Colorado Packaging EPR Law

Producers of covered packaging and paper sold into Colorado must join Circular Action Alliance, the approved producer responsibility organization, report supply data, and pay producer responsibility dues, which began in January 2026. Dues vary by material, with higher rates for materials not on the state's minimum recyclability list. Statewide program implementation began in 2026 under a plan covering 2026 to 2030. Businesses below an inflation-adjusted revenue threshold of roughly 5 million dollars, or selling under one ton, are exempt.

Colorado adds another state where shipping packaging generates recurring dues, raising the value of packaging-weight data from warehouse systems. Because dues are higher for packaging off the recyclability list, a change from plastic mailers or mixed-material envelopes to recyclable cardboard can reduce cost. For example, a subscription box company shipping into Denver from a Utah 3PL must report the boxes, inserts and void fill that reach Colorado customers and pay dues on them to Circular Action Alliance.

• Subscription Box FulfillmentShipping recurring boxes on a schedule
• Custom PackagingBranded boxes, mailers, and inserts
• Void FillMaterial that fills empty space in a box

• Oregon Plastic Pollution and Recycling Modernization Act2021, fees from 2025 · Oregon packaging EPR law, first to collect fees
• California SB 542022 · California EPR law for packaging and plastic foodware
• Maine Packaging EPR Law2021 · First US state packaging EPR law, enacted 2021

1. Colorado General Assembly: HB22-1355 leg.colorado.gov
2. Colorado CDPHE: Extended producer responsibility cdphe.colorado.gov