PackBOM
Active

Colorado Packaging EPR Compliance Guide — 2026

Everything brands need to know about Producer Responsibility Program for Statewide Recycling (HB 22-1355), including deadlines, data requirements, material categories, exemptions, and reporting preparation.

Check your Colorado readiness
Key Facts
LawHB 22-1355 — Producer Responsibility Program for Statewide Recycling
AdministratorColorado Department of Public Health and Environment (CDPHE)
PROCircular Action Alliance
EffectiveSigned June 2022; program start July 2025
RegistrationRegistration is completed through the PRO.
ReportingAnnual reporting begins with producer data submissions in 2026.
ExemptionExemptions are defined by CDPHE rules and program guidance.
Who Needs to Comply

The producer is typically the brand or entity that first introduces covered packaging or paper products into Colorado commerce.

Packaging and paper products sold or distributed into Colorado.

Small producer note: Exemptions are defined by CDPHE rules and program guidance.

What Data You Need
  • SKU-level sales into the state
  • Packaging BOMs for covered SKUs
  • Component material categories
  • Component weights in grams
  • PCR and recycled content
  • Recyclability and evidence files

Key Deadlines

Program start
July 1, 2025
First producer reporting
May 31, 2026
Annual fee cycle
September 30, 2026

Material Categories for Colorado

These are common packaging categories brands should be ready to classify and report. Always follow final state and PRO instructions.

MaterialClassColorado note
PETPlasticCommon priority material for this state.
HDPEPlasticCommon priority material for this state.
PVCPlasticReport PVC separately when identified as vinyl, PVC, or resin code #3.
LDPEPlasticReport as LDPE or #4 plastic when supplier documents state low-density polyethylene.
PPPlasticReport as PP or #5 plastic, especially for closures and small components.
PSPlasticReport rigid PS separately from EPS foam where programs distinguish the two.
EPSPlasticReport foam EPS separately when required; do not combine with rigid polystyrene unless the report format instructs it.
Other PlasticPlasticUse only when the resin is unknown or explicitly categorized as other/#7 plastic.
Multi-layer PlasticPlasticUse when the package includes multiple plastic layers or barrier materials that prevent single-resin classification.
Small-format PlasticPlasticUse where reporting programs separate small-format plastics from regular resin categories.
Clear GlassGlassReport clear/flint glass separately when color categories are required.
Brown GlassGlassUse brown/amber glass category when documents call out amber, brown, or UV-protective glass.

How to Report

  1. 1Determine covered products and Colorado sales.
  2. 2Create packaging BOMs for each SKU sold into Colorado.
  3. 3Map components to approved material categories.
  4. 4Generate state detail and material summary reports for review.
Common Mistakes
  • • Using national sales instead of Colorado-specific sales.
  • • Forgetting paper products and secondary packaging.
  • • Missing supplier evidence for estimated weights.

Penalties for Non-Compliance

CDPHE has enforcement authority under the producer responsibility program.

Frequently Asked Questions

Does Colorado cover paper products?

Yes. Colorado covers packaging and paper products.

Do I report by material or by SKU?

You should maintain SKU-level detail, then aggregate by material for reporting.

Is CAA the Colorado PRO?

Yes, Circular Action Alliance is the PRO for Colorado.

What evidence should I retain?

Keep supplier specs, COAs, technical drawings, and any measurement records used to determine weight and material.

Can I force-generate reports with gaps?

PackBOM can generate exports with warnings, but critical gaps should be reviewed before filing.

How PackBOM helps with Colorado compliance

PackBOM connects SKU sales, packaging BOMs, supplier evidence, AI spec extraction, validation rules, and report exports so your Colorado data is ready for review.

Start your Colorado EPR Data Audit

Related Resources

EPR Obligation Checker

Check whether your brand may need to comply with packaging EPR.

EPR Deadline Tracker

See deadlines across all current EPR states.

Multi-State EPR Checklist

Prepare data across California, Oregon, Colorado, and other states.