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 first of an annual reporting cycle.
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 runs through a producer responsibility organization, 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 below the thresholds exempt. 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, the first year producers pay mandatory responsibility fees based on the volume and type of packaging they report. The supply report covering 2025 data was due by May 31, 2026, the first of an annual reporting cycle, aligned with several other states. 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 your 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.