Colorado vs Yukon EPR: Rules Compared
Last verified
Colorado and Yukon both run packaging EPR, but the rules differ. Yukon exempts only producers below the lower revenue floor, CA$1,000,000 against $5,000,000 in Colorado. Colorado has the lower weight floor, 907.2 kg against 1 tonne in Yukon. Yukon publishes the higher per-kilogram fee in 5 of 5 shared material classes.
Colorado and Yukon side by side
4 of 9 rows have a verified figure on each side of Colorado and Yukon; 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 | Yukon | Stricter |
|---|---|---|---|
| Registration duty | Required | not yet published | Not comparable |
| Producer organisation | more than one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | $5,000,000 | CA$1,000,000 | Yukon |
| 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 | 136 cents per kilogram | Yukon |
| Plastic fee, cheapest matched rate | 62.0 cents per pound | 588 cents per kilogram | Yukon |
The lowest revenue exemption is $5,000,000 in Colorado and CA$1,000,000 in Yukon ($715,410 at the Bank of Canada 2025 annual average rate). Yukon therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Colorado but still in scope in Yukon.
The lowest weight exemption is 907.2 kg of packaging in Colorado and 1 tonne in Yukon, about 1.1 times as much in Yukon as in Colorado. A seller whose packaging falls between the two lines is exempt in Yukon but counted in Colorado.
Across 5 shared material classes, Yukon 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 Yukon
Who collects and who the producer files with, in Colorado and then Yukon.
| Aspect | Colorado | Yukon |
|---|---|---|
| Regime | Colorado Producer Responsibility Program for Statewide Recycling Act, C.R.S. 25-17-701 et seq. (HB22-1355) | Extended Producer Responsibility Regulation, OIC 2024/19 (effective 2024-01-25; launched 2025-11-01) |
| Regulator | Colorado Department of Public Health and Environment (CDPHE), Solid Waste and Materials Management Program | Government of Yukon, Ministry of the Environment |
| Producers obligated | Yes | Yes |
| Registration | Required, Circular Action Alliance producer portal | not yet published |
| 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 |
| Revenue counted as | realised gross total revenue, USD, prior calendar year | gross revenue inside the jurisdiction, CAD, completed 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: 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; Yukon 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 Yukon cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Colorado or Yukon has no verified entry for it in the dataset.
| Aspect | Colorado | Yukon |
|---|---|---|
| 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; 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. | Charity, under CAD 1,000,000 Yukon revenue or under one tonne |
| 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 | seller; marketplace |
Thresholds and exemptions in Colorado and Yukon
Every verified threshold Colorado and Yukon 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 |
| Yukon | revenue | CA$1,000,000 | exempt below | revenue in Yukon |
| Yukon | packaging tonnage | 1 tonne | exempt below | supply |
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.
Yukon exemption: Charity, under CAD 1,000,000 Yukon revenue or under one tonne 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$1,000,000 in Yukon ($715,410 at the Bank of Canada 2025 annual average rate). Yukon therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Colorado but still in scope in Yukon.
The lowest weight exemption is 907.2 kg of packaging in Colorado and 1 tonne in Yukon, about 1.1 times as much in Yukon as in Colorado. A seller whose packaging falls between the two lines is exempt in Yukon 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) | Yukon (CAD per kg) | Yukon in USD, approx. | Higher fee |
|---|---|---|---|---|
| paper and board | 9.0 cents per pound | 136 cents per kilogram | $0.973 | Yukon |
| plastic | 62.0 cents per pound | 588 cents per kilogram | $4.2066 | Yukon |
| glass | 5.0 cents per pound | 122 cents per kilogram | $0.8728 | Yukon |
| aluminium | 5.0 cents per pound | 455 cents per kilogram | $3.2551 | Yukon |
| steel | 11.0 cents per pound | 211 cents per kilogram | $1.5095 | Yukon |
Scaling the cheapest published rate by weight shows what the gap between Colorado and Yukon 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) | Yukon fee (CAD) | Yukon in USD, approx. | Yukon minus Colorado (USD) |
|---|---|---|---|---|---|
| paper and board | 1 | $0.20 | CA$1.36 | $0.97 | +$0.77 |
| paper and board | 10 | $1.98 | CA$13.60 | $9.73 | +$7.75 |
| paper and board | 100 | $19.84 | CA$136.00 | $97.30 | +$77.45 |
| paper and board | 1,000 | $198.42 | CA$1,360.00 | $972.96 | +$774.54 |
| paper and board | 10,000 | $1,984.16 | CA$13,600.00 | $9,729.58 | +$7,745.41 |
| paper and board | 100,000 | $19,841.60 | CA$136,000.00 | $97,295.75 | +$77,454.15 |
| plastic | 1 | $1.37 | CA$5.88 | $4.21 | +$2.84 |
| plastic | 10 | $13.67 | CA$58.80 | $42.07 | +$28.40 |
| plastic | 100 | $136.69 | CA$588.00 | $420.66 | +$283.97 |
| plastic | 1,000 | $1,366.87 | CA$5,880.00 | $4,206.61 | +$2,839.74 |
| plastic | 10,000 | $13,668.66 | CA$58,800.00 | $42,066.10 | +$28,397.44 |
| plastic | 100,000 | $136,686.60 | CA$588,000.00 | $420,661.04 | +$283,974.44 |
| glass | 1 | $0.11 | CA$1.22 | $0.87 | +$0.76 |
| glass | 10 | $1.10 | CA$12.20 | $8.73 | +$7.63 |
| glass | 100 | $11.02 | CA$122.00 | $87.28 | +$76.26 |
| glass | 1,000 | $110.23 | CA$1,220.00 | $872.80 | +$762.57 |
| glass | 10,000 | $1,102.31 | CA$12,200.00 | $8,728.00 | +$7,625.69 |
| glass | 100,000 | $11,023.11 | CA$122,000.00 | $87,280.01 | +$76,256.90 |
| aluminium | 1 | $0.11 | CA$4.55 | $3.26 | +$3.14 |
| aluminium | 10 | $1.10 | CA$45.50 | $32.55 | +$31.45 |
| aluminium | 100 | $11.02 | CA$455.00 | $325.51 | +$314.49 |
| aluminium | 1,000 | $110.23 | CA$4,550.00 | $3,255.12 | +$3,144.88 |
| aluminium | 10,000 | $1,102.31 | CA$45,500.00 | $32,551.15 | +$31,448.84 |
| aluminium | 100,000 | $11,023.11 | CA$455,000.00 | $325,511.52 | +$314,488.40 |
| steel | 1 | $0.24 | CA$2.11 | $1.51 | +$1.27 |
| steel | 10 | $2.43 | CA$21.10 | $15.10 | +$12.67 |
| steel | 100 | $24.25 | CA$211.00 | $150.95 | +$126.70 |
| steel | 1,000 | $242.51 | CA$2,110.00 | $1,509.51 | +$1,267.01 |
| steel | 10,000 | $2,425.08 | CA$21,100.00 | $15,095.15 | +$12,670.06 |
| steel | 100,000 | $24,250.85 | CA$211,000.00 | $150,951.50 | +$126,700.65 |
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.
Yukon: the 2027 fee schedule of Circular Materials Yukon, 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.
Yukon 2027: the category “Boxboard and Other Paper Packaging” is published at 136 cents per kilogram.
Yukon 2027: the category “LDPE/HDPE Film” is published at 588 cents per kilogram.
Yukon 2027: the category “Clear Glass” is published at 122 cents per kilogram.
Yukon 2027: the category “Aluminum Food Containers” is published at 455 cents per kilogram.
Yukon 2027: the category “Other Steel Containers and Packaging” is published at 211 cents per kilogram.
Real packs usually land in a dearer category, so use the calculator for Colorado and Yukon.
Deadlines in Colorado and Yukon
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 |
| Yukon | report | May 31 | the previous calendar year |
| Yukon | report | July 1 | the previous calendar year |
| Yukon | report | every three years, on or before September 1, beginning with the second annual report submitted for the program; not annual | verifies the annual report most recently submitted for the program |
Penalties in Colorado and Yukon
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 Yukon
How the report file for Colorado compares with the one for Yukon.
| Aspect | Colorado | Yukon |
|---|---|---|
| Layout | Colorado producer supply report by material category 2026-09-29 (built from CAA Colorado 2026 dues schedule) | Yukon steward annual report Fee-year categories, reviewed 2026-09-29 |
| Recipient | Circular Action Alliance (Colorado PRO) | Government of Yukon / 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 Yukon
Check the exemption thresholds before anything else. Yukon reaches smaller sellers than Colorado, so a seller that is exempt in Colorado may still have to register in Yukon.
Questions about comparing these two programmes
Is Colorado or Yukon stricter on packaging EPR?
Yukon exempts only producers below the lower revenue floor, CA$1,000,000 against $5,000,000 in Colorado. Colorado has the lower weight floor, 907.2 kg against 1 tonne in Yukon. Yukon publishes the higher per-kilogram fee in 5 of 5 shared material classes.
Do I register in both Colorado and Yukon?
Colorado requires producers to register. Yukon has not yet published its registration duty.
How do the fees per kilogram compare in Colorado and Yukon?
Across 5 shared material classes, Yukon 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 Yukon?
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.yukon.ca: 2024 0019 retrieved
Original wording: On or before May 31 of each year, a steward must
Original wording: completed year of less than $1,000,000,
Original wording: (A) the brand holder of the product, if the brand holder is resident in Canada,
Original wording: imported into or supplied in Yukon in the most recently completed year less than one tonne of designated materials
Original wording: On or before May 31 of each year, a steward must submit the records described in paragraphs (1)(d) to (f)
Original wording: On or before July 1 of each year, the operator of a stewardship program must
Original wording: Every three years, the operator of a program must submit an audit report on or before September 1
- circularmaterials.ca: Circular Materials Report to Producers 2025 retrieved
Original wording: Average fee rate (cents per kg) (Total fee budget/supply tonnes) 227 c/kg
- 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 the Yukon Fee Schedule (Cents/Kg)
Original wording: Boxboard and Other Paper Packaging 136 127 7.1 %
Original wording: LDPE/HDPE Film 588 566 3.9%
Original wording: Clear Glass 122 116 5.2%
Original wording: Aluminum Food Containers 455 410 11.0%
Original wording: Other Steel Containers and Packaging 211 191 10.5%
The free plan is enough to start. We estimate and prepare; you sign and submit.