Colorado’s packaging EPR law (HB 22-1355, C.R.S. §§25-17-701–716, 6 CCR 1007-2 Part 1 §18) is past its launch dates — this is operating compliance, not future planning.

Status at last review (2026-09-21)

• Participation restriction active since July 2025; dues active since January 2026. (CDPHE producer-responsibility program page; CAA Colorado.)
• 2026 dues schedule published — estimates against it are current-schedule estimates. Passive eco-modulation factors are built into the published rates; separate active incentives continue to evolve — cite the schedule version on every number.
• Small-producer shorthand: under 1 dry short ton into Colorado or below the annually CPI-adjusted global-revenue threshold (confirm the current July 1 figure). A dry short ton (2,000 lb) is not a metric ton (about 2,204.62 lb) — store kg and lb and attach the state-specific conversion used.
• No express contractual-assignment override identified — the statutory producer definition controls; a private cost-sharing contract does not change who the statute treats as producer.

What this means for a brand

• If you sell packaged products into Colorado above the small-producer inputs, assume dues reporting through the PRO is a current duty — confirm with CAA/CDPHE.
• Keep packaging mass evidence in grams with the unit conversion shown; never reuse Oregon’s metric-ton test here.

Sources (retrieved 2026-09-21)

• HB 22-1355 bill page — https://leg.colorado.gov/bills/hb22-1355
• CDPHE producer-responsibility program — https://cdphe.colorado.gov/hm/epr-program
• CAA Colorado — https://circularactionalliance.org/colorado
• 2026 Colorado dues schedule — https://circularactionalliance.org/s/CO-2026-Dues-Schedule-Public.pdf

Data/compliance support only — not legal advice. Confirm current authority before relying.