Extruded

How Colorado’s Packaging EPR Program Affects Beauty Brands

Written by

Creighton Thomas

Published on

July 2, 2026

Colorado’s packaging producer-responsibility rule began charging in January 2026, and many beauty brands selling into the state now help fund the recycling of whatever they put on the shelf. The charges track packaging weight, material type, and recyclability, which means lightweight, recyclable designs carry a real cost advantage. Brands that grasp the rules early can trim compliance costs through smarter format and material choices rather than absorbing a surprise bill.

We run a contract manufacturing floor in Douglas County, so we have watched this rule take shape from inside the state. The questions reaching us have shifted too. Founders used to ask only about scent and formulation. Now they ask what their cartons will cost under the new rules, and whether a different format changes the math. It does, sometimes by a wide margin, and that is the thread running through everything below.

Key Takeaways

Colorado’s charges began in January 202 and recur each year thereafter.
The brand owner whose trademark sits on the product usually owes the money, not the factory.
Packaging weight drives the bill, so heavier containers cost more.
Eco-modulation rewards recyclable, single-material designs with lower charges.
Solid, waterless formats generally carry far less fee exposure than bottled liquids.
Seven states now run similar laws, so the issue is national, not local.

What Colorado’s Recycling Law Actually Requires

The rule has a formal name: the Producer Responsibility Program for Statewide Recycling Act, passed as HB22-1355 and signed by Governor Polis in 2022. Its core idea is simple to say and harder to absorb. The cost of recycling wrappers and cartons shifts from taxpayers to the businesses that introduce those items into the market. You can read the Colorado statute on producer responsibility for recycling directly if you want the legislative text.

A nonprofit runs the day-to-day, an arrangement the state spells out on its Colorado Department of Public Health and Environment program page. Oversight rests with that department, while recurring dues, reporting, and reimbursements to local governments flow through the designated organization. The materials in scope are called covered materials, and the definition is broad:

Packaging that contains, protects, or presents a product at the point of sale
Cartons, boxes, and folding paperboard
Plastic bottles, jars, tubes, caps, and pumps
Flexible films, sachets, and pouches
Printed paper and certain paper products

What is a Producer Responsibility Organization (PRO)? A PRO is a nonprofit that obligates businesses to fund the operation of the recycling system on their behalf. It collects dues, manages reporting, and reimburses local recycling programs. In Colorado, that role belongs to the Circular Action Alliance, which was appointed in 2023 as the nation’s first such organization.

What does the timeline look like in practice? A few dates matter more than the rest:

October 1, 2024: the first producer registration deadline passed
July 2025: businesses could no longer sell items using covered materials in the state without taking part
January 2026: the first invoices for dues went out, and charges began
May 31, 2026: supply reports detailing what was sold into the state came due
October 2026: The 2027 dues schedule is expected

Colorado projects real gains from all this. The state expects its paper and packaging recycling rate to climb from 25% to 58% by 2035, reaching roughly 700,000 more households at no cost, and it forecasts about $31 million in added annual wages alongside nearly 7,900 green jobs. For a founder, though, the projection that matters most is the one on your own invoice, and that depends heavily on who you are in the eyes of the rule.

Who Counts as a Producer, and Why It Might Be You Rather Than Us

Here is the part that trips up many beauty founders working with a contract partner. People assume the factory that pressed the bar carries the obligation. Usually it does not.

Colorado sets a hierarchy, and it generally starts at the top with the brand owner, meaning the business whose name or trademark appears on the product. Only when no qualifying party exists higher up does the duty fall to a manufacturer or an importer. The order runs roughly like this:

Brand owner: the trademark on the label, first in line
Licensee: whoever directs packaging choices under a licensed mark
Manufacturer: the maker of the packaged good, if no brand or licensee applies
Importer or first distributor: relevant mainly when nobody above sits inside the United States

So when we press a private-label bar for your line, your name goes on it, which means the obligation almost always falls on you, not on our floor. The split looks like this:

Company Type	Registers and Reports	Pays the Dues	Controls Packaging Design
Brand owner (your label)	Yes	Yes	Yes
Contract manufacturer (us)	Generally no	Generally no	Advises, but you decide

We point this out not to pass the buck, but because it changes how you should think about design. You hold the pen on packaging choices, so you also hold the lever on the charges those choices produce. A brand that understands this early tends to make sharper calls than one that learns it the hard way from a surprise bill. If you want a feel for how bars come together before a single carton spec is locked in, our solid shampoo production line shows the available format options, and our press-formed extrusion process shows how the bars themselves take shape.

Does Colorado EPR apply to beauty brands? Yes. A cosmetic brand that sells packaged products in Colorado is generally treated as a producer when its trademark appears on the packaging, making it responsible for registering, reporting, and funding the recycling of that packaging.

There is a softer edge worth noting. Smaller businesses below a state-set revenue threshold may qualify for an exemption, and that threshold gets adjusted each year for inflation. The exemption is not automatic, though. A producer generally has to apply and document eligibility rather than assume it, which catches plenty of people off guard.

How the Fees Are Calculated, and the Lever You Control

Dues are not a flat sticker price. They track the material a business places on the market, by type and by weight, and then the program adjusts the figure based on how recyclable or reusable that material is.

What is eco-modulation? Eco-modulation adjusts a producer’s dues based on the recyclability and reusability of its packaging. Lightweight, single-material, recyclable designs generally draw lower charges than mixed-material or hard-to-recycle ones.

Colorado wrote eco-modulation into its rules in late 2025. The mechanism works in two directions:

Packaging that recycles cleanly and uses recycled content can earn a more favorable rate
Hard-to-recycle formats, mixed materials, and problem additives can draw a higher charge

Put plainly, the design that is easiest for a material recovery facility to handle tends to cost the least under the program, while the design that gums up a sorting line tends to cost more. A glass jar with a metal lid and a plastic pump consists of three separate parts that a consumer has to take apart. A pressed bar in a folding paperboard sleeve is, more or less, one clean stream. The EPA’s own recycling basics and waste hierarchy guidance ranks source reduction and reuse above recycling, which is the same logic Colorado’s fee structure now puts a price on.

What actually drives the number on your invoice? A handful of factors:

Total weight of covered material shipped into the state
Material type, since plastics, glass, metal, and paper carry different rates
Recyclability of each component, judged against what local facilities accept
Recycled content, including post-consumer recycled (PCR) material, is designed into the package
Any additives or coatings that complicate sorting

Here is a shop-floor pattern we keep seeing. Over the past several months, we have reviewed packaging concepts from dozens of beauty startups, and the recurring surprise is rarely the reporting paperwork. It is how much a secondary carton, a shrink band, and a wad of tissue add to the weight that the charge is built on. Trim that material, and you trim the charge. It really can be that direct.

Why Solid Formats Carry Less Fee Weight

Now the part where our bias shows, so take it with the appropriate pinch of salt. Solid, waterless formats tend to carry far less packaging weight than their bottled cousins, and under a weight-based program, that gap shows up on the bill.

Consider a standard liquid shampoo. It ships in a rigid plastic bottle, often with a separate cap or pump, sometimes inside a printed box. A solid bar doing the same job ships in a thin paperboard wrap, a small tin, or nothing beyond a band. The table below sketches how common formats tend to stack up. Treat it as directional rather than a precise quote, since the program weighs each component against local recycling capability:

Format	Typical Packaging Load	Recyclability Profile	Relative Fee Exposure
Liquid shampoo is in a plastic bottle	Bottle, closure, often a carton	Mixed; pumps complicate sorting	Higher
Cream in a glass jar	Jar, lid, frequently a box	Glass recycles, lids vary	Higher
Solid bar in paper sleeve	Thin recyclable wrap	Clean single stream	Lower
Naked solid bar	Band or none	Minimal to no covered material	Lowest
Refill pouch	Flexible film	Hard to recycle in many areas	Variable

Notice the spread. The same job can land in very different places depending on format, and that gap is exactly the lever a thoughtful brand pulls. The format range that lends itself to lean packaging is wider than people expect:

Pressed shampoo bars that ship in a single paper sleeve
Solid conditioner bars that skip the bottle entirely
Gentle synthetic detergent cleansing bars wrapped in recyclable board
Travel and hotel amenity formats are sized to cut material further

A quick note on accuracy, since terminology matters in our trade. A synthetic detergent bar is not technically “soap” under the FDA’s definition, even though it cleanses, so we label these as syndet bars rather than blur the line. That same precision keeps your packaging claims clean, which raises a point most founders miss. If you market a wrapper as “recyclable” or tout recycled content, those claims fall under federal advertising rules, not just state recycling law. The FTC’s Green Guides on environmental marketing claims set the bar for what you can say and how you can say it. Designing genuinely recyclable packaging eases both problems at once: a lower charge and a defensible label.

Where Cosmetic and Beauty Labels Fit Into the Picture

Personal care sits squarely in the crosshairs of these rules because the category relies heavily on packaging. The numbers are stark. The global beauty industry produces roughly 120 billion units of packaging every year, a figure traced to the British Beauty Council and the Ellen MacArthur Foundation, and packaging accounts for around 70% of the cosmetics sector’s waste. In the United States alone, a 2018 Forbes analysis estimated rigid plastic output for personal care at nearly 7.9 billion units. Layer on the wider reality that only about 9% of all plastic ever made has been recycled, and the scale of the problem these laws target comes into focus.

So which components fall in scope for a cosmetic line? The table below maps it out:

Category	Examples	In Scope?
Primary containers	Bottles, jars, tubes	Yes
Closures and applicators	Caps, pumps, droppers	Yes
Secondary packaging	Cartons, folding boxes	Yes
Flexible packaging	Films, sachets, pouches	Yes
Printed paper	Inserts, leaflets	Yes, in Colorado
Transport packaging	Pallet wrap, shippers	Varies by state

The average beauty product is a small parade of covered material, and almost all of it counts. Founders who plan packaging around recyclability, rather than treating it as an afterthought once the formula is set, tend to come out ahead. Why pay for material when the program will only charge you to recycle?

Colorado Versus Other State Packaging Laws

Colorado is not acting alone, and any label selling nationally needs the wider view. Seven states have now passed packaging producer-responsibility laws, each with its own scope and timeline:

State	Law	Fees Begin	Administering Organization
Maine	LD 1541 (2021)	To be set	Not yet designated
Oregon	SB 582 (2021)	July 2025	Circular Action Alliance
Colorado	HB22-1355 (2022)	January 2026	Circular Action Alliance
California	SB 54 (2022)	2027	Circular Action Alliance
Minnesota	HF 3911 (2024)	Phased toward 2029	Circular Action Alliance
Maryland	SB 901 (2025)	Around 2028	Multiple organizations permitted
Washington	SB 5284 (2025)	The program starts later	Not yet designated

Cosmetic packaging counts as consumer packaging in every one of these, so a beauty label shipping nationally can face several obligations at once. The same nonprofit administers the system in five of the seven, giving multi-state sellers a single point of contact in those states. Even so, the patchwork is real. The identical lip balm carton can trigger different reporting duties and different charges depending on where it ships. More states keep circling, too, with bills surfacing in New Hampshire, Wisconsin, and elsewhere. The practical takeaway stays steady: design lean and recyclable once, and you cut exposure across every system at the same time.

Packaging Decisions That Lower Exposure

So what should a founder actually do with all this? Plenty, and most of it is design work rather than paperwork. A useful mental model is the 7 R’s of sustainable packaging: rethink, refuse, reduce, reuse, recycle, recover, and replace. The exact list varies by source, but the spirit holds, and the earliest R’s tend to move costs the most.

Concrete moves that tend to pay off:

Reduce total material weight, since weight is the basis of the charge
Rethink whether a bottle is needed at all, or whether a bar does the job
Refuse unnecessary secondary cartons and decorative filler
Choose single-material components that a facility can sort without disassembly
Build in recycled content where the formula and format allow
Drop coatings, mixed laminates, and additives that complicate sorting

There is an operational side too, beyond the design table:

Confirm whether your revenue clears the exemption threshold, and apply if it does
Register and report on time to keep the right to sell in the state
Track which states you ship to, since obligations follow the shelf, not your office
Keep packaging specs documented, because reporting asks for material and weight details

We will be honest about one tension. Lean packaging sometimes fights with shelf drama and unboxing theater, and not every brand wants to give those up. That is a real trade-off, not a slam dunk. Still, the direction of regulation is fairly clear, and the brands adjusting now seem less rattled than the ones waiting for a bigger bill. For founders who like to keep a pulse on where the category is heading, our shop-floor notes and industry write-ups cover much of this ground from a maker’s perspective.

About the Manufacturer Behind This Guide

MidSolid Press & Pour is a contract manufacturer of solid shampoo and conditioner bars based in Douglas County, Colorado, which means we sit inside the very program described here. We run both private label, where we build a custom formulation for your brand, and white label, where you rebrand an existing format. Our minimum order is 5,000 bars, and our weekly capacity is 35,000 bars, so we tend to fit brands past the sampling stage and into real production volume. You can read more about our company background and approach.

Frequently Asked Questions

What is EPR in cosmetics?

In the beauty world, extended producer responsibility means the brand that sells a cosmetic pays toward recycling the packaging it puts on the market. It applies to the container and carton, not the formula inside. Jars, tubes, pumps, droppers, and boxes all count as covered material. The brand owner whose name appears on the product is typically the obligated party, and the charge usually scales with the amount of packaging that ships and how easily that packaging can be recycled.

What states have passed packaging EPR laws?

Seven states have enacted packaging producer-responsibility laws as of 2026: Maine and Oregon in 2021, Colorado and California in 2022, Minnesota in 2024, and Maryland and Washington in 2025. Each sets its own scope, deadlines, and fee structure, so a product sold nationally can face several obligations at once. Circular Action Alliance administers the system in five of those states. Additional legislatures, including New Hampshire and Wisconsin, have introduced similar bills, so the count is widely expected to grow.

What are the 7 R’s of sustainable packaging?

The 7 R’s are a design hierarchy for cutting packaging waste, commonly listed as rethink, refuse, reduce, reuse, recycle, recover, and replace. Some versions swap in repair or rot, but the logic stays consistent: prevention beats disposal. The earliest steps carry the most weight, since refusing or reducing material avoids waste before it exists, while recycling handles what remains. For brands facing recycling charges, the framework also serves as a cost guide, as lighter, cleaner packaging tends to incur lower fees.

What packaging is included in EPR?

Most consumer-facing packaging falls within these programs. That covers primary containers such as bottles, jars, and tubes, as well as closures, pumps, and applicators. Secondary cartons, folding boxes, films, bands, and protective inserts also count, along with e-commerce mailers and shipping materials. Many programs also fold in printed paper. Industrial or transport packaging is sometimes treated differently by the state. The practical rule of thumb: if it wraps, holds, or presents a retail product and then becomes household waste, it is probably in scope.

Does Colorado’s program apply to e-commerce sales?

Yes. The rules cover items sold or distributed in Colorado, regardless of channel, so online orders shipped to residents fall within the scope the same way shelf products do. The obligation generally rests with the brand owner whose trademark appears on the item, not the platform through which it is sold. E-commerce often adds a layer of covered material, since mailers, void fill, and protective wrap all carry weight. Brands selling direct should fold that shipping packaging into their reporting and design decisions, not just the retail carton.

Can small beauty brands be exempt?

Possibly. Colorado allows an exemption for producers whose revenue falls below a state-set threshold, which is adjusted each year for inflation. The exemption is not automatic, though. A qualifying business generally has to apply and document its eligibility, rather than simply assuming it owes nothing. Thresholds and procedures also differ from state to state, so a brand exempt in one place may still owe in another. When in doubt, confirm status before a deadline passes rather than after an invoice lands.

Does Colorado charge by package count or by weight?

Mostly by weight and material type, not by a flat count of packages. The program looks at how much covered material a business ships into the state, sorted by category, then adjusts the figure through eco-modulation based on recyclability. Two products with the same unit count can owe very different amounts if one uses a heavy glass jar with a pump and the other uses a light paper sleeve. That weight basis is precisely why trimming material, not just unit volume, lowers the charge.

Are cosmetic pumps and caps recyclable?

Often not through curbside programs. Pumps, droppers, and many dispensing caps combine plastic with metal springs or mixed resins, and their small size lets them slip through sorting equipment at recovery facilities. Local rules vary, so a component accepted in one area may be landfilled in another. Under an eco-modulated charge, these hard-to-recycle parts can also drive up fees. Designing closures from a single, widely accepted material, or skipping the pump entirely with a solid format, sidesteps both problems.

Talk to a Manufacturer Who Lives Under These Rules

Sitting in Colorado, we see this program up close and build the kind of lean, recyclable formats that tend to land more softly under it. If a recycling charge is reshaping how you think about your line, a short conversation can save you guesswork later.

Ask us about pressed and private-label shampoo bar production designed for minimal packaging, and we will discuss the specifics for your brand. When you are ready for numbers, reach out to our team for a quote, and we will map out a format that fits your volume and shelf.