Colorado's packaging EPR law is HB 22-1355, the Producer Responsibility Program for Statewide Recycling Act of 2022. Its defining feature is that producers fund all program operations, financing a statewide recycling service that is provided to residents at no direct cost. Producers register, report covered-material data, and pay eco-modulated fees through the Circular Action Alliance. Producer fees began in January 2026, and the supply report covering 2025 data was due by May 31, 2026, the second of Colorado's annual reports (the first, covering 2024 data, was due July 31, 2025).
Colorado built its program on a simple proposition: producers pay for the recycling system, and residents get statewide recycling service for free as a result. That makes the producer fee the engine of the whole program, which raises the stakes on getting the producer determination and reporting right. This guide covers what HB 22-1355 requires, who is obligated, the model, and the 2026 dates.
The law and the model
HB 22-1355, the Producer Responsibility Program for Statewide Recycling Act, was enacted in 2022. Its distinctive design is that producers fund all program operations, so the eco-modulated fees cover the cost of the expanded, statewide recycling service rather than only supplementing it. The program is overseen by the Colorado Department of Public Health and Environment and codified at C.R.S. §§ 25-17-701 to 25-17-716. It runs through a single designated producer responsibility organization — CDPHE appointed the PRO on May 1, 2023 (C.R.S. § 25-17-705(1)(b)(II)), the first such designation in the nation; registration with the PRO was required by October 1, 2024, and since July 1, 2025 a producer may not sell or distribute products using covered materials in Colorado unless participating in the program (C.R.S. § 25-17-708(1)) — with the Circular Action Alliance serving as the PRO.
Who is an obligated producer
As in the other states, the producer is defined through a hierarchy that generally lands on the brand owner, shifting to the importer or distributor where there is no in-state brand owner, with small producers exempt — under roughly $5 million in gross revenue in the prior calendar year (the figure is CPI-adjusted each July 1) or less than one ton of covered materials into the state, along with governments, nonprofits, and certain other categories (C.R.S. § 25-17-713). The producer-funds-everything model means the population of obligated producers carries the full cost, so accurate scoping matters to both the producer and the system.
The 2026 dates
Colorado moved into the paying phase early. Producer fees began in January 2026 — producer responsibility dues were due to the PRO no later than January 1, 2026, and annually thereafter (C.R.S. § 25-17-709(1)(a)) — the first year producers pay mandatory dues based on the volume and type of packaging they report. The supply report covering 2025 data was due by May 31, 2026 — Colorado's second annual supply report (the first, covering 2024 data, was due July 31, 2025) and the first filed on the harmonized May 31 deadline the PRO now runs across its states. The May 31 date is set by the PRO, not the statute. A producer in scope has both a reporting and a fee obligation in 2026.
Colorado shows what producer-funded recycling looks like once fees are live. For the multistate picture, see the US packaging EPR compliance guide; to determine obligated-producer status, see the US packaging EPR producer obligation assessment.
Primary sources
- Colorado HB 22-1355 (2022), the Producer Responsibility Program for Statewide Recycling Act: Colorado's packaging EPR law, under which producers fund all program operations; producer fees began in January 2026.
- Circular Action Alliance: The producer responsibility organization designated or selected to run the program in most US packaging EPR states; producers register, report, and pay fees through it.