Colorado
Colorado’s Producer Responsibility program for packaging and paper products requires covered producers to join a Producer Responsibility Organization (PRO), and through the PRO, fund and manage the end of life of those materials, which includes collection, processing, and recycling or composting.
CAA was approved by the Colorado Department of Public Health & Environment (CDPHE) as the PRO that will administer Colorado’s EPR law for packaging and paper products on May 1, 2023. CAA submitted the initial Plan Proposal to Colorado’s Producer Responsibility Advisory Board on Feb. 3, 2025.
FAQ
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Yes. The Plan Proposal is available on the CDPHE website. An overview of EPR and CAA can be found in CAA’s General FAQs.
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With the Plan Proposal submitted, the Advisory Board has 90 days to review for compliance with Colorado’s EPR law and provide recommended amendments. CAA has 60 days to respond, after which the Advisory Board must forward the Plan to CDPHE with its recommendation for approval or rejection.
CDPHE will publish the Plan and is expected to open public comment September through December, after which they must either approve or reject the plan. If the full timeline is utilized and CDPHE approves the plan, that approval would occur near the end of December 2025 with implementation starting in early 2026.
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Once CAA responds to any Advisory Board input, the Advisory Board will forward the plan to CDPHE, who will post the plan on their website and open public comment. Public comment is expected to open in September 2025. In the meantime, Advisory Board meetings are open to the public.
The Plan Proposal incorporates Needs Assessment findings along with extensive feedback solicited by CAA during a robust consultation process. More than 2,000 representatives of Colorado businesses, governments, trade associations, and nonprofits engaged in the process. Once a Final Plan is approved, CAA will submit detailed annual reports, and the Advisory Board will have continued opportunity to recommend changes.
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Covered materials are defined in the Act and include packaging and paper products. The covered materials can be broken down into 2 lists:
Minimum Recyclable List (MRL) – The list of covered materials that must be collected statewide in a manner that is as convenient as the collection of solid waste.
Additional Materials List (AML) – Covered materials not on the minimum recyclables list that may be collected in different geographic areas through curbside services, drop-off centers, or other means.
CAA Colorado recognizes that a phased approach is necessary to collecting and processing items on the MRL and AML. Communities can learn more about this phased approach and see the full MRL and AML in Chapter 7 of the Plan Proposal.
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While the Plan Proposal and implementation details are not yet approved, communities can learn more by reviewing Chapter 6: Service Provider Reimbursement. For local governments, the first step toward participating in the EPR program will be to respond to the local government Request for Reimbursement (RFR). Local governments will be asked to submit information to CAA such as who provides recycling services (if applicable), their recycling service costs (if known), the number of households serviced, and the existing education and outreach efforts. This data will be the basis of future service agreements for reimbursement. Communities that wish to participate in the program should email coloradoinfo@circularaction.org.
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Colorado’s EPR program is projected to expand access to convenient recycling services for to up to 700,000 households and nearly double the recycling rate of paper and packaging in the state. The plan is also expected to reduce greenhouse gas emissions by an estimated 1.3 million metric tons of carbon dioxide - equivalent to 278,000 cars’ worth – annually by 2035.
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Producers should register with CAA now – it’s free – to participate in educational forums and events designed to prepare producers. CAA also developed guidance materials to provide more detailed reporting instructions. Find key details in the Producer Resource Center.
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The Plan Proposal incorporates Needs Assessment findings along with extensive feedback solicited by CAA during a robust consultation process. As required by law, elements of the Plan Proposal include producer compliance, minimum recyclables list, recycling goals, education and outreach, and more. Download a Colorado EPR Fact Sheet, or see the full plan on the CDPHE website.
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Implementation and reimbursement timelines will vary across communities due to a variety of factors. The Colorado Plan Proposal outlines a Service Approach timeline, including implementation in different types of communities, starting on page 52. No service agreements will be signed prior to final Plan approval by CDPHE, which is anticipated to occur in December 2025. See Chapter 5: Recycling Services Approach for additional details.
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There is no requirement for governments, tribes or service providers to participate in the EPR program. Eligible service providers that choose to participate in the program will be reimbursed for 100% of the eligible net service costs of provided recycling services as required by the Act. Colorado’s waste service providers and communities that elect to participate in the program will no longer charge consumers for recycling services that are being provided on behalf of CAA, as required by the state law.
Key Milestones in the Regulatory and Implementation Process
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June 3, 2022
Governor Polis Signs HB22-1355.
State Rulemaking Updates
Consumer Price Index Rule
Colorado’s Producer Responsibility Program for packaging and paper products requires CDPHE to adjust the de minimis small producer exemption based on the Bureau of Labor’s Consumer Price Index annually by July 1. The rule went into effect in 2023.
Primary Regulations
On December 7, 2023, CDPHE initiated the process of establishing producer responsibility regulations by releasing a first draft of the proposed rules. The Colorado Solid Hazardous Waste Commission approved the final rules on June 14, 2024.
Eco-modulation Regulations
Beginning in 2025, CDPHE will conduct stakeholder meetings for the eco-modulation rule concept. CAA encourages all producers to monitor and participate in the regulation stakeholder meetings.
More information can be found on CDPHE Producer Responsibility Program landing page.
Advisory Board
The Advisory Board in Colorado was selected in December of 2022 and first met on January 31, 2023. The group has met monthly in 2023. As of May 1, 2023, CAA was appointed to the non-voting Producer Responsibility Organization seat on the Colorado Advisory Board. The Advisory Board will provide input to CAA and CDPHE throughout the needs assessment process and program plan implementation.
