Colorado

Producer Responsibility Program for Statewide Recycling Act (HB 22-1355, 2022)

Active — Fees Due

PRO

Circular Action Alliance

Agency

CDPHE

Exemption

Under ~$5.5M global gross revenue OR less than 1 ton of covered materials

Fees

Published rates — varies significantly by material category

Material Categories

Penalties

$5,000 + $1,500/day (1st offense); $10,000 + $3,000/day (2nd); $20,000 + $6,000/day (3rd+). Non-compliance can restrict selling in CO.

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
Jul 31, 2025	Producer registration deadline	PASSED
May 31, 2026	Annual Supply Report (2025 data) + Mandatory PCR reporting	URGENT
Jan 1, 2026	First fees due	PASSED
Jan 1, 2027	Ongoing fee invoices	FUTURE
Jul 1, 2027	Ongoing fee invoices	FUTURE

Fee Rates (Colorado)

Published fee rates per pound of packaging material.

Simplified rate groupings for estimation. Official CAA categories are more granular (60–95 categories). See your state’s Producer Responsibility Organization for the complete rate schedule.

Material	Low ($/lb)	High ($/lb)
Readily recyclable plastic (PET, HDPE, PP)	$0.04	$0.10
Non-recyclable plastic (PS, PVC, multi-layer)	$0.17	$0.34
Paper/Fiber (corrugated)	$0.01	$0.04
Paper/Fiber (paperboard)	$0.02	$0.06
Glass	$0.01	$0.04
Aluminum	$0.01	$0.02
Steel	$0.02	$0.05

Calculate Your Colorado Fees →

Eco-Modulation Factors

Credits (reduce fees)

Mono-material (recyclable)-10% to -20%

Switch from multi-material to single-material recyclable formats

High PCR content (>30%)-5% to -15%

Post-consumer recycled content reduces fees

Standardized packaging-5%

Industry-standard sizes and formats

Consumer recycling label-3% to -5%

Clear recycling instructions on packaging

Maluses (increase fees)

Multi-material / non-recyclable+15% to +30%

Hard-to-recycle composites increase fees

Contaminants+10% to +20%

Dark plastic, additives, and other contaminants

Official Resources

CDPHEcdphe.colorado.gov/hm/epr-program CAA Colorado Portalcircularactionalliance.org/circular-action-alliance-colorado

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