How to File the Colorado Annual Supply Report & PCR Report (HB 22-1355)
May 20, 2026 · 13 min read
Colorado requires two separate filings: the Annual Supply Report (packaging weight by material) and the mandatory PCR Content Report (recycled content in your packaging). No other EPR state requires a PCR report alongside the supply report. This guide covers both.
At a glance
Two separate filings due May 31
Filing 1: Annual Supply Report
Total packaging weight by material category sold into Colorado during CY 2025. This determines your EPR fees (called “dues” in Colorado).
Filing 2: Mandatory PCR Content Report
Post-consumer recycled content in each packaging component sold into Colorado. This demonstrates compliance with HB 21-1162 minimum content requirements.
Both are filed through the same CAA portal, but they are separate forms. Plan your time accordingly — the PCR report requires additional data that the Supply Report does not.
Part 1: Annual Supply Report
Confirm your obligation
You must file if you are a “producer” under HB 22-1355 — brand owner, licensee, importer, or first distributor of a packaged product sold into Colorado — and you exceed either threshold:
- Revenue threshold: Over ~$5.5 million in global gross revenue (CPI-adjusted annually — check current amount)
- Volume threshold: Over 1 ton of covered materials into Colorado
Either threshold triggers obligation — you don't need to exceed both. If you're under $5.5M globally AND under 1 ton into CO, you are exempt.
Understand Colorado's scope
Covered in Colorado
- Consumer-facing packaging (B2C)
- Printed paper / writing paper
- Food service ware
- Consumer-facing shipping packaging (B2C)
Exempt in Colorado
- Under ~$5.5M global revenue
- Under 1 ton of covered materials
- B2B/commercial transport packaging
- Beverage containers under CO bottle bill
Key difference: Colorado exempts B2B/commercial transport packaging. If you only ship B2B, that packaging is not covered. But B2C shipping packaging (e-commerce boxes, mailers) is covered.
Map materials to Colorado categories
Colorado uses approximately 61 material categories under HB 22-1355. The fee schedule varies significantly by recyclability:
| Category | Examples | Est. Fee ($/lb) |
|---|---|---|
| Readily recyclable plastic | PET (#1), HDPE (#2), PP (#5) containers/closures | $0.08–0.21 |
| Non-recyclable plastic | PS (#6), PVC (#3), multi-layer pouches/film | $0.38–0.76 |
| Corrugated cardboard | Shipping boxes, corrugated trays | $0.02–0.08 |
| Paperboard | Cartons, folding boxes, labels | $0.05–0.13 |
| Glass | Bottles, jars | $0.02–0.08 |
| Aluminum | Cans, foil, closures | $0.02–0.05 |
| Steel | Cans, drums, strapping | $0.05–0.10 |
Colorado has the steepest non-recyclable plastic rates among the three active EPR states — up to $1.72/lb. Correct material classification saves significant money.
Calculate weight and allocate to Colorado
Calculation: Weight per unit × national units sold × CO revenue % = Colorado weight per material category.
Example: 50,000 kg total PET nationally. At 2% CO revenue: 50,000 × 0.02 = 1,000 kg PET reported to Colorado.
Use your Colorado-specific revenue percentage. Do not reuse your California or Oregon allocation — each state should reflect actual sales distribution.
Part 2: Mandatory PCR Content Report
Colorado is the only active EPR state that requires a PCR content report alongside the supply report. This comes from HB 21-1162, a separate law from the EPR statute, and it applies specifically to plastic packaging.
Colorado PCR minimum content requirements
| Product Category | 2025 Minimum | 2027 Minimum |
|---|---|---|
| Rigid plastic beverage containers | 15% PCR | 25% PCR |
| Plastic trash bags | 10% PCR | 20% PCR |
| Plastic carryout bags | 20% PCR | — |
These are minimum content laws — you must meet these percentages or face separate penalties under HB 21-1162. The PCR report filed through CAA demonstrates your compliance.
What to report in the PCR report
For each packaging component sold into Colorado, report:
| Field | What to Enter |
|---|---|
| Product / SKU | Product identifier |
| Component | Packaging component (bottle, cap, label, film, etc.) |
| Material type | Resin or material category (PET, HDPE, PP, etc.) |
| Total weight (lbs) | Weight of the component |
| PCR content weight (lbs) | Weight of post-consumer recycled material in the component |
| PCR percentage | PCR weight ÷ total weight × 100 |
| Verification method | How you verified PCR content (supplier cert, third-party audit, etc.) |
Where to get PCR data
- Supplier certifications — Most packaging suppliers provide PCR content data on request. This is the most common source.
- Resin purchase records — If you buy resin directly, your purchase records show virgin vs. recycled content.
- Third-party certifications — APR Postconsumer Resin Certification Program, SCS Global, or similar.
- If you don't have PCR data: Report 0% and develop a plan to increase PCR content. Do not fabricate numbers — report accurately and plan improvements.
Eco-modulation credits are available for high PCR content (>30%) — see below.
Colorado eco-modulation factors
Colorado's 2026 Dues Schedule includes three passive eco-modulation factors that are automatically applied based on your supply data. Four additional active incentives are expected to be published by CAA:
| Factor | Type | Impact |
|---|---|---|
| Detriments | Malus | +5% for materials that disrupt recycling |
| Not on MRL | Malus | AML materials ≥20% above similar MRL rates; N/C materials ≥10% above similar AML rates |
| High Recycling Rate | Bonus | -5% for materials with high recycling rates (applied automatically per material) |
| Active incentives (4 factors) | TBD | To be published by CAA (may include PCR, standardized packaging, label credits) |
The Recycling Bonus is already reflected in the Final Dues rates shown in the schedule. The PCR content you report may qualify for future active incentive credits. See strategies to reduce your fees →
Colorado penalty structure
Colorado has escalating penalties — each subsequent offense increases the fine:
| Offense | Fixed Penalty | Daily Penalty |
|---|---|---|
| 1st offense | $5,000 | $1,500/day |
| 2nd offense | $10,000 | $3,000/day |
| 3rd+ offense | $20,000 | $6,000/day |
Non-compliance can also restrict your ability to sell products in Colorado. CDPHE (Colorado Department of Public Health and Environment) enforces these penalties.
Register and submit through CAA
Both filings go through the CAA Producer Portal. CAA refers to Colorado fees as “Dues” rather than “Fees” — same thing, different label:
- Go to circularactionalliance.org/producer-resource-center
- Create a producer account (if not registered — registration deadline was October 1, 2024)
- Select Colorado as a covered state
- Complete the Annual Supply Report — enter weight by material category in pounds
- Complete the PCR Content Report — enter PCR weight and percentage for each component
- Include your revenue allocation methodology
- Submit both before May 31, 2026
Filing checklist
Annual Supply Report
- Confirm you exceed the exemption threshold (~$5.5M global revenue OR 1 ton into CO)
- Inventory all consumer-facing packaging components per SKU (B2C only — B2B is exempt)
- Assign each component to a Colorado material category (~61 categories)
- Calculate weight per component per unit (grams → pounds)
- Calculate national totals × Colorado revenue percentage for each category
- Enter data in CAA portal under Colorado Annual Supply Report
PCR Content Report
- Request PCR content certifications from packaging suppliers
- For each component: record total weight, PCR weight, and PCR percentage
- Verify compliance with HB 21-1162 minimums (15% for rigid beverage containers, 10% for trash bags, 20% for carryout bags)
- Document verification method (supplier cert, third-party audit, etc.)
- Enter PCR data in CAA portal under Colorado PCR Content Report
Final steps
- Claim eco-modulation credits where available (CO: Recycling Bonus -5% for high-recycling-rate materials; future active incentives TBD)
- Submit both reports before May 31, 2026
Official resources: CAA Colorado Portal · CDPHE EPR Program · CAA Producer Resource Center · EPR Fee Check — Colorado