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.
FAQ
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On April 17, 2024, the Colorado General Assembly’s Joint Budget Committee (JBC) approved the recycling scenario recommended by the Colorado Department of Public Health and Environment (CDPHE). With the JBC’s approval, implementation of Colorado’s EPR law will move forward. CAA will develop a plan proposal aligned with the approved recycling scenario and supported by additional stakeholder input and data collection. The program plan is due to CDPHE on or before February 1, 2025.
Concurrently, CAA is working to register producers with the PRO in Colorado, Oregon, and California. Producers can register here.
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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.
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CAA’s producer registration deadline is July 1, 2024. This aligns with the producer registration proposed in CDPHE’s draft rules.
To register, producers must complete CAA’s Obligated Producer Registration form. To ease producer compliance, CAA is working to register all producers in Colorado, California, and Oregon by July 1, 2024.
Early producer registration helps:
* Reduce the number of non-compliant obligated producers in the system so system costs are covered fairly; and
* Provide CAA with more precise producer data to inform accurate and fair fee schedules.
NOTE – Producers may choose to comply with Colorado’s EPR law as an individual company, provided the individual company complies with the requirements in 25-17-705(8)(a).
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In Colorado, participant producers must first pay dues to CAA on or before January 1, 2026. CAA will develop guidance to support producers with packaging data reporting and dues payment.
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The statute does not specify a date by which participant producers must first report data to CAA.
CAA will develop guidance to support producers with packaging data reporting.
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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July 1, 2024
Deadline for Covered Producers to Join CAA.
*Proposed in Rules. -
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February 1, 2025
CAA Submits Program Plan.
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January 1, 2026
Producers Remit Dues to CAA on or before this date.
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Q1 2026
Program Begins.
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June 30, 2026
CAA Remits First Administrative Dues to CDPHE.
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. A second draft was released in February 2024. CAA encourages all producers to monitor deadlines for comments and participate in the regulation stakeholder meetings. Information on the latest drafts, stakeholder meetings, and how to comment can be found on CDPHE’s Proposed Rulemaking page.
A formal rulemaking hearing of the Colorado Solid and Hazardous Waste Commission to codify draft rules is scheduled for May 21, 2024. Registration for the hearing is open.
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.
News
“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.”