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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Following CAA’s Feb. 3 submission of the Colorado Plan Proposal, the State’s Advisory Board reviewed the Plan Proposal and on April 30, provided its amendment requests. 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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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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With the July 31, 2025 reporting deadline for Colorado's Extended Producer Responsibility (EPR) packaging law fast approaching, producers must take immediate steps to comply with regulatory requirements. Unregistered producers should register today with CAA.
The portal for supply reporting is now open; producers need to sign the Colorado State Addendum (COSA) before they can submit a supply report for Colorado. CAA is dedicated to helping producers navigate EPR with expert guidance, resources, and streamlined compliance solutions. 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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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. Learn more about the reimbursement process.
Key Milestones in the Regulatory and Implementation Process
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June 3, 2022
Governor Polis Signs HB22-1355.
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December 8, 2022
CDPHE Appoints Advisory Board Members.
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May 1, 2023
CDPHE Selects CAA as PRO and Appoints it to the Advisory Board.
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August 2023
CAA Selects HDR and Eunomia Research & Consulting as the Third-Party Contractors to Conduct the Needs Assessment.
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January 24, 2024
CAA Reports Needs Assessment Results to CDPHE.
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March 15, 2024
CDPHE Presents Needs Assessment Findings & Proposed Program Scenario to General Assembly’s Joint Budget Committee.
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April 17, 2024
General Assembly’s Joint Budget Committee Approves CDPHE-Recommended Recycling Scenario.
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October 1, 2024
Colorado Regulatory Deadline for Producers to Register with CAA.
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February 1, 2025
CAA Submits Draft Program Plan Proposal.
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July 31, 2025
CAA Deadline for Data Reporting.
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January 1, 2026
Producers Remit Dues to CAA On or Before this Date.
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Early 2026
Program Begins.
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June 30, 2026
CAA Remits First Administrative Dues to CDPHE.
Events and Updates
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.
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