States · CO
Colorado packaging EPR
Producer Responsibility Program for Statewide Recycling Act (HB22-1355). Facts last checked October 31, 2026.
The short answer
Colorado requires producers of covered packaging and paper products to join Circular Action Alliance (CAA), which funds and runs recycling across the state. Producers report annually to CAA and have paid dues since January 2026.
| Law | HB22-1355, signed June 3, 2022 |
|---|---|
| State agency | CDPHE |
| Producer responsibility organization | CAA, selected by CDPHE May 1, 2023; final plan approved December 9, 2025 |
| Registration deadline | October 1, 2024 (regulatory deadline to register with CAA) |
| 2026 report | Annual supply report on 2025 data, due May 31, 2026 |
| Next report | Annual supply report on 2026 data, due to CAA by May 31, 2027 |
| Fees | Dues to CAA from January 2026 |
| Small-producer exemption | Set in the Act; CDPHE adjusts the threshold for inflation each July 1 |
Worth knowing
- Colorado offers optional eco-modulation bonuses, submitted separately from the main report.
Who counts as a producer in Colorado?
Usually the brand owner of the packaged product. Where there is no brand owner in the state’s chain, the definitions move to the licensee, importer or first distributor, and retailers are producers for their private-label goods. Each state’s law defines it a little differently, and CAA publishes producer-definition guidance for each state. You decide whether you’re a producer, with your counsel if you like; our free EPR Check lays the rule text next to your figures.
Sources
We summarize public sources and may miss a later change. This is general information, not legal advice.