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Producer Information

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. 


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. 


Colorado Base Dues

Program operations in Colorado are funded by producer dues managed by Interchange 360 as a nonprofit organization. The dues are based on the estimated cost to operate the program and the amount of material being sold into the state. Each individual producer’s dues are based on the volume of covered materials it sells into the state.  Producers are responsible for paying back to the start date of planning dues regardless of their join date. To learn more aboud dues, visit our Producer Fees/Dues page.

EPR Law PassedPlanning Dues DatesPlanning DuesImplementation Dues DatesImplementation Dues
2022July 1, 2024 to March 31, 2025$.056/galApril 1, 2025 to present$.56/gal

Colorado’s current base implementation dues are $0.56/gallon for all products, sizes, and formats. By January of each year, CDPHE, in consultation with Interchange 360 and the Colorado Advisory Board, will develop an eco-modulation schedule. The first eco-modulation bonuses are currently scheduled for 2027. Learn more about eco-modulation in Colorado.


Important Resources for Colorado Producers

Access the most frequently used resources for producers:

Colorado Eco-Modulation

Colorado News:


Milestones


Important Documents:

November 17, 2025 – Letter to CDPHE Expressing Concerns with Proposed Amendment to Producer Eco-Modulation Regulations

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

LPMA Applicable Product List

Colorado Certificate of Incorporation


Frequently Asked Questions about Colorado:

How do I know if my company is already registered?

There is a listing of all registered producers on the Colorado Producers page and the Producer Resource Center that is updated regularly. If your company does not appear, please contact Member Services immediately for assistance.

Has Interchange 360’s Individual Producer Plan (IPP) been approved in Colorado?

Yes. On September 9, 2025, Interchange 360’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.

Why does Interchange 360 have a separate program in Colorado?

There are a number of reasons Interchange 360 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 Interchange 360 program provides cost savings to the industry over the long-term.  

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. 

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.

Why are producers required to pay dues back to July 1, 2024, when the program did not 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 Interchange 360 has conducted on behalf of producers. This includes developing the program plan, education and outreach, infrastructure, legal, and other associated costs. 

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.

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. Interchange 360 is required by law to submit a list of registered producers. 

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. 

How can I ensure I’m fully compliant with my Producer Obligations?

The state’s deadline to register with Interchange 360 was July 1, 2025. If you are an obligated producer who has not yet registered with Interchange 360 in Colorado please contact Interchange 360 Member Services for assistance with the process.

What is the difference between fees and dues?  

There is currently no difference in how Interchange 360 applies the words “fees” and “dues,” however some states use a specific term. Colorado uses “dues” while all others use “fees” to reference what producers must pay into a program. 

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.