Colorado packaging EPR under the Producer Responsibility Program for Statewide Recycling.

Current Colorado EPR status

Colorado’s Department of Public Health and Environment states that, beginning July 1, 2025, a producer may not sell or distribute products using covered materials in Colorado unless the producer participates in the Producer Responsibility Program. CDPHE also states that producers must pay producer responsibility dues annually and maintain records and report data to document compliance.

Program plans moved into implementation in 2026

CDPHE approved Circular Action Alliance’s program plan and states that implementation was to begin within six months of approval, or by June 9, 2026. CDPHE also approved an individual program plan for Interchange 360, with implementation by March 13, 2026.

For compliance operations, that means the important record is no longer simply whether the law exists. Teams need to connect the correct producer entity to the appropriate program path, current plan requirements, reporting records and evidence.

Who is the producer in Colorado?

Colorado’s statute defines producer through a hierarchy that begins with the manufacturer when a product is sold under the manufacturer’s own brand or without brand identification and can move to a licensee or other responsible person depending on the facts. The exact statutory sequence should be reviewed against the company’s legal entities, brand relationships and distribution model.

The practical mistake to avoid is using the commercial brand as the compliance entity. A brand can sit above, below or beside the legal entity that actually fits the statutory definition.

What to keep in a Colorado entity record

Official Colorado sources

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