separately.
Which to plan for first, Colorado or New Brunswick
Check the exemption thresholds before anything else. New Brunswick reaches smaller sellers than Colorado, so a seller that is exempt in Colorado may still have to register in New Brunswick.
Questions about comparing these two programmes
Is Colorado or New Brunswick stricter on packaging EPR?
New Brunswick exempts only producers below the lower revenue floor, CA$2,000,000 against $5,000,000 in Colorado. Colorado has the lower weight floor, 907.2 kg against 1 tonne in New Brunswick. Both require producers to register. New Brunswick publishes the higher per-kilogram fee in 5 of 5 shared material classes.
Do I register in both Colorado and New Brunswick?
Colorado requires producers to register. New Brunswick requires producers to register.
How do the fees per kilogram compare in Colorado and New Brunswick?
Across 5 shared material classes, New Brunswick publishes the higher cheapest per-kilogram fee in 5, and Colorado in 0. A higher fee is not the same as a stricter rule; it is simply a larger published number per kilogram.
Which deadline comes first, Colorado or New Brunswick?
The dataset does not hold a verified annual report date on both sides, so this page does not say which comes first.
How these figures are made
Sources
- cdphe.colorado.gov: producer responsibility program retrieved
Original wording: In 2022, Governor Polis signed the Producer Responsibility Program for Statewide Recycling Act into law
Original wording: CDPHE appointed Circular Action Alliance as the designated Producer Responsibility Organization in May 2023.
Original wording: a producer cannot sell or distribute products that use covered materials in Colorado unless they participate in the Producer Responsibility Program
Original wording: All producers of paper products and packaging materials should register with Circular Action Alliance and submit a supply report.
Original wording: Interchange 360 manages the recycling of automotive lubricant packaging, such as motor oil and antifreeze.
- colorado.public.law: crs 25 17 713 retrieved
Original wording: in realized gross total revenue, not including on-premises alcohol sales, during the prior calendar year
Original wording: A person with less than five million dollars in realized gross total revenue, not including on-premises alcohol sales, during the prior calendar year
Original wording: has used less than one ton of covered materials for products sold or distributed within or into the state
Original wording: A producer is exempt from the requirements of this part 7 if the producer is
- colorado.public.law: crs 25 17 703 retrieved
Original wording: the person that is the licensee of a brand or trademark under which a packaged item is sold or distributed in the state
Original wording: means any material, regardless of recyclability, that is intended for single or short-term use
- circularactionalliance.org: CO 2026 Dues Schedule Public retrieved
Original wording: Producers who supply 10 tons or less of covered materials into the state are eligible to pay flat dues according to the following schedule
Original wording: Material Class Covered Material Type Base Dues Detriments Malus Not on MRL Malus High Recycling Rates Bonus Final Dues
- colorado.public.law: crs 25 17 709 retrieved
Original wording: no later than January 1, 2026, and annually thereafter by a date determined by the organization
Original wording: By January 1, 2026, and each year thereafter, the executive director shall develop an eco-modulation bonus schedule
- leg.colorado.gov: 2022a 1355 signed retrieved
Original wording: FIRST VIOLATION, AN INITIAL PENALTY OF FIVE THOUSAND DOLLARS FOR THE FIRST DAY OF EACH VIOLATION AND ONE THOUSAND FIVE HUNDRED DOLLARS PER DAY
- laws.gnb.ca: 2024 37 retrieved
Original wording: This Regulation may be cited as the Designated Materials Regulation – Clean Environment Act
Original wording: The stewardship board established by the Minister under section 22.1 of the Act, to be known as Recycle New Brunswick, is continued.
Original wording: the producer generates less than $2,000,000 in gross annual revenue in the Province;
Original wording: An application for registration shall be submitted on a form provided by the stewardship board
Original wording: On or before May 31 in each year, a producer shall submit an annual report to the stewardship board
Original wording: the brand holder of the designated material if the brand holder has a permanent establishment in Canada;
Original wording: the producer manufactures, distributes, sells or offers for sale less than one tonne of packaging and paper annually in the Province; or
Original wording: A producer who was not a brand owner shall submit an application for registration referred to in section 16 no later than June 30, 2025.
Original wording: a stewardship plan under this Regulation, including the performance measures and targets referred to in section 44 , no later than June 30, 2025.
- circularmaterials.ca: Circular Materials Report to Producers 2025 retrieved
Original wording: Newspapers 74 80 -7.5%
- Bank of Canada, FXAUSDCAD (annual average 2025) retrieved
- circularactionalliance.org: CO 2027DuesSchedule 100126 retrieved
Original wording: 2027 Colorado Producer Dues Schedule Dues for Program Year 2027
Original wording: Kraft Paper MRL $0.09 $0.00 $0.00 $0.00 $0.09
Original wording: HDPE (#2)/LDPE (#4) Flexible and Film Items AML $0.62 $0.00 $0.00 $0.00 $0.62
Original wording: Glass Bottles and Jars & Other Containers MRL $0.05 $0.00 $0.00 $0.00 $0.05
Original wording: Aluminum Containers MRL $0.05 $0.00 $0.00 $0.00 $0.05
Original wording: Steel Containers MRL $0.12 $0.00 $0.00 -$0.01 $0.11
- knowledge.werecycle.ca: Report to Producers 2026 OCT15 retrieved
Original wording: Circular Materials in New Brunswick Fee Schedule (Cents/Kg)
Original wording: Boxboard and Other Paper Packaging 68 65 4.6%
Original wording: LDPE/HDPE Film 195 187 4.3%
Original wording: Clear Glass 47 46 2.2%
Original wording: Aluminum Food Containers 100 93 7.5 %
Original wording: Other Steel Containers and Packaging 83 82 1.2%
The free plan is enough to start. We estimate and prepare; you sign and submit.