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 your own? No need to wait for the next post, just email us at memberservices@interchange360.com.

What states do producers need to be registered in?
In 2025, five states required producers to register in 2025 in order to comply with their EPR laws:

• Colorado – If you sell any of the materials on our Applicable Products List, you need to register with Interchange 360 as soon as possible.
• Vermont – There is a Household Hazardous Waste (HHW) program run by the state. If you sell any Covered Products you must register and Interchange 360 can assist you with compliance.
• Oregon
• Minnesota
• California

Interchange 360’s goal is to serve as an independent compliance option in all states with EPR laws and we’re already active in several. If you have missed a state deadline, please reach out to our Member Services team for guidance.

We anticipate registration dates to be announced in other states in early 2026. Make sure to sign up for our newsletter by completing the form at the bottom of our homepage and register for our next quarterly producer webinar on January 14, at 10 am PT/1 pm ET to stay up to speed with the latest information.

Can dues be passed down through the supply chain in Colorado?
Yes. Dues can be passed down; however, they cannot appear as a separate line item on a receipt at the final point of sale to the consumer purchasing the product through a retailer.

Can distributors or retailers report and remit fees/dues on behalf of manufacturers?
Yes. Often distributors or retailers are the only ones who have the information required for reporting. Interchange 360 allows for supply chain agreements among different parties so that any segment of the supply chain can register, report, and remit. All producers who have others report and remit on their behalf are encouraged to maintain records and have supply chain agreements on file with Interchange 360 to make it easier when it comes time for auditing.

If a producer is exempt, do they still need to register in Colorado?
It is up to the producer. By registering, the producer will appear on the public list of registered producers the state will review when considering enforcement actions. They are also already registered in the event they go over the allowable threshold. However, the producer will have to pay the $200 Interchange 360 registration fee and is subject to auditing. If the producer does not register, the state may do a compliance check and ask for proof of exemption.

How are producer dues currently being spent in Colorado?
After months of preparation, Interchange 360 is actively ramping up activities in Colorado in advance of our operational go-live date of March 13, 2026. This includes identifying collection locations, meeting with municipalities, service providers and transporters, and pricing out infrastructure. Interchange 360 has also developed and published a Manual for Registered Processors & Transporters, and the Program Manual for Return Collection Facility (RCF) Operators. This is an exciting time for the industry as we are full steam ahead.