Colorado Producer Responsibility Program: Rules, Fees, and Registration Steps
Colorado's Producer Responsibility Program is the next US packaging EPR program coming into force after Oregon. Here is what it covers, how registration works through Circular Action Alliance, and what to do in 2026.
By Kevin Kai Wong, Managing Partner at gCurv Technologies
April 1, 202610 min read
What the Colorado program does
Colorado's Producer Responsibility Program for Statewide Recycling, established under HB22-1355, is one of the next US packaging EPR programs to come online after Oregon. It moves the cost of managing covered packaging away from Colorado ratepayers and onto producers who place that material on the Colorado market. Implementation is run through Circular Action Alliance (CAA), the same PRO that runs California, Minnesota, Maryland, and several other state programs.
For producers already registered with CAA for one US state, the Colorado registration is an extension of an existing relationship rather than a new PRO setup.
Who is a producer in Colorado
The Colorado producer test follows the same hierarchy as other US programs:
1. The brand owner with US operations. 2. If no US brand owner, the importer of record. 3. If neither, the distributor or seller first placing goods on the Colorado market.
Marketplaces and online platforms can be deemed producers when no upstream entity qualifies. Small-producer thresholds apply; consult Colorado's current published rule before assuming exemption.
What Colorado covers
Colorado covers packaging in all three layers and certain paper products. The sweep includes:
- Primary, secondary, and tertiary packaging.
- Paper products including direct mail and printed paper (consult Colorado's current published rule for scope).
- Single-use food serviceware (consult Colorado's current published rule for scope).
Out of scope: durable, reusable transport packaging; certain medical packaging; and a small number of statutory carve-outs.
How Colorado fees work
Colorado fees are set and collected by Circular Action Alliance using the same general framework as other CAA states:
- Base rates per material category calibrated to the cost of recovery in Colorado.
- Eco-modulation rewarding PCR content and recyclable design, penalizing design contaminants.
- Annual reconciliation between reported and audited volumes.
Producers who already model fees for California through CAA can extend the model to Colorado on the same dataset; the major variable is the Colorado-specific rate sheet and the volume share attributable to Colorado.
Registration steps
For a producer not yet registered with CAA, the Colorado registration sequence is:
1. Determine your producer status under the hierarchy above. 2. Establish a CAA membership if you do not have one. 3. Submit registration data: legal entity, contacts, brand list, material categories, indicative Colorado volume. 4. Schedule the first data submission cycle. 5. Maintain an audit trail for all submitted data.
For producers already registered with CAA for California or other states, Colorado is added as an additional state on the existing membership rather than a new registration from scratch.
What "compliant" looks like in Colorado
The same six-piece operating model that California and Oregon require applies to Colorado:
1. Registered producer entity, CAA membership. 2. SKU-level dataset tagged for Colorado-bound volume. 3. State-attribution methodology. 4. Audit trail for PCR and recyclability claims. 5. Change-control on packaging redesigns. 6. Budgeted fee line that scales.
For a multi-state side-by-side, see Maine, Oregon & Colorado EPR Compared and EPR Laws in the US: State Regulations 2026.
How Packgine helps
Packgine extends the same SKU-level dataset and fee model that drives California and Oregon compliance into Colorado, applying CAA's Colorado-specific rate sheet and modulation curves and producing the submission package CAA expects. One data investment, multi-state output.
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