Colorado's Producer Responsibility for Recycling Act (HB 22-1355) creates a statewide packaging EPR program requiring producers to fund the collection, transportation, and recycling of packaging and paper products. The program is overseen by the Colorado Department of Public Health and Environment (CDPHE) and administered through the state's designated Producer Responsibility Organization, Circular Action Alliance (CAA). Colorado's program is notable for its emphasis on expanding recycling access to rural and underserved communities and establishing needs assessments to identify infrastructure gaps across the state. Key deadlines have already taken effect: producers were required to register with CAA by October 1, 2024; beginning July 2025, producers not participating in the program may no longer sell or distribute covered products in Colorado; and producers were required to report supply data to CAA by July 31, 2025 to comply with Colorado's packaging EPR law. Following CDPHE's approval of CAA's final program plan on December 9, 2025, producers were required to remit first dues to CAA on or before January 1, 2026. Both deadlines have passed as of August 22, 2026.
By Kevin Kai Wong, Managing Partner, gCurv Technologies
Packgine automates Colorado EPR registration tracking, data reporting, fee calculation, and deadline management alongside all other US state and EU obligations.
Packaging and paper products producers register with Circular Action Alliance (CAA), the state-designated PRO. Applicable automotive lubricant packaging requires registration through Interchange 360's approved individual program plan; some producers need both.
Fees are calculated based on packaging material type, weight, and recyclability, with eco-modulation incentives for sustainable formats.
Producers report packaging data through the applicable program: CAA for packaging and paper products, and Interchange 360's approved individual program plan for applicable automotive lubricant packaging. Some producers must report through both.
Fees fund recycling infrastructure expansion in rural and underserved communities as part of the statewide needs assessment.
Phased minimum recycled content requirements for certain packaging types increase over time to stimulate demand for recycled materials.
Colorado's Producer Responsibility Program for Statewide Recycling, established under HB22-1355, shifts the cost of managing covered packaging from Colorado ratepayers onto the producers placing that material on the Colorado market. Implementation runs through Circular Action Alliance, the same PRO administering California, Minnesota, Maryland, and several other state programs, so for producers already registered with CAA elsewhere Colorado is an extension of an existing relationship rather than a new PRO setup.
The hierarchy matches other US programs: the brand owner with US operations first, then the importer of record where no US brand owner exists, then the distributor or seller first placing goods on the Colorado market. Marketplaces and online platforms can be deemed producers when no upstream entity qualifies, and small-producer thresholds apply, so check the current published rule before assuming an exemption.
Colorado covers packaging across all three layers along with certain paper products, including printed paper and direct mail, and single-use food serviceware. Durable reusable transport packaging, certain medical packaging, and a small number of statutory carve-outs sit outside scope. Confirm edge cases against the current published rule before final filings.
Circular Action Alliance sets and collects Colorado fees on the familiar framework: base rates per material category calibrated to the cost of recovery in Colorado, eco-modulation rewarding PCR content and recyclable design while penalizing design contaminants, and annual reconciliation between reported and audited volumes. Producers who already model California fees through CAA can extend the same dataset to Colorado; the variables are the Colorado rate sheet and the volume share attributable to Colorado.
A producer new to CAA determines producer status, establishes membership, submits registration data covering legal entity, contacts, brand list, material categories, and indicative Colorado volume, schedules the first data submission cycle, and maintains an audit trail for everything submitted. Producers already registered for California or another CAA state add Colorado to the existing membership for materials in CAA's program. Applicable automotive lubricant packaging also requires registration and reporting through Interchange 360's approved individual program plan; some producers need both programs.
Operationally, compliant means six things in place: a producer entity registered with the applicable program or programs, a SKU-level dataset tagged for Colorado-bound volume, a defensible state-attribution methodology, an audit trail for PCR and recyclability claims, change control on packaging redesigns, and a budgeted fee line that scales with volume.
Every Packgine article covering Colorado packaging rules, from producer scope to reporting mechanics.
Colorado's law sits in the middle of the national picture: later than the first wave, earlier than the states still drafting rules. Our US state EPR overview shows how its registration and reporting duties line up with the rest of the country.
For direct comparison, Oregon's Recycling Modernization Act follows a similar eco-modulated fee approach, while Minnesota's producer responsibility law borrows much of Colorado's structure with a later phase-in.
Put Colorado reporting dates in context with your other obligations, and connect your ERP and PLM data so material weights flow into each report without manual rekeying.
Determines producer coverage status based on Colorado market sales data
Tracks CAA registration status and alerts for renewal deadlines
Maps SKU-level packaging data to Colorado's material classification system
Calculates projected fees using current CAA eco-modulation rate schedules
Generates Colorado-formatted reports ready for CAA submission
Monitors Colorado EPR deadlines alongside all other jurisdictions in a unified calendar
A producer is defined as a brand owner whose product is sold in packaging in Colorado, or an importer of packaged goods if the brand owner is outside the U.S. The law also covers producers of paper products like newspapers and direct mail.
Colorado designated Circular Action Alliance (CAA) as the single Producer Responsibility Organization to administer the program. CAA handles registration, fees, and reporting for packaging and paper products. Producers of applicable automotive lubricant packaging must register and report through Interchange 360's approved individual program plan; depending on their covered materials, some producers need both programs.
Fees are based on the weight and type of packaging material placed on the Colorado market. Eco-modulation adjustments lower fees for easily recyclable materials and increase fees for hard-to-recycle formats.
Colorado places strong emphasis on equitable recycling access, requiring the PRO to fund infrastructure in rural and underserved communities. The program includes a comprehensive statewide needs assessment to identify gaps.
Yes. Packgine manages Colorado EPR compliance simultaneously with all other US state programs and EU PPWR obligations from a single dashboard.
The Colorado Department of Public Health and Environment (CDPHE) enforces the program. For covered producers, failing to participate through the applicable program or missing required packaging reports can trigger enforcement. CAA administers the statewide PRO program, while Interchange 360 administers an approved individual program plan for applicable automotive lubricant packaging; CDPHE is the state oversight authority.
Content reviewed by Kevin Kai Wong, Managing Partner at gCurv Technologies
Manage Colorado packaging EPR alongside all other US states and EU markets from one platform.