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Colorado EPR Guide

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

Active — Fees Due
PRO
Circular Action Alliance
Agency
CDPHE
Exemption
Under $5M realized gross revenue (excl. on-premises alcohol sales; CPI-adjusted annually each Jul 1) OR less than 1 ton of covered materials (C.R.S. 25-17-713)
Fees
2027 dues schedule published Oct 1, 2026 — dues rise on 44 of 61 material categories (median increase ~14%). EPS foam reaches ~$2.09/lb. Passive eco-modulation: Detriments +5%, Not-on-MRL pricing tiers, High Recycling Rate Bonus −5%; CDPHE bonus benchmarks guidance due by Oct 1, 2026.
Material Categories
61
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:

  1. 1Brand owner of the product sold in packaging in CO
  2. 2Licensee who sells under another's brand
  3. 3Importer of record for sale in CO
  4. 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 (<$5M realized gross revenue, CPI-adjusted, OR <1 ton of covered materials)
  • ✕Commercial transport packaging (B2B)

Colorado does not currently have an active bottle bill / beverage container deposit-law exclusion.

Fee Rates (Colorado)

Simplified groupings for estimation. The official CAA schedule has 61 material categories — see the downloadable rate schedule PDF below for exact rates by material type.

MaterialRate ($/lb)
Recyclable rigid plastic (PET, HDPE, PP)$0.18 – $0.27
Non-recyclable rigid plastic (PS, PVC, mixed)$0.66 – $2.09
Recyclable flexible plastic (HDPE/LDPE film)$0.62
Non-recyclable flexible plastic (PP film, laminates, mixed film)$0.69 – $0.78
Paper/Fiber (corrugated cardboard)$0.10
Paper/Fiber (paperboard, printed & packaging)$0.09 – $0.36
Glass bottles and jars$0.05
Aluminum (containers, foil, other)$0.05 – $0.39
Steel/tin (containers, other)$0.11 – $0.41

✓ 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. Updated for 2027.

Annual Supply (short tons)Flat Fee
1 – 2.5 short tons$900
2.5 – 5 short tons$1,800
5 – 7.5 short tons$2,900
7.5 – 10 short tons$4,100

When does the flat fee save money? At 2.5 short tons (5,000 lbs) with an average 2027 dues rate of $0.36/lb, per-pound dues would be ~$1,800 — equal to the $1,800 flat fee. Producers with predominantly paper/fiber or MRL metals (low dues rates) may pay less per-pound than the flat fee.

Eco-Modulation Factors

Credits (reduce fees)

High recycling rate bonus-5%

Applied to materials with high recycling rates (shown as Recycling Bonus in fee schedule)

Active incentives (4 factors)TBD

Four active eco-modulation incentives to be published by CAA; may include PCR, standardized packaging, and label credits

Maluses (increase fees)

Detriments malus+5%

Automatically applied to materials that disrupt recycling processes

Not on MRL malus≥20% above MRL

AML materials priced at least 20% higher than similar MRL materials; N/C materials at least 10% higher than similar AML

Key Deadlines

DateWhat's DueStatus
Oct 1, 2024Producer registration deadlinePASSED
Jul 31, 2025Annual Supply Report (CY 2024 data)PASSED
Jan 1, 2026First fees duePASSED
May 31, 2026Annual Supply Report (CY 2025 data) + Mandatory PCR reportingPASSED
Jul 30, 2026Second 50% installment due for 2026 Program Year dues (based on CY 2024 data)PASSED
Jan 1, 2027Ongoing fee invoicesFUTURE
May 31, 2027Annual Supply Report (CY 2026 data)FUTURE
Jul 1, 2027Ongoing fee invoicesFUTURE

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