CAA Submits Proposed Producer Responsibility Plan to Colorado Advisory Board
An important milestone has occurred in the implementation of Colorado’s Extended Producer Responsibility (EPR) law for packaging and paper. On February 3, 2025, the Circular Action Alliance (CAA) – the organization designated as the Producer Responsibility Organization (PRO) under Colorado’s EPR law – submitted its initial Plan Proposal to the state’s Producer Responsibility Advisory Board. The Plan Proposal describes how CAA will implement the EPR law in Colorado. The draft Plan Proposal and appendices can be accessed from the Colorado Department of Public Health and Environment (CDPHE) Producer Responsibility Program webpage.
As background, Colorado’s Producer Responsibility Program for Statewide Recycling Act (HB 22-1355) was signed into law on June 3, 2022. It requires producers of single-use packaging (i.e., brand owners of goods sold in single-use packaging) and paper products to fund a statewide recycling system for those materials. Producers of packaging and paper were required to join CAA by October 1, 2024.
The CAA Plan Proposal does the following:
- Describes how CAA will track compliance,
- Provides a uniform list of recyclable materials that must be collected,
- Sets targets for minimum post-consumer recycled (PCR) content,
- Sets 2030 and 2035 collection and recycling rates,
- Describes an approach for setting dues,
- Describes how participating service providers will be reimbursed for 100% of the net recycling services costs,
- Proposes an approach to measure the use of reusable and refillable covered materials,
- Proposes an educational and outreach program, and
- Ensures that collected covered material will be transferred to a responsible end market.
Colorado’s Producer Responsibility Advisory Board will now review CAA’s Plan Proposal for compliance with the law and provide feedback within 90 days of receipt, after which CAA will have 60 days to respond. Then, the Advisory Board must forward the Plan Proposal to CDPHE, which administers the EPR program, with its recommendation for approval or rejection. Once CDPHE approves the plan, there will be a public comment period, anticipated later this year. Final approval of the Plan Proposal is expected by December 2025, and implementation of the plan is expected to begin in early 2026.