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. On December 9, 2025, CAA’s final plan was approved by CDPHE.
FAQ
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Implementation must begin within six months of final plan approval. CAA Colorado has opened the request for reimbursement, or RFR, process for entities providing recycling services in the state. Learn more on the reimbursement page.
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Which materials are collected under the program? What if my community doesn’t currently offer collection for those materials?
Covered materials are defined in the Act and include packaging and paper products. The covered materials can be broken down into two 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 final plan.
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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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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.
Past and Future Milestones
State Rulemaking Updates
Consumer Price Index Rule
Colorado’s Act requires CDPHE to adjust the de minimis small producer exemption based on the Bureau of Labor’s Consumer Price Index annually by July 1.
Primary Regulations
The Colorado Solid and Hazardous Waste Commission approved the final rules on June 14, 2024.
Eco-modulation Regulations
The finalized eco-modulation ruleset is forthcoming, and more information will be posted to CDPHE’s website as it becomes available.
Details can be found on CDPHE’s Producer Responsibility page and Solid Waste rulemakings page.
Advisory Board
The Advisory Board in Colorado was selected in December of 2022 and first met on Jan. 31, 2023. As of May 1, 2023, CAA was appointed to the non-voting Producer Responsibility Organization seat. The Board provided input to CAA and CDPHE throughout plan development and continues to advise on program plan implementation.
Join Circular Action Alliance (CAA) Colorado for a detailed walkthrough of the Step 1 Processor Request for Reimbursement (RFR). This session will cover everything processors need to know to prepare and submit Step 1 accurately and on time. We’ll outline each step of the process, review required forms and documentation, and highlight key deadlines to help ensure submissions are complete.
Join Circular Action Alliance (CAA) Colorado for a detailed walkthrough of the Step 1 Processor Request for Reimbursement (RFR). This session will cover everything processors need to know to prepare and submit Step 1 accurately and on time. We’ll outline each step of the process, review required forms and documentation, and highlight key deadlines to help ensure submissions are complete.