Colorado EPR Guide
Producer Responsibility Program for Statewide Recycling Act (HB 22-1355, 2022)
Who is a “producer”?
Under HB 22-1355, a “producer” is determined in the following order of responsibility:
- 1Brand owner of the product sold in packaging in CO
- 2Licensee who sells under another's brand
- 3Importer of record for sale in CO
- 4Person who first distributes the item in or into CO
B2B packaging is explicitly exempt in Colorado.
What's covered
Covered
- ✓Consumer-facing packaging
- ✓Printed paper / writing paper
- ✓Food service ware
- ✓Consumer-facing shipping packaging (B2C)
Not Covered / Exempt
- ✕Small producers (<$5.5M global revenue OR <1 ton of covered materials)
- ✕Commercial transport packaging (B2B)
- ✕Beverage containers under CO bottle bill
Key Deadlines
| Date | What's Due | Status |
|---|---|---|
| Oct 1, 2024 | Producer registration deadline | PASSED |
| Jul 31, 2025 | Annual Supply Report (CY 2024 data) | PASSED |
| Jan 1, 2026 | First fees due | PASSED |
| May 31, 2026 | Annual Supply Report (CY 2025 data) + Mandatory PCR reporting | PASSED |
| Jan 1, 2027 | Ongoing fee invoices | FUTURE |
| May 31, 2027 | Annual Supply Report (CY 2026 data) | FUTURE |
| Jul 1, 2027 | Ongoing fee invoices | FUTURE |
Fee Rates (Colorado)
Published fee rates per pound of packaging material. Ranges reflect the spread across CAA material categories within each group.
Simplified groupings for estimation. Official CAA schedules have 60–95 material categories — see the downloadable rate schedule PDF below for exact rates by material type.
| Material | Rate ($/lb) |
|---|---|
| Recyclable rigid plastic (PET, HDPE, PP) | $0.14 – $0.32 |
| Non-recyclable rigid plastic (PS, PVC, mixed) | $0.43 – $1.72 |
| Recyclable flexible plastic (HDPE/LDPE film) | $0.48 |
| Non-recyclable flexible plastic (PP film, laminates, mixed film) | $0.64 – $0.74 |
| Paper/Fiber (printed) | $0.06 |
| Paper/Fiber (packaging) | $0.08 – $0.30 |
| Glass bottles and jars | $0.04 |
| Aluminum (containers, foil, other) | $0.02 – $0.34 |
| Steel/tin (containers, other) | $0.07 – $0.34 |
✓ Published rates. Download official rate schedule (PDF) →
Calculate Your Colorado Fees →Flat Fee Option
Optional flat rate for low-volume producers (≤10 short tons/year). Does not vary by material category — pays one annual fee regardless of material mix.
| Annual Supply (short tons) | Flat Fee |
|---|---|
| 1 – 2.5 short tons | $800 |
| 2.5 – 5 short tons | $1,600 |
| 5 – 7.5 short tons | $2,600 |
| 7.5 – 10 short tons | $3,600 |
When does the flat fee save money? At 2.5 short tons (5,000 lbs) with an average rate of $0.20/lb, per-pound dues would be $1,000 — but the flat fee is only $800, saving $200. Producers with predominantly paper/fiber packaging (low per-lb rates) may pay less per-pound than the flat fee.
Eco-Modulation Factors
Credits (reduce fees)
Applied to materials with high recycling rates (shown as Recycling Bonus in fee schedule)
Four active eco-modulation incentives to be published by CAA; may include PCR, standardized packaging, and label credits
Maluses (increase fees)
Automatically applied to materials that disrupt recycling processes
AML materials priced at least 20% higher than similar MRL materials; N/C materials at least 10% higher than similar AML
Official Resources
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