Colombia EPR

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What is Colombia EPR Packaging

Colombia’s packaging EPR regime is based primarily on Resolution 1407 of 2018 of the Ministry of Environment and Sustainable Development, as amended by Resolution 1342 of 2020. These rules regulate the environmental management of waste packaging made of paper, cardboard, plastic, glass and metal placed on the Colombian market, including imported packaging. The core obligation is for producers to formulate, implement and keep updated a packaging waste management plan.

The operational regulator for producer plans is the ANLA (Autoridad Nacional de Licencias Ambientales). ANLA states that all producers in scope must submit, implement and maintain either an individual or collective packaging waste management plan. Colombia therefore operates a plan-based EPR model, rather than a simple registration-plus-fee model.

Colombia’s packaging framework also sits within the country’s broader circular-economy and REP policy agenda. In addition, Resolution 0803 of 2024 partially implemented Law 2232 of 2022 on certain single-use plastics and expressly states that it also applies to packaging producers, so businesses should monitor both the core packaging REP rules and newer plastic-specific obligations.

Does this apply to e-commerce & online sales

Yes. Colombia’s packaging EPR rules apply based on who places packaged goods on the Colombian market, not on whether the goods are sold offline or online. ANLA’s published guidance states that the regime covers producers that manufacture, import, or place on the market branded packaged goods for final consumers in Colombia.

This means cross-border e-commerce can fall within scope. A foreign seller that imports packaged goods into Colombia for sale to final consumers, or places own-brand packaged goods on the Colombian market, can trigger EPR obligations. The online channel itself does not remove liability.

In practice, foreign businesses usually need a Colombian operating structure that can file through VITAL and interact with ANLA. The formal system is built around a producer plan submission process in Colombia, so a purely offshore seller with no local compliance footprint may struggle to comply directly. That makes importer structure and local brand ownership analysis especially important for foreign sellers.

Who is the “producer” under Colombia EPR?

Under Colombia’s packaging rules, a producer includes the entity that:

  1. Manufactures, assembles or remanufactures goods under its own brand for commercialization in Colombia to the final consumer, where those goods are contained in packaging
  2. Imports goods contained in packaging for placement on the Colombian market to the final consumer
  3. Places goods on the market as the owner of the brand shown on the packaging

For foreign companies, the key risk points are importer status and brand ownership. If a foreign company is the party importing packaged goods into Colombia, or is the brand owner placing those goods on the market, it may be the obligated producer even if sales occur through distributors or online channels.

Who must register for EPR packaging in Colombia

Companies that fall within the producer definition must present and maintain a packaging waste management plan before ANLA. ANLA’s guidance is explicit that all producers in national territory must formulate, file, implement and keep their plan updated.

The relevant public authority is ANLA, and the filing platform is VITAL (Ventanilla Integral de Trámites Ambientales en Línea). ANLA’s filing instructions explain that the initial submission and subsequent advance reports for packaging plans are made through VITAL.

Unlike some countries, Colombia does not rely on a single national PRO as the first legal step. The first legal step is being in the ANLA plan system. A producer may then comply through an individual plan or join a collective plan.

Colombia EPR Packaging Registration Threshold

Colombia does not set a general turnover threshold or minimum tonnage threshold for packaging EPR. ANLA’s published FAQ expressly states that there is no minimum or maximum quantity of packaging placed on the market for a company to be considered a producer and fall within the scope of the regulation.

For foreign companies, that means the obligation can arise from the first in-scope commercial activity if the company matches the producer definition. There is no de minimis threshold comparable to the turnover-and-tonnage thresholds used in some European regimes.

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Packaging Covered (and Excluded)

Colombia’s packaging EPR rules cover primary, secondary and single-use sales packaging made of paper, cardboard, plastic, glass and metal, whether domestically produced or imported, where the packaging is designed to constitute a sales unit to the final consumer.

In practical compliance terms, the covered packaging types include:

  1. Primary packaging
  2. Secondary packaging
  3. Single-use sales packaging used to place goods on the market to final consumers

The main exclusions identified by ANLA are:

  1. Packaging that becomes hazardous waste under applicable rules
  2. Packaging made of wood and of textile or natural fibers other than paper and cardboard
  3. Pharmaceutical and medicine packaging

Producer Responsibility Organization (PRO)

Colombia does not operate with one mandatory national packaging PRO. Instead, producers must submit either an individual plan or a collective plan to ANLA. The collective-plan route functions as the Colombian equivalent of a PRO-based compliance approach, but the legal obligation remains tied to the producer’s approved ANLA filing.

For foreign companies, this means that joining a collective scheme can be commercially efficient, but it does not replace the need to ensure the Colombian producer entity is correctly identified and that the ANLA plan obligations are properly handled.

EPR Registration in Colombia

The practical compliance process in Colombia is usually:

  1. Determine which entity is the Colombian producer under the rules
  2. Confirm which packaging materials and formats are in scope
  3. Prepare an individual or collective packaging waste management plan
  4. File the plan through VITAL before ANLA
  5. Implement collection, return, traceability and recovery measures under the plan
  6. Submit annual advance reports through VITAL
  7. Keep the plan updated as business operations or packaging flows change

ANLA’s instructions show that VITAL is the filing channel both for the initial packaging plan submission and for the annual advance reports.

Authorized Representative

Colombia’s packaging EPR regime does not use a standard foreign-producer authorized representative model like some EU systems. The rules are framed around the producer itself and the filing of the producer’s plan before ANLA.

In practice, foreign companies usually comply through:

  1. A Colombian importer
  2. A Colombian subsidiary
  3. A local brand-owning entity
  4. A local legal representative or advisor managing the ANLA/VITAL process on behalf of the Colombian obligated entity

So while Colombia does not clearly require an “authorized representative” by that name for packaging REP, foreign companies generally need a local entity or local legal presence capable of filing and operating the plan in Colombia.

What Data Must Be Reported

Colombia’s packaging system is data-heavy. Producers must report the quantities of packaging placed on the market and the quantities effectively returned and recovered under the plan. ANLA’s official templates and instructions refer to packaging weights, returned quantities, recovered quantities, and material-level reporting logic.

In practice, producers should maintain at least:

  1. Packaging weight by material
  2. Packaging quantities placed on the Colombian market
  3. Quantities collected, returned and recovered
  4. Evidence from transformers/recyclers supporting recovery
  5. Documentation for consumer awareness and source-separation measures
  6. Supporting information for multimaterial packaging composition

ANLA’s reporting template also states that for multimaterial packaging, the dominant material can be used for reporting only when it exceeds 70% of total packaging weight; otherwise all materials must be reported.

First Reporting Period & EPR Reporting Deadlines

The original compliance timetable was reset by Resolution 1342 of 2020. ANLA’s published FAQ states that producers already operating before 31 December 2018 had to submit their initial plan by 31 January 2021, while producers created from 1 January 2019 onward had to submit their plan no later than 31 December of the year following their first fiscal operating period.

For ongoing compliance, ANLA states that the first and subsequent annual advance reports are filed in March and April according to the schedule in Table 1 of Resolution 1342 of 2020, which is linked to the producer’s identification schedule.

For a foreign company entering Colombia now, the practical point is that obligations do not begin with a later mass registration campaign. They begin when the company becomes an in-scope producer and must therefore prepare and submit its plan on the timetable applicable to new producers.

Labels & Marketing Claims

Colombia’s packaging EPR rules do not create a general nationwide mandatory disposal label for packaging comparable to some EU sorting-label systems. The core packaging resolutions focus on plan submission, collection, recovery, traceability, consumer awareness and reporting rather than a universal on-pack marking requirement.

That said, producers are expected to implement consumer awareness and source-separation measures under their plans. This means packaging communication still matters operationally even though Colombia’s packaging EPR regime is not built around a mandatory national label.

Environmental marketing claims should be used carefully. Businesses should ensure that recyclability or sustainability statements are consistent with the actual material, collection and recovery route used in Colombia, especially where multimaterial or hard-to-recycle packaging is involved. This is an inference from the reporting and recovery structure, not a separate Colombia-specific green-claims code within Resolution 1407 itself.

EPR Eco Fees & Eco-Modulation

Colombia does not currently publish a single national packaging eco-fee tariff equivalent to the fee tables used in some European EPR systems. Instead, producers bear the cost of implementing their individual or collective plan, including collection, storage, transport, traceability and recovery activities.

In addition, ANLA charges regulatory fees for evaluation and follow-up of environmental control instruments, including REP-related procedures, under Resolution 1140 of 2022. That is a public-law administrative fee and is separate from the producer’s operational recycling costs.

Colombia’s packaging rules are therefore cost-bearing, but not yet structured as a mature eco-modulated national fee schedule by packaging design. In practice, costs are driven by the chosen compliance model and the actual packaging portfolio rather than by a statutory bonus-malus table.

Risks, Penalties & Common Mistakes

The most common compliance mistakes in Colombia are:

  1. Assuming there is a minimum tonnage threshold before the rules apply
  2. Treating e-commerce imports as outside scope
  3. Misidentifying the producer where importer, manufacturer and brand owner are different entities
  4. Reporting only primary packaging and ignoring secondary or single-use sales packaging
  5. Misclassifying excluded packaging, especially hazardous packaging and pharmaceutical packaging
  6. Failing to file the plan in VITAL before relying on a collective arrangement
  7. Using incomplete evidence from recyclers or transformers for recovery reporting

Enforcement sits with Colombia’s environmental authorities, including ANLA, under the environmental sanctioning framework of Law 1333 of 2009, as amended by Law 2387 of 2024. ANLA explains that environmental sanctions and preventive measures exist to stop or correct violations of environmental law.

What E-Commerce Sellers Should Do Now

  1. Identify which entity is importing or branding the packaged goods in Colombia.
  2. Confirm whether that entity is the producer under Resolution 1407 of 2018.
  3. Map all in-scope packaging materials, including secondary and single-use sales packaging.
  4. Build a packaging data file with weights, material composition and recovery evidence requirements.
  5. Decide whether to comply through an individual or collective plan.
  6. Set up VITAL access and prepare the ANLA plan filing.
  7. Review whether any packaging is also affected by Resolution 0803 of 2024 and Law 2232 of 2022 on certain single-use plastics.

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FAQ

Is Colombia packaging EPR mandatory?
  • Yes. Colombia’s packaging EPR regime is mandatory under Resolution 1407 of 2018, as amended by Resolution 1342 of 2020, and requires producers to submit and operate a packaging waste management plan before ANLA.
Do foreign sellers need to comply?
  • Potentially yes. If the foreign seller is the importer, brand owner or other entity placing packaged goods on the Colombian market, it can be the producer for REP purposes.
Is there a threshold in Colombia?
  • No general turnover or tonnage threshold applies. ANLA states that there is no minimum or maximum quantity of packaging placed on the market for the regulation to apply.
Are packaging labels mandatory in Colombia?
  • Colombia does not currently have a general mandatory national packaging disposal label under the core packaging EPR resolutions. The system focuses on producer plans, recovery and consumer awareness measures.
Are online marketplaces automatically responsible?
  • Not automatically. Liability follows the producer definition in the packaging rules, especially importer status, brand ownership and placement on the Colombian market, rather than marketplace status alone.

Battery EPR law in Colombia: None enacted

Colombia is not among the countries with enacted battery EPR legislation.

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Textile EPR law in Colombia: None enacted

Colombia is not among the countries with enacted textile EPR legislation.

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March 26, 2026 129
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