Colorado Single-Use Packaging Reduction EPR Act (HB 22-1355): Operational Status Following Full 2025 Launch
ENFORCEMENT TIMELINE
Program fully launches in 2025; fee structure finalized in 2026; eco-modulation begins in 2027
Overview
Colorado's HB 22-1355 establishes an extended producer responsibility (EPR) program covering single-use packaging and paper products, with full program operation having begun in 2025. The law reflects the same broader policy trend seen in California's SB 54—shifting the financial responsibility for single-use plastic packaging from municipalities and taxpayers to producers—and Colorado is recognized as one of the earliest states nationally to bring such an EPR program into full operation.
Enforcement Timeline
June 2022: The Colorado Governor signs HB 22-1355, the nation's first comprehensive packaging EPR law, into law
May 2023: The Colorado Department of Public Health and Environment (CDPHE) formally designates Circular Action Alliance (CAA) as the sole Producer Responsibility Organization (PRO)
2024–2025: Statewide recycling infrastructure needs assessments are completed
2025: Full program operation begins; covered producers begin PRO registration and submission of baseline packaging material data
2026: CAA finalizes its program operating plan and material-specific eco-modulated fee rates
2027: Producers begin full-scale EPR fee contributions, and the statewide recycling expansion program becomes fully operational
Business Impact
Producers of single-use packaging and paper products in Colorado should note that the program has moved beyond initial implementation into full operational status as of 2025, meaning producer responsibility obligations are now actively enforced rather than pending, and should treat this as an ongoing compliance program similar in structure to California's SB 54.