“EPR is a complex and constantly moving target. As a brand, what should you be doing right now to prepare for upcoming regulations? At NPE: The Plastics Show, John Hite, [Regulatory & Stakeholder Engagement Advisor] at Circular Action Alliance (CAA), provided a primer on EPR for Packaging, CAA, and what you need to do to meet upcoming deadlines.”

“The program requires applicable product producers to contribute a small amount of funds for recycling of the products and packaging the companies sell in the state. The funds will help manage the end of life of materials through collection, processing and recycling, or composting.

”Colorado designated Circular Action Alliance in May 2023 as the Producer Responsibility Organization to coordinate, fund and manage the statewide recycling system.”

“CAA, a brands-led organization that also has been selected as a producer responsibility organization for California and Oregon, will engage with stakeholders over the next nine months to prepare a program plan aligned with these goals.”

“As of press time, the CDPHE’s recommended program has been submitted to the state’s joint budget committee for approval. If approved, CAA, with the aid of an EPR advisory committee comprised of 13 stakeholders, including those in the hauling, packaging, recycling and legislative sectors, will develop how to implement the program, with a deadline of Feb. 1, 2025. The finalized program, complete with a statewide minimum recyclables list, is scheduled to begin in the first quarter of 2026.”

“In its initial program plan, CAA outlines an approach to implementing the RMA that builds on the existing system by upgrading facilities and improving public participation, understanding and equity throughout the state’s recycling system. With this approach, CAA is seeking to increase the diversion of recyclables from disposal and reduce the negative environmental, social and health impacts from the end-of-life management of products and packaging.”

“Circular Action Alliance, a nonprofit producer responsibility organization founded by Coca-Cola, Amazon, Unilever and other major brands and retailers, has submitted its initial program plan to the Oregon Department of Environmental Quality for implementation of the state’s extended producer responsibility for packaging law.”

This year, Colorado and Maryland chose the Circular Action Alliance as their producer responsibility organization, while California is expected to choose theirs in 2024.

This year, Colorado and Maryland chose the Circular Action Alliance as their producer responsibility organization, while California is expected to choose theirs in 2024.

This year, Colorado and Maryland chose the Circular Action Alliance as their producer responsibility organization, while California is expected to choose theirs in 2024.

“So far, CAA has been chosen as Colorado’s PRO and was also the only PRO named to Maryland’s EPR advisory council. Getting CAA off the ground, “it is no small feat to do what was done over the last 11 months,” Schwarze said. CAA is further anticipating California’s selection of a PRO and Colorado’s transition from a needs assessment into program and action planning, along with additional states looking at EPR.”

Maryland hasn’t adopted an EPR law for packaging, but CAA’s appointment to the council sets it up to potentially be the top choice for producer responsibility organization if the state adopts one.