Short answer: Colorado's packaging EPR program, created by HB 22-1355, requires producers of covered materials to participate through Circular Action Alliance, report data and pay dues. Since July 2025, producers cannot sell or distribute products using covered materials in Colorado unless they participate, and dues on covered materials are owed beginning January 2026 and each year after.
What the program is
Governor Polis signed the Producer Responsibility Program for Statewide Recycling Act (HB 22-1355) in 2022. The Colorado Department of Public Health and Environment (CDPHE) oversees the program, and Circular Action Alliance (CAA) operates it as the Producer Responsibility Organization.
Program facts
Current status, as published by CDPHE
- CDPHE appointed CAA as the designated Producer Responsibility Organization in May 2023.
- A statewide needs assessment was completed in 2023.
- CDPHE's executive director approved the CAA program plan in 2025, and CAA must begin implementing it by summer 2026.
- As of July 2025, a producer cannot sell or distribute products using covered materials in Colorado unless it participates in the program.
- Producers must pay dues on covered materials in January 2026 and each year after.
- In November 2025, the Solid and Hazardous Waste Commission approved final Section 18 regulations, including eco-modulation.
- CDPHE projects the paper and packaging recycling rate rising from 25% to 58% by 2035.
Producer obligation concepts
Colorado uses a producer hierarchy similar in spirit to other states: obligations generally attach to the brand owner, with defined fallbacks. A producer participates by registering with CAA, submitting supply reports and paying dues based on the covered materials it supplies into the state.
The program includes an exemption based on an inflation-adjusted dollar threshold. CDPHE has indicated it is proposing rule changes to adjust that threshold, so confirm the current figure directly with CDPHE before relying on it.
Colorado also runs a separate program for automotive lubricants packaging (Interchange 360). Some producers may need to register and report with both.
Dues and eco-modulation
Dues are calculated from the covered materials a producer reports. Colorado's regulations include eco-modulation, which adjusts dues to reflect packaging attributes such as recyclability. That makes accurate material classification financially meaningful: a component misclassified into a higher-cost category raises dues, and an unsupported favorable classification creates risk. See how EPR fees work.
Data preparation
Colorado reporting draws on the same three inputs as other programs: units supplied into Colorado, component-level packaging data, and mapping to CAA's material categories. If you already report in Oregon, much of the packaging foundation can be reused, with state-specific allocation and category mapping.
CertaRelay recommendation
Build Colorado and Oregon reporting from the same packaging records. Differences between states should come from allocation and category rules, not from two different versions of what your packaging weighs.
Recurring reporting
Because dues are annual, Colorado reporting is a recurring cycle. Keep SKU launches, discontinuations and packaging changes logged with effective dates so each year's data reflects what was actually supplied.
What your team should prepare
- Units supplied into Colorado by SKU for the relevant data year.
- Component-level packaging specifications with materials and weights.
- CAA registration status and any prior Colorado supply reports.
- Revenue information needed to evaluate the small producer threshold.
- Whether any products fall under the separate automotive lubricants program.
How CertaRelay helps
- Screen Colorado obligations and threshold questions for counsel.
- Reuse and extend your packaging foundation for Colorado-specific allocation and categories.
- Prepare filing-ready supply reports and track the annual dues cycle.
- Model the effect of eco-modulation and packaging changes on dues.