Colorado
Compliance Program Overview
Interchange 360’s compliance program in Colorado is guided by an Individual Program Plan (IPP) approved by the Colorado Department of Public Health and Environment (CDPHE).
It covers all materials described on the Applicable Products List. Through the use of return collection facilities/depots, commercial collection, and community collection events, the program has target collection rates of 44% by 2030 and 58% by 2035. The target recycling rates are 35% and 50% for the same periods, with anticipated growth in the years to come. Operations are anticipated to begin in early 2026.
Program Milestones:
- June 3, 2022 – Colorado EPR program for packaging and paper becomes law
- December 31, 2024 – LPMA submits its initial Individual Program Plan
- May 15, 2025 – Colorado Producer Responsibility Advisory Board Recommends LPMA’s program plan for approval by CDPHE
- September 9, 2025 – CDPHE approves LPMA program plan
- By March 11, 2026 – Implementation of LPMA’s program plan (Operations expected to begin in early 2026)
Producer Registration
The state deadline for producers to register with Interchange 360 was July 1, 2025. If you are a producer selling products on our Applicable Products List into Colorado and not yet registered, you are out of compliance and could face enforcement action from the state. Sign the Colorado Participation Agreement, create an account in The Vault, and follow the prompts to register as soon as possible to begin the compliance process.
Important Resources for Colorado Producers
Access the most frequently used resources for producers:
Eco-Modulation
Colorado’s current implementation due is $0.56/gallon for each product. By January 1, 2026, and each year thereafter, CDPHE, in consultation with LPMA and the Colorado Advisory Board, will develop an eco-modulation bonus schedule.
In addition, LPMA, as required by law, will develop a separate eco-modulation schedule including both bonuses and penalties that will go into effect in 2028. The eco-modulated dues are estimated to range by +/- 25% from the cost-base dues and will be adjusted to meet the product performance target.
The following incentives will be determining factors in lower dues:
- Reduction in the amount of packaging materials used for products.
- Innovations and practices to enhance the recyclability or commodity value of covered materials.
- High levels of post-consumer recycled material use.
- Design for the reuse and refill of covered materials.
- High recycling and refill rates of covered materials.
The following incentives will be determining factors in increased dues:
- Designs and practices that increase the costs of recycling, reusing, or composting covered materials.
- Designs and practices that disrupt the recycling of other materials.
Other Resources
If you have any questions, please contact our Member Services team.
Colorado News:
- Thinking about the EPR Think Tank
More than 120 people braved the single-digit temperatures in New York City to attend this year’s EPR Think Tank, demonstrating just how big of a… Read more: Thinking about the EPR Think Tank - Why Lubricant Packaging Needs its Own EPR Pathway
In this article in Waste Advantage, CEO David Lawes outlines why lubricant packaging needs a sector-specific EPR pathway. - Producer Q&A: Part 1
This entry is the first in a series where the Interchange 360 team answers some of the most frequently asked questions. Have a question of… Read more: Producer Q&A: Part 1 - From Costs to Compliance: Working Group Develops Draft for Future Fees and Dues
Over the past several months, Interchange 360 convened a Fee/Dues Setting Working Group—a team comprised of producers, distributors, retailers, and industry experts committed to providing… Read more: From Costs to Compliance: Working Group Develops Draft for Future Fees and Dues - Leading the Way in Colorado
In Colorado, Interchange 360 will launch container collections in early March 2026. Interchange 360, on behalf of all the petroleum and lubricants industry, is on track… Read more: Leading the Way in Colorado - Important Changes to LPMA Payment Structure
LPMA powered by Interchange 360 is driven by producers in the petroleum, lubricant, and automotive industries. Over the course of the last 18-months, we have… Read more: Important Changes to LPMA Payment Structure
Important Documents:
September 9, 2025 – Official Approval Letter from CDPHE for LPMA IPP
August 26, 2025 – Revised Individual Program Plan (IPP) Submission to CDPHE
August 25, 2025 – A Guide to Products Covered Under the LPMA Program
May 15, 2025 – Advisory Board Recommendation for IPP Approval
April 15, 2025 – Revised Individual Program Plan (IPP) Submission to CDPHE
Dec 31, 2024 – Individual Program Plan (IPP) Submission to CDPHE
Dec 19, 2024 – CDPHE Letter regarding Approval Process for IPP
Nov 25, 2024 – LPMA Presentation to CDPHE Advisory Board re: IPP
Colorado Certificate of Incorporation
Frequently Asked Questions about Colorado:
How can I ensure I’m fully compliant with my Producer Obligations?
The state’s deadline to register with LPMA was July 1, 2025. If you are an obligated producer who has not yet registered with LPMA in Colorado please contact LPMA Member Services for assistance with the process.
Is it too late to register?
No, complete the Colorado Participation Agreement as soon as possible and submit it to Member Services. Note that all producers are required to pay back to the start of the planning phase of the program (July 1, 2024) to ensure fairness.
What happens if my company doesn’t register?
The state of Colorado can take enforcement action against any producer not registered, including restricting sales of products in the state. LPMA is required by law to submit a list of registered producers.
How do I know if my company is considered a Producer in Colorado?
The Colorado Department of Public Health & Environment (CDPHE) has developed a Producer Determination Chart to help Producers understand their obligations.
Please note, this is applicable only to Colorado and should not be considered the law for other states.
When and how do we file our Remittance Report and make a payment?
Members and Participants will report sales data by state and calculate their total remittance owing for the reporting period through The Vault, our secure online portal. Sales data reporting and payment is due 30 days after the reporting period ends. More information can be found on the Reporting page.
To support operational flexibility, LPMA now offers quarterly, monthly, or annual reporting and payment options; members choosing annual reporting should contact accounting@interchange360.com for setup instructions.
Why are producers required to pay dues back to July 1, 2024, when the program doesn’t have to be operational until March 2026?
The law requires a start date, but there is a lot of work that must be done leading up to that date that LPMA has conducted on behalf of producers. This includes developing the program plan, education and outreach, infrastructure, legal, and other associated costs.
Do you have a list of Applicable Products in Colorado?
Yes. For the benefit of Producers, we plan on maintaining a consistent list of Applicable Products List for our program across all states. View the list here.
What if I accidentally report materials to the wrong compliance organization?
Don’t worry. Our team is here to help, and we expect there to be a learning curve for all producers. The items on LPMA’s product list are not shown on any other compliance organization’s reporting system. However, sometimes mistakes can happen in how products are classified. If this were to be discovered either through an audit process or by the producer they should be granted a refund from the organization and the file an amended report with the correct organization.
Why does LPMA have a separate program in Colorado?
There are a number of reasons LPMA established this first-in-the-nation independent program in Colorado. It is the only program in Colorado where producers of petroleum and automotive products have their products recycled which leads to better environmental outcomes.
Other programs focus on curbside collection. On such a model, petroleum and automotive products are sent to landfill even though producers still must pay. And because the products are not recycled it will lead to higher long-term costs for the industry. Therefore, the LPMA program provides cost savings to the industry over the long-term.
Has LPMA’s Individual Producer Plan (IPP) been approved in Colorado?
Yes. On September 9, 2025, LPMA’s IPP was approved by CDPHE making it the first EPR program approved in the State and the first IPP to be approved in the nation. Read more here.
Where can I get more information on the Colorado Producer Responsibility Program for Statewide Recycling Act?
Visit the Producer Responsibility Program page on the CDPHE website here.
Have you held any Producer Webinars?
Yes. We hold Producer-focused webinars on a quarterly basis, or as the need arises. You can watch the replays of past Webinars and register for upcoming ones here.