Colorado's Packaging Producer Responsibility Program: Producers Must Participate as of July 2025

Colorado's packaging EPR law, formally the Producer Responsibility Program for Statewide Recycling Act (HB 22-1355), was signed in 2022 and is now in active compliance. Producers selling packaging and paper products into Colorado are required to participate in the program and pay annual dues.

Administering Agency

The Colorado Department of Public Health and Environment (CDPHE) administers the program.

Producer Responsibility Organizations

Two PROs serve different material categories under the Colorado program:

Circular Action Alliance (CAA) — appointed May 2023 for packaging and paper products. CAA's program plan was approved by CDPHE in December 2025.

Interchange 360 — for automotive lubricant packaging (motor oil containers, antifreeze containers). This program launched in March 2026 and operates separately from the main packaging program.

What's Required Now

As of July 2025, producers cannot sell or distribute products using covered materials in Colorado without participating in the Producer Responsibility Program.

The first annual producer dues were due January 2026.

Fees are eco-modulated, meaning producers pay more for less recyclable packaging and less for sustainable materials. The structure incentivizes packaging redesign toward materials that qualify under the program's recyclability standards.

Final eco-modulation regulations were adopted in November 2025.

Program Goals

The program targets an increase in Colorado's recycling rate from approximately 25% to 58% by 2035. A specific operational goal is providing no-cost curbside recycling access to 700,000 additional Colorado households over the program's buildout phase.

Who the Program Applies To

Covered producers include:

- Brand owners selling packaging and paper products into Colorado - Manufacturers of covered materials sold in Colorado - Importers of finished goods packaged in covered materials

A small producer exemption applies. The threshold is adjusted annually for inflation.

Compliance for Multi-State Operators

For producers selling into Colorado as part of a broader U.S. footprint, Colorado is now one of several states with active or imminent packaging EPR programs. Coordinating registration, reporting, and fee payments across multiple state programs requires consolidated material stream documentation that can be sliced by jurisdiction.

How ICTV Helps

ICTV provides material stream documentation that supports producer compliance claims under Colorado's program. Diversion data and recovery pathway documentation are structured in formats compatible with CAA's reporting requirements and can be aggregated across multiple state EPR programs for producers with multi-state exposure.

For operations downstream of producers, ICTV provides commercial recycling and diversion services that align with Colorado's recycling rate goals and support producer claims of achieved recovery rates.