Colorado Producers Subject to EPR Law Must Register by Oct. 1

Producers subject to Colorado’s Extended Producer Responsibility (EPR) law are required to register with the Circular Action Alliance (CAA) by October 1, 2024, unless exempted. The deadline was established this summer through a state rulemaking process (Producer Responsibility Regulations, Section 18.2.4(A)(1)).* To register, producers need to submit their name, email, phone, and primary contact in writing to CAA via its website.

As background, Colorado’s Producer Responsibility Program for Statewide Recycling Act (HB 22-1355), which was signed into law on June 3, 2022, requires producers of packaging and paper products to fund a statewide recycling system for those materials. The Colorado Department of Public Health and Environment appointed CAA as the producer responsibility organization (PRO) that will implement and manage the recycling program created by HB 22-1355. CAA is responsible for creating a list of items that can be recycled and for establishing targets for minimum collection rates, recycling rates, and post-consumer recycled content rates.

Effective July 1, 2025, a producer may not sell or distribute any products that use covered materials in Colorado unless the producer is participating in the program or an approved individual plan. Producers must pay the first annual dues to the PRO by January 1, 2026.

*Section 18 of the Producer Responsibility Regulations can be accessed from the Producer Responsibility Program webpage. The link is under the subhead, “Adopted rulemakings.”