Colorado Packaging Regulations form part of the state's Extended Producer Responsibility (EPR) framework for packaging and paper products. The legislation places obligations on producers to report packaging data and contribute towards the collection and recycling of materials across the state.
The Circular Action Alliance (CAA) is the approved Producer Responsibility Organisation (PRO) which manages the Extended Producer Responsibility (EPR) rules for Colorado. The CAA is responsible for many different aspects of the packaging waste regulations.
Firstly, they register all obligated producers and manage payments from producers. They also collect recycling funds and are working to expand access to recycling across the state. Furthermore, the CAA reimburses local municipalities for the recycling services that they provide on behalf of the state, as they are assisting in the goal of achieving greater access to recycling.
The CAA has many environmental objectives for the state of Colorado. These include promoting increased use of post-consumer recycled (PCR) content by setting material-specific PCR targets and incentivising more environmentally friendly packaging design that reduces social, environmental and health impacts, while reducing the amount of waste reaching landfill.
The CAA plans to refine its approach over time, including increasing access to kerbside recycling services for around 700,000 additional households by 2030 and improving the state’s recycling rate to 58% for packaging and paper by 2035.
The intended positive economic and environmental impacts of the programme include:
Colorado has had two packaging submissions so far, covering 2024 and 2025 packaging data. The CAA’s plan is to continue with annual submissions, with the reporting deadline set as 31 May each year.
PCR content reporting was added to the 2025 data submissions, reflecting an increased focus on recycling performance in Colorado.
Businesses with obligations in Colorado should establish robust packaging data collection processes to support future reporting requirements and PCR content disclosures.
Producers are obligated for packaging that reaches the household waste stream only (primary, primary outer and e-commerce packaging), which means that, in most cases, business-to-business, secondary and transit packaging are exempt.
The CAA’s definition of “packaging material” for Colorado is:
“Any material, regardless of recyclability, that is intended for single or short-term use and is used for the containment, protection, handling, or delivery of products to the consumer at the point of sale, including through an internet transaction.”
Packaging material comprises cartons, flexible foam, glass, metal, paper, plastic, rigid packaging and other materials.
Producers are also obligated for paper products sold in the state of Colorado. The CAA’s definition of paper products is:
“Paper and other cellulosic fibres, whether or not they are used as a medium for text or images.”
Examples include:
There are several exempt materials that are not included within the Colorado regulations. These include:
Additionally, producers can be exempt in the state of Colorado if they fall under certain criteria, including:
More information regarding these exemptions can be found on the Circular Action Alliance website: Colorado – Circular Action Alliance
At Valpak, we assist businesses in collecting, verifying and reporting Colorado submissions for Extended Producer Responsibility (EPR) compliance.
If you are overseeing multiple suppliers, incorporating post-consumer recycled (PCR) information into packaging data, or preparing for new regulatory requirements, our specialists can help you establish the necessary processes and governance.
We work with businesses across sectors to:
Colorado’s packaging regulations will continue to evolve as the CAA works to improve recycling outcomes and support a circular economy. Delaying action until regulations become mandatory may disadvantage your business. Early preparation helps ensure clearer data, more efficient compliance and stronger sustainability credentials.
Whether you need support with packaging data collection, international compliance requirements or emerging EPR regulations across multiple jurisdictions, Valpak can help.
Contact our specialists to assess your current position, identify reporting gaps and prepare for future regulatory requirements.
EPR Account Manager (US), Data Insights
Colorado packaging regulations introduce Extended Producer Responsibility (EPR) requirements for producers supplying packaging and paper products into the state.
Generally, producers supplying obligated packaging and paper products into Colorado are required to report and comply unless an exemption applies.
Most household packaging, including primary, primary outer and e-commerce packaging, is in scope.
Circular Action Alliance is the approved Producer Responsibility Organisation responsible for administering Colorado’s packaging EPR programme.
Colorado packaging reporting is currently conducted annually, with submissions due by 31 May.
Yes. PCR content reporting was incorporated into the 2025 reporting cycle and is expected to become increasingly important in future reporting periods.