What is the Colorado HB 22-1355 deadline?

Covered producers were required to register with Circular Action Alliance by Oct 1, 2024. The first full reporting year is 2025, with fees assessed based on that year's packaging data.

Who is the PRO for Colorado?

Circular Action Alliance (CAA) is Colorado's designated PRO. CDPHE (Colorado Department of Public Health and Environment) is the state agency overseeing the program.

What materials does Colorado HB 22-1355 cover?

Covered materials include paper, rigid and flexible plastics, glass, metal, and other consumer packaging placed on the Colorado market. Food-service ware is included.

What is Colorado's de minimis threshold?

Producers with less than $5M in annual gross revenue from covered products sold into Colorado are generally exempt. That is the highest de minimis threshold of the four active states.

Where do I register for the Colorado EPR program?

Registration is handled by Circular Action Alliance. Program rules and updates are published at cdphe.colorado.gov under the Producer Responsibility Program for Statewide Recycling.

Colorado HB 22-1355

What do you owe Colorado under HB 22-1355?

Drop in your Shopify URL. We read your SKUs and estimate Colorado producer fees across plastic, fiber, glass, and metal.

Estimate my CO liability See fee schedule

Covers CA SB 54, CO HB 22-1355, ME LD 1541, and OR SB 582

Rates pulled from PRO guidance, refreshed quarterly

No signup. Results in under a minute.

Built for $10M to $100M brands on Shopify

What is Colorado HB 22-1355?

HB 22-1355, the Producer Responsibility Program for Statewide Recycling, was signed by Governor Polis in June 2022. Colorado was the second US state to pass a packaging EPR law after Maine, and the first in the Mountain West. CDPHE oversees the program and delegates day-to-day administration to a single statewide PRO.

That PRO is Circular Action Alliance (CAA), the same nonprofit running the programs in California, Oregon, Maryland, Minnesota, and Washington. Registration was due October 1, 2024. The first reporting year is 2025, and fees are assessed on the packaging you ship into Colorado during that year.

HB 22-1355 covers every category of consumer packaging and paper product: rigid and flexible plastic, paper and paperboard, glass, metal cans, food-service ware, and multi-material formats. Colorado sets a noticeably higher de minimis than California. Producers under $5M in covered Colorado revenue are exempt, which gives smaller DTC brands a real runway before fees kick in.

CAA sets fees annually with CDPHE sign-off. Rates vary by material, and Colorado layers on light eco-modulation: recyclable and recycled-content packaging pays less per ton than hard-to-recycle composites.

Who must comply

If your brand sells packaged consumer goods into Colorado and clears the state's de minimis threshold, you are a covered producer under HB 22-1355. Colorado applies to producers with more than $5M in annual gross revenue from covered products sold into Colorado. Out-of-state DTC sellers are included. A physical tax nexus is not required.

Administered by Circular Action Alliance.

Covered materials and example rates

Rates below are modeled from PRO public guidance (2025-01-01). Actual rates are set annually and subject to change.

Material	Rate (USD / metric ton)
Rigid plastic	$520
Flexible plastic and film	$780
PET bottles	$380
HDPE bottles	$380
Corrugated fiber	$140
Paperboard and cartons	$180
Glass	$80
Aluminum	$60
Steel	$65
Multi-material / laminates	$720
Compostable packaging	$320

Deadline

HB 22-1355 timeline: Registration with Circular Action Alliance was due October 1, 2024. Fees are assessed on 2025 packaging.

How we estimate your fee

1
Extract your packaging

We read your Shopify storefront (or product URLs you provide) and identify every SKU with its likely packaging components: bottles, caps, cartons, mailers, labels, and inserts.
2
Apply Colorado rates

For each material family, we multiply estimated tonnage sold into Colorado by the HB 22-1355 per-metric-ton fee published by Circular Action Alliance.
3
Return a ±20% band

You get an annual fee range (low / mid / high) with a per-material breakdown you can hand to your ops or compliance team.

Example calculation

A $40M CPG beverage brand shipping 1.2M aluminum cans into Colorado annually

Estimated fee: $6,000 – $9,500 / year

Estimates shown with a ±20% confidence band. Not audit-grade; for informational use.

Read the full text of HB 22-1355 on the official Colorado Department of Public Health and Environment (CDPHE) site: https://cdphe.colorado.gov/hm/producer-responsibility-program-statewide-recycling

Colorado HB 22-1355: frequently asked questions

What is the Colorado HB 22-1355 deadline?

Covered producers were required to register with Circular Action Alliance by Oct 1, 2024. The first full reporting year is 2025, with fees assessed based on that year's packaging data.
Who is the PRO for Colorado?

Circular Action Alliance (CAA) is Colorado's designated PRO. CDPHE (Colorado Department of Public Health and Environment) is the state agency overseeing the program.
What materials does Colorado HB 22-1355 cover?

Covered materials include paper, rigid and flexible plastics, glass, metal, and other consumer packaging placed on the Colorado market. Food-service ware is included.
What is Colorado's de minimis threshold?

Producers with less than $5M in annual gross revenue from covered products sold into Colorado are generally exempt. That is the highest de minimis threshold of the four active states.
Where do I register for the Colorado EPR program?

Registration is handled by Circular Action Alliance. Program rules and updates are published at cdphe.colorado.gov under the Producer Responsibility Program for Statewide Recycling.
What is Extended Producer Responsibility (EPR) for packaging?

EPR shifts the cost of managing post-consumer packaging waste from cities and taxpayers to the brands that sold the packaging in the first place. In an EPR state, the "producer" (usually the brand owner or importer) pays a per-ton fee on every packaging material it ships into the state. That money pays for recycling collection, sorting infrastructure, and consumer education.
Does my brand have to comply?

If you sell packaged consumer goods into California, Colorado, Maine, or Oregon and your revenue clears the state de minimis threshold (roughly $1M to $5M depending on the state), you are a covered producer. This includes out-of-state DTC brands. Physical nexus is not required; the fee follows the packaging, not the seller.
How is the EPR fee calculated?

Each state publishes a per-metric-ton fee for every packaging material family: rigid plastic, flexible plastic, glass, aluminum, fiber, and so on. Your fee is (tons of that material shipped into the state) × (state rate), added up across every material and every state. Our calculator reads your product pages to estimate the tonnage and applies the current rate tables.
What is a Producer Responsibility Organization (PRO) and do I need to register?

A PRO is a nonprofit appointed by the state to collect fees and run the program. California, Colorado, and Oregon all use Circular Action Alliance (CAA). Maine is different: its program is run by Maine DEP directly, with no PRO. If you are a covered producer in CA, CO, or OR, you register with CAA and submit packaging data each year.
When are the compliance deadlines?

California: producer reporting started in 2025 under SB 54. Colorado: registration was due October 1, 2024, with fees on 2025 packaging data. Oregon: compliance fees began July 1, 2025. Maine: first producer payments are due in 2026. Confirm current dates with the relevant authority before filing.
How is EPR different from a carbon tax or sales tax?

EPR is not a tax on emissions or retail sales. It is a material-specific fee assessed on the weight of packaging you put on the market in a given state, paid once a year to either the state's PRO (CA, CO, OR) or to the state agency itself (ME). The revenue goes to recycling infrastructure, not the general fund.