A Producer’s Guide To Colorado EPR Reporting And Material Mapping
Colorado EPR reporting isn’t just paperwork—it’s your chance to align data, reduce costs, and avoid last-minute panic. This solo episode offers a clear, tactical walkthrough of everything producers need to prepare for the July 31st Colorado EPR submission deadline. Learn how to gather sales data by SKU, align packaging weights, map materials accurately, and understand how Colorado’s reporting categories differ from Oregon’s. With insight into methodology language, fee projections, and long-term strategy, this guide will help you turn compliance into a competitive edge.
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A Producer’s Guide To Colorado EPR Reporting And Material Mapping
Welcome to the show where we explore the shift to the circular economy, how to navigate it, how to accelerate it, and how to keep your sanity in the process. You may have read previous episodes where we talk about Extended Producer Responsibility. This is a legislation that has been passed in seven states, some of which are Colorado, California, Oregon, Minnesota, and Maryland. We’re going to get tactical about some compliance deadlines in the state of Colorado for Extended Producer Responsibility.
This episode is mostly for producers, but it's helpful to know about the requirements and how this might impact a business. If you're a sustainability lead, a packaging manager, or anyone staring down Colorado's Extended Producer Responsibility deadline of July 31st, 2025, this is the episode for you. We'll walk through what you need to know to prepare for this deadline, how to learn from your Oregon reporting experience, and what to expect when it comes to Colorado's fee structure. Spoiler alert, just because you reported in Oregon doesn't mean you are completely ready for Colorado. There's still some work that has to get done, but it does give you a head start.
Decoding EPR: What's A Producer?
In most of my episodes, we like to start with a vocabulary check. I did Extended Producer Responsibility for you already. There's a full episode on what that is if you want to go deeper. I am going to reiterate what a producer is. An obligated producer is a company that is obligated to pay fees per pound of paper and packaging sold into a particular Extended Producer Responsibility state.
These producers, by definition, are generally anybody who sells anything that is a product that is contained and protected in paper or packaging. That’s almost everything that's sold in Walmart, REI, and any retailer stores. That’s anything that’s sold to a consumer online or through Amazon. There are a lot of producers out there. You do have to sell over $1 million in revenue globally, and you have to sell more than a metric ton in the states of Oregon and Colorado. The definition of small volume producers is different in California. The point is, it’s somebody who uses paper and packaging to contain and protect a product that is sold to a consumer.
Another vocabulary word I'll use a lot is Stock Keeping Unit or SKU. These are the individual products that a company sells. It can be the thing that you scan at a register, but it can also be a pallet of product. It can be a case of product. It depends on how you transact business with your customer. If that customer is not an end consumer, which most producers are selling through retailers, then it is how much is sold to that retailer and how you sell it to that retailer, which can make things tricky. We'll talk about that later.
I'm also going to talk about material mapping. If you've ever done any data integrations, which you may not have, data mapping is when you have a key or the lowest level definition of something, and then you have another definition of something, and you map those two things together to say, “This translates to that.” It's almost like a dictionary translation table for data. In this case, you're going to have to map Oregon's definition of material to Colorado's definition of material because they are different.
We then have fees or dues. In this instance, Colorado uses the terminology dues. Most of the other EPR programs use the terminology fees. I use them interchangeably and generally use fees, but they're the same thing. It's how many cents per pound are charged to the producer of what's sold into the state. There's what we call a fee schedule that is shared in a program plan. This is a list of materials and a list of fees or dues associated with those materials. Colorado has a list of reporting categories, and then they have a list of fee categories. You can connect the dots on the two or do categories.
Colorado Vs. Oregon: EPR Compliance Deep Dive
We'll start with what makes Colorado different, and then Oregon. Oregon's reporting is weight-based. The first invoices were issued promptly after reporting. Reporting was due in April 2025. Its invoices went out this month. In Colorado, the reporting is weight-based also, but the categories are different, and the payment is not going to be until January 2026. The program kicks off in January 2026. What will happen is that the Circular Action Alliance will take in your data. They will produce a final fee schedule, likely in the October 2025 timeframe. When they do that, they're also going to share a final fee schedule for Oregon for 2026 as well. You'll pay the fees for both in January 2026.
Another difference between Oregon and Colorado is that Oregon's fees for 2025, which the invoices went out already, are only for half of a year of program costs. 2026’s fees will be a full year of program costs. You can anticipate that the fees per category will increase in 2026 for Oregon. At first glance, it looks like the fees in Colorado are higher than the fees in Oregon, but it's because of that denominator being different. I'll talk a little bit more about that later.
Preparing For Colorado EPR: Your Actionable Checklist
How do you prepare for Colorado? I've got a bit of a checklist. First, gather data. Second, review and refresh the data that you may already have. Third, map your materials to the categories for Colorado. Update any methodology language, get internal approval and alignment, and then submit. Those are six easy, I'm sure, steps. If only it were easy.
First, gather your data. You need to gather the sales by SKU in Colorado. This into Colorado is the tricky bit. I've had clients who are retailers, so they know exactly how much is sold into the state because they're the ones selling it. They have a private label, so they know how much of each product is sold in the state, which is great. Most companies sell via a distributor, an online retailer, a brick-and-mortar store, or all the above.
You can do a couple of things. Circular Action Alliance has guidance available on how you can estimate, based on population, how much you sell into a state. However, you can also use the sales information that you have and get a bit more granular based on assumptions that you can confidently make about how your product is sold.
Whatever you do, you have to document your methodology. As you're gathering this data, you need to start to think through, “What are the gaps in this data that I'm gathering? Where am I going to need to make assumptions?” You'll also need to pull in for each SKU what the packaging profiles are and what the weights associated with each aspect of that packaging are.
For example, you may sell the same end consumer product in a pallet and a case. You need to know how many consumer products are in that pallet and how much weight each of the components of those consumer products is on that pallet. It’s the same thing for the case. Generally, cases are 24 or something like that, depending on your business. You have to break it down to the end consumer product, figure out how much of each material sits within that SKU, figure out how much of that SKU you've sold, and then do the math that way per material type.
If you do have an Oregon report, you should pull that in as one of your data elements. Finally, you want to start to bring all of this together as much as you can into one file so that you can have all of this data easily referenced. You're pulling together some reference data, some sales data, and your packaging components, and then you're going to need to bring all of that together.
If this isn't your first time, you have this added step of reviewing and refreshing. It is checking your Oregon report compared to your Colorado sales. What are the SKUs that you only sell in Colorado that you don't sell in Oregon? You're going to need to get the additional information for those. Also, you should have learned some things when you did the Oregon report, as far as gaps are concerned. You want to start to refine and refresh your methodology according to what you've learned. If in that process you find that you need to update your Oregon report, there's still an opportunity to do that, but you can only do that once. You can only submit one request for change.
Next, map materials to Colorado's categories. Colorado has its own categories, and some materials are classified differently than in Oregon. You need to look at how you've mapped your SKU and product level information in Oregon, and then see if the same category exists in Colorado. If you're having trouble, you can lean on consultants like me or others, or you can try to use the Producer.Support@CircularAction.org email at Circular Action Alliance.
Colorado has its own categories and some materials are classified differently than in Oregon.
This mapping is generally one-to-one. There are a couple of categories where you might find a little bit of nuance between Oregon and Colorado. One example is that in Oregon, you have other paper laminates and other paper packaging. In Colorado, you have other paper laminates, molded pulp food service, and other paper packaging.
Another nuance is that in Oregon, tertiary or B2B packaging is covered. In Colorado, it is not, so you don't need to report any of that. The definition of tertiary is not necessarily the definition that you use in your business. What they mean is it needs to be B2B only, which means it doesn't end up in a consumer's hands. If you have a tertiary packaging that is shipped to a consumer or ends up in a consumer's hands, then you do need to report that.
The next step is to update your methodology language or write your methodology language if this is your first time. Be explicit about your assumptions, estimates, and any improvements you've made in data quality. The more information you give, the better off you'll be. The more consistent you are with your Oregon report, the better off you'll be. There's guidance the CAA provides on what methodology language needs to be, but clarity around where your data is coming from and any assumptions you've had to make.
Since this will generate an invoice, it's highly recommended that you get internal approval on your reporting. In that approval, I recommend estimating your fees based on the fee schedule provided in the program plan. Finally, submit by July 31st, 2025. There is a workbook that you can use to prepare your report in the format and answer all the questions that you're expected to answer prior to sitting down and doing it. You can use that to get approval as well. The final step is logging into the portal and submitting.
Fee Forecast: Understanding EPR Costs In Oregon And Colorado
Let's break down the Oregon fees versus the Colorado fees. The Colorado fees, at first glance, look higher than the Oregon fees if you were to take a snapshot. The reality is, the Oregon fees are not for a full year of the program. If you do some estimate of what future Oregon fees could look like, then the Oregon fees don't look as much lower than the Colorado fees.
In fact, in every category, the Colorado fees are lower except for the categories of paper slash fiber, or printing and writing paper. This is due to the nuance difference that Colorado was looking at for laminated, wax, or poly-coded paperboard. There's a higher fee as well as small-format items tied to the recyclability of those elements. That's the fee structure.
Between Oregon and Colorado, on average, you're seeing $0.2 to $0.3 difference between the fees at a category level. When I say category, I mean metal versus paper fiber versus plastic flexible. That’s a higher-level category because those subcategories are different. On average, you're seeing 20% to 30% difference in fees. It's significant-ish, but it's not dramatic.
You should expect these fees to evolve over time for a couple of reasons. One, there are going to be more producers that come on board. That will lower fees for all producers. As they identify more obligated producers that may have missed the deadlines and bring them in for the next reporting cycle, that will lower the fees.
You should expect these fees to evolve over time.
Also, the costs will change, in general, of what it costs to improve the program. That will adjust the fees. It depends on whether that will go up or down. I think in the long run, it will go down. It might go up at first as it costs more to invest and change things. That's what the program plan is for. It’s to make it even across the years to anticipate these fees. That’s what CAA is doing. They’re balancing the nature of investment needed versus producer participation in calculating these fees.
Key takeaways from a fee perspective are that you can anticipate Oregon's fees to increase in 2026, but it won't go up as much every year following. It should be more of a one-time increase. It's because of the 6-month denominator, if you will, versus a 12-month denominator. Colorado is generally higher in fees for the paper category and lower in all other categories.
You should anticipate fee timelines to sync up. Oregon and Colorado will announce a 2026 final fee schedule for both in October 2025. There's no other reporting deadline for Oregon. They will use the same data set, but you'll see the final fee schedule for 2026 invoices that will come out in January 2026. That will be announced in the October-ish timeframe of 2025. Moving forward, the Oregon and Colorado timelines will be synchronized. As states come online, they will work to synchronize those states as well.
Strategic EPR Planning: Lessons From Oregon And Colorado
What should you do next? Think of Oregon as the dress rehearsal. Start there if you can. Don't reinvent the wheel if you don't have to, and build from there. Learn from what you've done and add to your Colorado sales. Be as precise as possible. The quality of your data in 2025 impacts your invoices in 2026. It helps you identify your gaps. The more detailed you can get, the more you can start to look at the strategy of EPR. It’s like, “What is this costing me per SKU? Where are my heavy-hitters? Where are my areas of opportunity?”
Finally, get ahead of fee planning. Not paying in 2026 doesn't mean you shouldn't start budgeting in 2025 and thinking through what this will mean for your business. EPR is rolling out fast. If you're operating in multiple states, you're likely already juggling all these different timelines, templates, and expectations. Colorado's deadline is imminent on July 31st, 2025. It's the second state.
Just because you're not paying in 2026, doesn't mean you shouldn't start budgeting now and thinking through what this will mean for your business.
Oregon’s program has kicked off. They're starting reimbursements. If you can get it in 2025, then that will help you set yourself up for success in 2026’s reporting cycle, California’s reporting cycle, and Maine’s reporting cycle. The more you can do to start to unpack what your packaging components are for this reporting, the better you'll be set up for success.
Why embrace this change of EPR reporting and thinking about EPR reporting strategically? It is to find process improvement areas for 2026. At the end of each reporting cycle, you should do a retrospective. I've told you before that I'm a big fan of retrospectives. What went well? What didn't work? Each time, find opportunities for improvement and opportunities to reduce waste.
Continue to move forward and see the strategic opportunity here. Where can you start to use this granularity to make business decisions? If you embrace it in that way, then it will hopefully and ultimately help you find a way to remove waste in your fees. If you do nothing with EPR, it will cost you, but doing the work now can give you that strategic advantage later.
Thank you for your time. Thank you for being here. There are plenty of us consultants out there to help with EPR reporting if you're struggling. Tune in to our next episode where we pull back the curtain on the most talked-about policies related to circularity. The question is, are policies like EPR, landfill bans, and deposit schemes driving us toward a circular economy or shifting the burden? From promising progress to painful trade-offs, we unpack what's working, what's failing, and what's needed to evolve. If we want a future built on circularity, our policies can't just sound good. We have to think about how to make them work and how to make them better.
Important Links
Episode - What is EPR?