Circular Action Alliance Submits Amended Plan for Colorado’s Producer Responsibility Program
Circular Action Alliance (CAA) submitted its amended program plan describing how the organization will implement Colorado's new Producer Responsibility Program. The amended program plan incorporates all amendment requests from the Colorado Producer Responsibility for Statewide Recycling Advisory Board, and numerous other changes to ensure clarity based on broader feedback from the advisory board and interest holders. The overall goals and general approach remain unchanged, and CAA remains poised to more than double the state’s recycling rate of packaging and paper by 2035. CAA will share implementation updates and training sessions via a monthly newsletter.
“Circular Action Alliance’s work creates a cost-effective recycling system that’s accessible and easy to understand. That’s a win-win-win for Colorado businesses, communities, and residents,” said Colorado Executive Director Juri Freeman.
Colorado’s Extended Producer Responsibility (EPR) law requires that producers pay dues to fund the costs of collection, sortation and processing of packaging and paper. The program plan describes how CAA will help producers comply with all elements of the law. Currently, the organization’s producer support staff is guiding producers through a major deadline: reporting supply data by July 31, 2025. The supply data allows CAA to finalize producer dues and meet the objectives of the state law which requires producers to fund recycling services in Colorado starting in 2026.
What Changed in the Amended Plan?
The advisory board amendment requests – which are necessary to meet the statutory requirements – sought clarification on several topics. One such request included the addition of text to specify that future needs assessments (which are required by the law) are not considered administrative costs. Other requests sought additional details, including description about “the process for evaluating and transitioning eligible materials from the non-recyclable category to the Additional Materials List (AML) by 2030, specifically from the ‘hard to recycle packaging’ category.”
CAA also made several plan revisions to address advisory board and interest holder comments. While not necessary to meet statutory requirements, these updates were designed to add clarity around major points of discussion that arose during the review period. Revisions addressed comments about recycling drop-off centers, service provider reimbursements, reuse and refill, and more. A new appendix to the plan includes a summary of notable revisions; that appendix and all documents can be found on the Colorado Department of Public Health & Environment (CDPHE) website.
Next Steps
Colorado’s Producer Responsibility for Statewide Recycling Advisory Board has 45 days to review the amended plan for compliance with the law, after which the board must forward the plan to CDPHE with its recommendation for approval or rejection. CDPHE is expected to open public comment in late summer. If the full timeline is utilized and CDPHE approves the plan, that approval would occur near the end of December 2025, with program implementation beginning in 2026. Sign up for the CAA newsletter to keep track of major milestones and key updates.
About Circular Action Alliance
Circular Action Alliance (CAA) is a U.S. Producer Responsibility Organization (PRO) dedicated to implementing effective Extended Producer Responsibility (EPR) laws for paper and packaging. As a nonprofit, producer-led organization, CAA is committed to helping producers comply with EPR laws, delivering harmonized best-in-class compliance services and to working with governments, businesses and communities to reduce waste and recycle more. CAA was founded in 2022 and is guided by producers representing the food, beverage, consumer goods, and retail industries.
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Media Contact:
Rachel Zerowin
Colorado Communications Manager
Circular Action Alliance
rachel.zerowin@circularaction.org
(303) 717-9620