Materials covered
- Single-use packaging (plastic, glass, metal, paper, multi-material)
- Paper products (newspaper, magazines, office paper)
- Cosmetic packaging (primary and secondary)
Packaging EPRCO
Colorado packaging producer responsibility
HB22-1355 — Producer Responsibility Program for Statewide Recycling (2022)
Colorado's Producer Responsibility Program for Statewide Recycling (HB22-1355, 2022) requires producers of packaging and paper products to fund a statewide recycling program through a Producer Responsibility Organization. CDPHE appointed Circular Action Alliance as the PRO in May 2023 and approved its program plan in December 2025. Producers pay dues on covered materials, starting January 2026, and report supply data to CAA every year.
Last updated:
- Producer Responsibility Organization
- Circular Action Alliance (CAA)
Who is a producer in Colorado?
The brand owner of a product placed in covered packaging. Small producers under $5M in annual gross revenue (or under 1 ton of covered material annually) are exempt.
Producer obligations
- Join Circular Action Alliance, the designated PRO
- Report packaging and paper supply data to CAA every year; the 2026 report, on calendar-year 2025 data, was due May 31, 2026
- Pay producer responsibility dues on covered materials, starting January 2026 and every year after
- Keep records that document compliance with the law
Compliance timeline
- Active
CAA appointed as PRO
CDPHE appointed Circular Action Alliance as Colorado's Producer Responsibility Organization.
- Active
Program plan approved
CDPHE approved CAA's program plan for the statewide recycling program.
- Fees begin
Producer dues begin
Producers pay producer responsibility dues on covered materials, and every year after.
- Reporting begins
Annual supply report
Producers' 2026 supply report to CAA, on calendar-year 2025 data.
- Active
Program implementation
CAA must begin implementing the approved program plan.
How Cosmetica helps
Cosmetica coverage for Colorado
Cosmetica builds Colorado's CAA supply workbook, including the post-consumer recycled content sheet, from your packaging BOMs and per-state sales, and marks every packaging weight that is an estimate. It does not calculate dues.
Primary sources
EPR statutes and rules are evolving. Verify the latest dates, fee schedules, and de minimis thresholds with the state agency before relying on this summary for compliance decisions.