Colorado packaging EPR fees 2026

Colorado's dues come from HB22-1355, codified at C.R.S. 25-17-701 to 25-17-716 and tracked as PR-US-003³. The Act names the producer by a cascade in section 25-17-703(30): the brand-owning manufacturer or brand licensee first, then the importer where no such party is in the US, the publisher for magazines, newspapers and catalogues, the packer or shipper for e-commerce shipping materials, and otherwise whoever first distributes the covered material into the state³. Section 25-17-713 exempts producers with less than $5 million of gross revenue in the prior year, a figure the Commission indexes annually, and those using under one ton of covered materials³.

CDPHE appointed Circular Action Alliance (CAA) as the producer responsibility organisation, and its executive director approved CAA's programme plan in December 2025². Since July 2025 a producer outside the programme may not sell products in covered materials in Colorado, and dues have been payable since January 2026². When CAA submitted its first plan proposal on 3 February 2025 it projected access for up to 700,000 more households and a near doubling of recycling rates for paper and packaging⁵.

The statute fixes what dues pay for. Reimbursement to service providers must cover 100% of their net recycling services costs, administration may take no more than 5% of dues, surpluses must go back into the programme or lower dues, and the organisation must hold a financial reserve (section 25-17-705(4)(i) and (j))³. CDPHE adds that the plan funds infrastructure, end markets, performance targets and public education².

Dues must vary by type of covered material and by whether it is readily recyclable, and must rest on the net cost of recycling services for each material (section 25-17-705(4)(i))³. CAA's 2026 schedule, published on 13 October 2025, lists base dues per material in US cents per pound and then applies passive eco-modulation automatically to the final figure, as state law requires¹. The live rows on this page are those final figures converted to US dollars per metric tonne.

The Act also obliges the organisation to report each year a schedule of dues by weight for every covered material, the total collected and the reasons for changes, and to commission an independent annual financial audit (sections 25-17-708(5) and 25-17-709(2))³. The executive director had to produce an eco-modulation bonus schedule by 1 January 2026 and must revisit it every year³.

SPI calculation: 73 tonnes of packaging owe USD 24,339.16 in 2026 dues¹. The film is 4.1% of the weight and 13.0% of the bill, because flexible film is on the Additional Material List at 48.0 cents per pound against 14.0 cents for the jugs.

The jugs already include the 5% high recycling rate bonus. If the dairy used pigmented HDPE jugs instead, CAA's schedule prices them at 23.0 cents per pound, which on the same 50 tonnes would mean roughly USD 25,350 rather than USD 15,432.50 (SPI conversion, 2,204.62 pounds per tonne)¹. Any active incentive for recycled content would come off later through the portal and is not shown here.

Most Colorado dates come from the Act and from CAA's own notices; CDPHE sets the annual exemption adjustment¹³⁴.

There is no earlier Colorado schedule to compare: 2026 is the first year in which dues were payable²³. The 2026 figures were built from base dues per material with the passive eco-modulation factors already applied, which is the basis any later schedule will follow under section 25-17-705(4)(i)¹³.

The Act requires CAA to report the dues schedule each year with the reasons for any change, so the first year-on-year comparison will come with the next annual schedule³. SPI has not yet confirmed a 2027 Colorado schedule, and CDPHE is also consulting on a change to the small producer revenue threshold, discussed with partners on 6 April 2026, which could change who pays².