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Retail Delivery Fees Are the Next Sales Tax Headache: What Colorado and Minnesota Charge and Who Must Collect

4 min leestijdMike ThriftMike Thrift
Retail Delivery Fees Are the Next Sales Tax Headache: What Colorado and Minnesota Charge and Who Must Collect

Retail delivery fees (RDFs) look like sales tax, sit on the same return as sales tax, and are remitted with sales tax — but in Colorado and Minnesota, they are legally fees, not taxes, with their own thresholds, exemptions, and invoice rules. If you ship taxable goods to customers in those states, you may owe a per-delivery fee on top of the sales tax you already collect.

How the Two Active Fees Work

Colorado — $0.29 per retail delivery (2025–2026 rate, indexed annually). Applies to each retail delivery by motor vehicle of tangible personal property subject to Colorado sales tax. One order shipped together is one delivery, regardless of how many boxes it takes. The fee is actually six sub-fees (air pollution, bridge, road safety, etc.) aggregated into a single line, and the total is adjusted for inflation each year.

Minnesota — $0.50 per retail delivery where the transaction is $100 or more. Effective July 1, 2024, applies to each transaction of taxable tangible goods delivered in Minnesota meeting the $100 threshold. Deliveries of food and products generally exempt under the sales-tax code are excluded, except clothing, which remains subject to the fee when the threshold is met. Unlike Colorado, Minnesota's fee is not limited to motor-vehicle deliveries in the statute.

Both fees are imposed on the purchaser but collected and remitted by the retailer or marketplace facilitator that collects sales tax. The fees are due on the same filing frequency as the retailer's sales-tax return.

Who Must Collect — and When You Are Exempt

The RDF thresholds are separate from sales-tax nexus thresholds and differ by state:

StateSmall-seller exemption
ColoradoRetailers with Colorado retail sales < $500,000 in the prior year; marketplace facilitators with sales < $100,000
MinnesotaRetailers with Minnesota retail sales < $1,000,000 in the prior year; marketplace facilitators with sales < $100,000

If you are under the RDF threshold, you are not required to collect the fee even if you have sales-tax nexus and collect sales tax. If you exceed it, you collect the fee on every qualifying delivery, even small-dollar ones in Colorado.

Marketplace facilitators — Amazon, Walmart Marketplace, and similar — collect on facilitated sales and many retailers assume they are covered. Verify whether your facilitator collects the RDF, not just sales tax; marketplace laws and RDF laws were enacted separately and facilitator definitions do not always align.

Invoice, Accounting, and Compliance Traps

Separately stated. Colorado requires the retail delivery fee to be stated separately from sales tax on any invoice, receipt, or checkout total, and it may not be combined on the same line as sales tax. Minnesota has similar disclosure expectations. Combining them creates an audit finding even when the total collected is correct.

Not sales tax for income-tax purposes. The RDF is not a sales tax and not a deductible state tax in the same way. In your books, keep it distinct: credit Liabilities:RetailDeliveryFee:CO and Liabilities:RetailDeliveryFee:MN at collection, debit on remittance. Do not net it against Liabilities:SalesTax.

Return mechanics. Colorado retailers report the fee on the state sales-tax return (DR 0100) on a dedicated RDF line; Minnesota reports on the sales-tax return as well. A zero-fee period may still require a fee line showing zero, depending on your filing.

Threshold monitoring. Because RDF thresholds and sales-tax thresholds are measured differently and update annually, a retailer can cross one without crossing the other. Track Colorado and Minnesota retail sales separately from total sales, and calendar the prior-year measurement date.

What Is Coming Next

Bloomberg Tax and the Tax Foundation both note growing state interest in RDFs as a replacement for eroding gas-tax revenue as fuel efficiency rises and EV adoption grows. Colorado and Minnesota are the only statewide RDFs in effect, but legislation has been introduced in several other states and more are studying the model. The pattern — small per-delivery amount, motor-vehicle nexus, small-seller exemption — is likely to repeat.

Simplify Your Financial Management

Delivery fees multiply the work you already do for sales tax: another liability to track, another line on the invoice, another reconciliation. Beancount.io keeps retail delivery fees as distinct liabilities by state, reconciles them to processor payouts, and ties each remittance to the return it covers — plain text, version-controlled, auditable. Get started for free and make the next new fee a config line, not a fire drill.

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