Colorado HB 22-1355 Compliance Checklist
Use this checklist to prepare packaging and paper product data for Colorado producer responsibility reporting.
1. Include packaging and paper products in your Colorado data set.
Why it matters: Colorado's program covers both packaging and paper products.
Common pitfall: Teams often capture packaging but forget paper inserts and mailers.
2. Map Colorado sales to matched product records.
Why it matters: Unmatched sales SKUs cannot reliably connect to BOM data.
Common pitfall: Marketplace SKU aliases often break matching.
3. Create a list of every SKU sold into EPR states.
Why it matters: EPR reporting starts with state-specific sales volume by SKU.
Common pitfall: Do not use national sales as a proxy for state sales unless the program explicitly allows it.
4. Build a packaging BOM for each covered SKU.
Why it matters: Reports need component-level material and weight data, not product-level guesses.
Common pitfall: Gift sets, bundles, labels, inserts, and ecommerce mailers are often missed.
5. Classify every component into a material category.
Why it matters: Fees and reporting formats are organized around material categories.
Common pitfall: Avoid broad labels like plastic, paper, or metal when PET, HDPE, PP, paperboard, or aluminum is known.
6. Collect supplier evidence for weights and materials.
Why it matters: Spec sheets, COAs, and technical drawings support audit defense.
Common pitfall: A sales quote is not enough if it lacks material and weight details.
7. Track PCR content separately from total recycled content.
Why it matters: Eco-modulation and recycled content reporting may distinguish post-consumer content.
Common pitfall: Do not assume total recycled content is PCR.
8. Run a validation check before generating reports.
Why it matters: Validation surfaces missing BOMs, stale sales data, and incomplete supplier responses.
Common pitfall: Generating reports before resolving critical gaps creates rework.
Get help with this checklist
Start with a PackBOM EPR Data Audit and get a clear map of your packaging compliance gaps.
Related Resources
Check which states your brand should evaluate.
Learn how to build BOMs for EPR reporting.
Read the connected EPR guide and supporting resources.