What eco-modulation factors has Colorado published?

Colorado's 2026 Dues Schedule includes three passive eco-modulation factors: Detriments malus +5% for materials disrupting recycling, Not-on-MRL pricing tiers (materials not on the Minimum Recyclable List pay higher base rates), and High Recycling Rate Bonus −5% for materials with proven high recycling rates. Four active incentives are still TBD.

Does Oregon have eco-modulation credits?

Oregon's eco-modulation has no defined fee adjustments — reductions are factored into fees based on environmental performance and impact. Qualifying activities: increasing PCR content, reusable packaging, and moving to lower-impact materials. The SIM portion is 0.0 ¢/lb for 2026 but likely to increase in future years. Oregon's base fee rates already reflect recyclability — non-recyclable materials cost 64–84% more per pound than recyclable ones.

Do Prop 65 chemicals in packaging affect EPR fees?

California's SB 54 is expected to include a malus for Prop 65 chemicals in packaging, but the specific surcharge percentages have not yet been published by CAA (expected Oct 2026). Removing these chemicals now prepares you for when the malus takes effect.

EPR Fee Check

Fee Reduction

How to Reduce EPR Fees — 7 Strategies

Q: What does design for recyclability mean?

Design for recyclability means removing problematic laminations, foils, adhesives, and coatings that push packaging into non-recyclable categories. Multi-material composites (plastic + foil + paper) are classified as non-recyclable and pay the highest rates. Even small design changes — like switching to water-based adhesives or replacing foil lamination — can shift a package from non-recyclable to recyclable.

Q: Does increasing PCR content reduce EPR fees?

Yes. Higher PCR content shifts packaging into lower-rate recyclable categories and supports impact-reduction claims. In Colorado, materials with proven high recycling rates qualify for a −5% High Recycling Rate Bonus. In Oregon, PCR increases are a qualifying activity under environmental performance incentives. Increasing PCR now also future-proofs packaging for upcoming state programs.

EPR fees are eco-modulated — non-recyclable materials cost 2–5× more per pound than recyclable ones. Material selection has the biggest financial impact, more than any credit or bonus. Here are 7 strategies ranked by savings.

These strategies are ranked by estimated impact, starting with the biggest savings.

Material selection — pick a lower-fee category

55–81%

Switching from a high-fee material category to a lower-fee category saves more than any eco-modulation bonus. Non-recyclable materials cost 2–5× more per pound than recyclable ones. Switching to recyclable rigid plastic saves 55–81% (CO: 67–81%, OR: 64–84%, CA: 35–73%).

How to implement

▸Audit your packaging portfolio — identify every SKU in a high-fee category
▸Prioritize high-volume products first — small changes at scale have the biggest impact
▸Work with your supplier on mono-material alternatives for multi-material SKUs
▸Test for product compatibility before switching

Applies to: All states with active fees (CA, OR, CO) — rate structure rewards recyclability

Design for recyclability

Category shift

Remove problematic laminations, foils, adhesives, and coatings that push packaging into non-recyclable categories. Multi-material composites (plastic + foil + paper) are classified as non-recyclable and pay the highest rates. Even small design changes can shift a package from non-recyclable to recyclable — dropping the per-pound rate dramatically.

How to implement

▸Identify laminated, coated, or multi-layer SKUs in your portfolio
▸Replace foil lamination with mono-material alternatives where possible
▸Switch to water-based adhesives and coatings that don't contaminate recycling streams
▸Standardize to industry-standard formats that stay on the MRL (Minimum Recyclable List)
▸Validate with your recycler that the redesigned format is actually recyclable

Applies to: All states with active fees — especially CO (MRL pricing tiers apply)

Lightweight your packaging

1:1 direct

EPR fees are calculated per pound of packaging material. Less weight = fewer pounds reported = lower fees. A 10% weight reduction = 10% fee reduction. No eco-modulation needed — it's a direct 1:1 savings that applies in every state.

How to implement

▸Identify over-packaged SKUs (excess void fill, oversized boxes, heavy closures)
▸Test lighter-weight alternatives without sacrificing product protection
▸Focus on heaviest materials first (glass, steel, corrugated)
▸Even small per-unit reductions compound across thousands of SKUs

Applies to: All states

Increase PCR content

Future-proofs + CO: −5%

Higher post-consumer recycled (PCR) content shifts packaging into lower-rate recyclable categories and supports impact-reduction claims. In Colorado, materials with proven high recycling rates qualify for a −5% High Recycling Rate Bonus. In Oregon, PCR increases are a qualifying activity under environmental performance incentives. Increasing PCR now future-proofs your packaging for upcoming state programs.

How to implement

▸Check if your packaging materials are on the CAA Minimum Recyclable List
▸Use materials with documented high recycling rates (PET, HDPE, corrugated)
▸Set PCR targets — even 10% PCR content can improve category classification
▸Document recycling rates and PCR percentages for CAA reporting

Applies to: CO: −5% High Recycling Rate Bonus published | OR: qualifying activity under environmental performance | CA: anticipated with program plan Oct 2026

Reuse & refill systems

Potentially largest incentive

Potentially the largest eco-modulation incentive, but also the most difficult to implement. Oregon's approved program rewards transitions from single-use packaging to reusable/refillable systems. California requires at least 10% of source reduction from reuse/refill or elimination. Best suited for high-volume SKUs where infrastructure investment pays off.

How to implement

▸Identify high-volume SKUs where reuse/refill is feasible (household products, beverages, CPG)
▸Start with pilot programs at key retailers rather than full rollout
▸Design for durability — reusable packaging must survive multiple trips
▸Track return/refill rates for CAA reporting and eco-modulation qualification
▸California requires a written Source Reduction Plan — reuse/refill counts toward the 10% minimum

Applies to: OR: qualifying activity for environmental performance incentives | CA: counts toward source reduction mandate | CO: active incentives still TBD

Avoid Detriments malus (Colorado)

+5% avoided

Colorado's published dues schedule includes a Detriments malus of +5% — an automatic surcharge on materials that disrupt recycling processes (like PVC, certain additives). Avoiding these materials dodges the surcharge on top of the already-higher non-recyclable base rate.

How to implement

▸Check the CAA Detriments list for materials you use
▸Audit packaging for PVC, contaminating additives, and flagged materials
▸Work with suppliers to replace detriment materials
▸Document material changes for CAA reporting

Applies to: Colorado (published) | CA & OR: not yet published

Avoid Prop 65 chemicals (California)

TBD

California's SB 54 is expected to include a malus for packaging containing Proposition 65 chemicals (PFAS, vinyl, etc.). The specific surcharge has not yet been published by CAA — expected with the program plan in Oct 2026. Removing these chemicals now prepares you for when it takes effect.

How to implement

▸Audit all packaging materials for Prop 65 listed chemicals
▸Focus on inks, adhesives, and plasticizers first — these are the most common sources
▸Work with suppliers to find alternative formulations
▸Document all changes for CAA reporting

Applies to: California only (specific malus TBD)

See your potential savings

Use the fee calculator to see exactly how much recyclable vs. non-recyclable materials cost in each state.

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