Colorado, USA, Packaging Data Reports Are Due July 2025

Colorado, USA, Packaging Data Reports Are Due July 2025

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The Colorado reporting deadline for packaging data is fast approaching. By July 31, 2025, producers selling products in packaging or selling paper products in Colorado must comply with the state’s Extended Producer Responsibility (EPR) law.

This legislation, known as the Producer Responsibility Program for Statewide Recycling Act (House Bill 22–1355), establishes a statewide recycling system funded and managed by producers. To stay compliant, obligated producers must submit annual data on their packaging materials, sign required agreements, and contribute fees to support the program.

Here’s what you need to know to determine if your business is affected and how to meet the requirements.

Is Your Business Obligated to Report?

Not all businesses are impacted by Colorado’s EPR law. Here’s how to determine your business’s status:

Obligated Producers

You are likely required to participate if your business meets any of the following criteria:

  • You sell products in packaging to consumers in Colorado.
  • You distribute paper products such as newspapers, catalogs, or office paper.
  • Your annual gross revenue exceeds the de minimis threshold defined by state regulations (adjusted each year)

Exempt Producers

You may be exempt if you fall under one of these categories:

  • Your business generates revenue below the adjusted de minimis threshold
  • You don’t distribute covered materials (e.g., no packaging or paper products).

 

For more information about how producers are determined, refer to this Producer Determination Flow Chart.

What is the Colorado State Addendum?

Producers are required to sign the Colorado State Addendum (COSA) when joining the Circular Action Alliance (CAA), the state-appointed Producer Responsibility Organization (PRO). COSA ensures that producers acknowledge their obligations under Colorado’s specific EPR regulations.

Why Sign the COSA?

  • It formalizes your participation in the Producer Responsibility Program.
  • It ensures compliance ahead of the Colorado reporting deadline.
  • It allows access to the Producer Portal, where you will submit your reports.

Producers can begin signing the COSA starting June 2, 2025.

Submitting Your Report Using the Producer Portal

Colorado’s reporting system streamlines compliance through the CAA’s Producer Portal. Here’s what you need to do to submit your report before the July 31, 2025 deadline.

  1. Sign Your COSA : Before accessing the portal, ensure your Colorado State Addendum is signed.
  1. Login to the Producer Portal: In the Producer Portal, enter the required data about your packaging materials.
  2. Submit Your Report: Provide details about the type and volume of materials distributed in Colorado during 2024. Payment of applicable fees will occur annually starting in January 2026.

 

Got questions about how to use the portal? The Circular Action Alliance website offers detailed guidance and FAQs for producers.

Understanding the Circular Action Alliance’s Role in Colorado

The Circular Action Alliance (CAA) serves as Colorado’s PRO, managing the statewide recycling system. Their responsibilities include funding the recycling program, maintaining reporting platforms, and ensuring compliance among producers.

Key functions of the CAA include:

  • Collecting producer fees to fund recycling services.
  • Publishing data reports and educational materials.
  • Supporting producers with compliance resources.

 

By participating in the CAA, you’ll not only help ensure legal compliance but also contribute to Colorado’s ambitious recycling rates and greenhouse gas reduction goals.

How RLG Can Simplify Your EPR Compliance

Navigating packaging laws like Colorado’s EPR program can feel overwhelming, but you don’t have to tackle it alone. Reverse Logistics Group (RLG) offers comprehensive support for reporting and compliance.

Here’s How We Can Help:

  • Data Management: We streamline the reporting process by supporting all activities related to data, including collecting, verifying, cleaning, and aggregating.
  • Expert Guidance: Our team stays up-to-date on Colorado’s evolving EPR regulations, providing step-by-step assistance.
  • Customized Solutions: Whether you’re a small business or a global corporation, we tailor our services to meet your compliance needs.

 

With RLG by your side, compliance is no longer a challenge, but an opportunity to make a positive environmental impact while streamlining operations.

Don’t Wait to Take Action

The Colorado reporting deadline will be here before you know it. Ensure your business is compliant by determining your obligations, signing the COSA, and using the Producer Portal to submit your report. Learn More and Get Started

Need help? Contact our RLG team today to learn how we can simplify EPR reporting and keep you ahead of the curve.

Disclaimer: This content is for informational purposes only and should not be considered legal advice. Laws are subject to interpretation and change without notice, so always consult with professional advisors and refer to primary sources. Content is accurate as of publication date but may not be regularly updated.

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Les Griffith - Speakers

Business Development Director
RLGA

Les Griffith is currently the Business Development Director at RLGA and is tasked with expanding the company’s data management offerings for packaging EPR in the Americas. Les has over 30 years of industry experience in Environmental Services, Extended Producer Responsibility and Reverse Distribution. Les has spent these last 30 years working with organizations to develop progressively more sustainable solutions to the management of end-of-life materials. Prior to joining RLG, Les spent eleven years at Covanta most recently serving as the Business Development Director for the Healthcare Solutions division. His group covered North and Central America and specialized in providing a suite of services to healthcare PROs, take-back services to retail pharmacy and law enforcement and environmental services to the healthcare sector and reverse distributors. Prior to Covanta Les spent 10 years at Waste Management Inc. as an Area Manager for their Healthcare Solutions group.

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Andriana Kontovrakis - Speakers

Director of Compliance Services
RLG

Andriana Kontovrakis is the Director of Compliance Services for Reverse Logistics Group’s US team.  She manages a team responsible for ensuring manufacturer and retailer customer compliance with EPR laws for electronics, batteries, packaging, household hazardous wastes, and other consumer products across the US. Along with RLG partner the Household and Commercial Products Association, she is spearheading the development of the Household Product Stewardship Alliance, a stewardship organization forming under the guidelines of Vermont’s HHW EPR law.  Prior to working with RLG, she was a Policy Analyst with the global electronics recycler Sims Lifecycle Solutions where she managed programmatic implementation and customer and supplier accounts for the US EPR compliance unit and the Deputy Director for Waste Prevention for the NYC Department of Sanitation.

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