Colorado Producer Information
State Overview
Colorado’s Producer Responsibility Program for Statewide Recycling Act (HB22-1355) was signed into law in 2022. The program is administered by the Colorado Department of Public Health & Environment and establishes a packaging EPR framework with the goal of increasing statewide recycling rates and offering free and convenient recycling to households throughout Colorado. Interchange 360 launched operations in the state on March 11, 2026, making Colorado the first state in the nation to collect petroleum and lubricant products under an EPR program in the U.S.
Producer Compliance
Operating under an Individual Program Plan (IPP), Interchange 360 is a state-approved compliance option for producers who sell materials on our Applicable Products List. The deadline for producers to register was July 1, 2025. Obligated producers of petroleum and lubricant products who have not yet registered with Interchange 360 or do not have their own IPP are considered out of compliance and could face enforcement action from the state. Producers can still register by completing Interchange 360’s Colorado Participation Agreement, creating an account in The Vault, and uploading the Agreement. Once the account is created, producers can begin filing reports and remitting dues to be fully compliant.
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 Passed | Planning Dues Dates | Planning Dues | Implementation Dues Dates | Implementation Dues |
|---|---|---|---|---|
| 2022 | July 1, 2024 to March 31, 2025 | $.056/gal | April 1, 2025 to present | $.56/gal |
Colorado Eco-Modulated Dues
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.
Producer Road to Compliance
Complete the following steps to make sure your company is fully complying with the law.
Interchange 360 Mile Markers
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.
Key Resources
Background Documents
May 11, 2026 – Letter to CDPHE Regarding Coverage of Secondary and Tertiary Packaging
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
Colorado News
- A First Pickup on the Western Slope: Interchange 360 Expands to Mesa County
Every new collection facility we add to our network represents something bigger than a logistics milestone. It represents a community that now has a reliable,… Read more: A First Pickup on the Western Slope: Interchange 360 Expands to Mesa County - Collection is underway in Colorado
Interchange 360 officially launched collection operations on March 11, marking a significant milestone for the organization. This is the first program of its kind in… Read more: Collection is underway in Colorado - RPM eco Becomes First Registered Processor in Colorado
Exciting news for Colorado. We’re thrilled to welcome RPM eco as the first Processor registered with Interchange 360 in the state. This is an important early step as… Read more: RPM eco Becomes First Registered Processor in Colorado - 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
Contact
If you have questions or comments, or would like to arrange a meeting, please reach out to Member Services.