Colorado: Packaging EPR program set for 2026 launch

In 2022, Colorado became the third US state to adopt EPR for packaging materials and printed paper under the Producer Responsibility Program for Statewide Recycling Act (HB22-1355).

The implementing regulations were completed in 2024, and the regime is slated for launch in January 2026.

Producers were required to register with the state’s single PRO and submit their 2024 placed-on-the-market data by 31 July 2025 to continue selling or distributing covered materials in the state.

The PRO submitted its 2026–2030 program plan in June 25, outlining the operational framework, recycling targets and post-consumer recycled (PCR) content goals.

Approved by the advisory board, the plan now awaits final approval by the executive director of the Colorado Department of Public Health and Environment (CDPHE), expected in December 2025.

The plan identifies 61 packaging and paper materials prioritised for collection, divided between those already deemed recyclable (MRL) and those awaiting broader infrastructure (AML).

While both categories are in scope, producers of AML materials may face higher future fees or transition requirements as recycling capabilities expand.

CDPHE’s draft eco-modulation schedule proposes fee reductions of up to 10% for MRL packaging with clear sorting instructions and locally sourced recycled content.

Incentives for reuse and refill systems are foreseen in later program phases.

CDPHE is expected to publish final eco-modulation guidance and 2026 producer fees by 31 October 2025.

While the PRO will manage the packaging regime, the Act allows producers to opt for individual programs.

To date, only one such plan has been filed by the Lubricant Packaging Manufacturers Association.

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