FOR IMMEDIATE RELEASE: February 3, 2025

Contact: media@circularaction.org

Circular Action Alliance (CAA) submitted its initial Plan Proposal to Colorado’s Producer Responsibility Advisory Board describing how the organization will implement Colorado's new Producer Responsibility Program. The state's extended producer responsibility (EPR) law requires that producers pay dues to fund the costs of collection, sortation, and processing of packaging and paper. Once fully implemented, the program is projected to expand access to convenient recycling services for to up to 700,000 Colorado households and nearly double the recycling rate for paper and packaging in Colorado. Such an increase would reduce greenhouse gas emissions equivalent to taking 247,000 cars off Colorado’s roads each year.  

As required by state law, the Plan Proposal details program operations and describes how CAA will help producers comply with all elements of the law. Additionally, the Plan incorporates extensive feedback solicited by CAA during a robust consultation process that engaged more than 2,000 representatives of Colorado business, government, trade association, and nonprofits.   

What’s in the Plan Proposal?  

• Producer Compliance: Describes how CAA tracks compliance among producers and collaborates with the Colorado Department of Public Health & Environment (CDPHE) to bring producers into compliance.  

• Minimum Recyclables List: A uniform statewide list of recyclable materials that must be collected in a manner that is as convenient as the collection of solid waste.  

• Post-Consumer Recycled Content (PCR): Sets targets for minimum PCR content rates for certain types of covered materials, including paper, glass, metal, and plastic, that the state will strive to meet by January 1, 2030, and January 1, 2035.  

• Collection and Recycling Rate Targets: Sets 2030 and 2035 collection and recycling rates.  

• Dues Schedule and Budget: Describes CAA’s approach to due setting, including eco-modulation of dues.  

• Reimbursement for Service Providers: Describes how CAA will reimburse participating service providers for 100% of the net recycling services costs.  

• Reuse and Refill: Proposes an approach to measure and report on the use of reusable and refillable covered materials and establishes goals and strategies for increasing reuse and refill.  

• Education and Outreach: Proposes an approach for a statewide education and outreach program.  

• Responsible End Markets: Ensures any covered materials collected for recycling will be transferred to a Responsible End Market.  

“Collaboration was critical in developing a proposal that will ultimately increase Colorado’s recycling rates for packaging and paper,” said Juri Freeman, Executive Director of CAA Colorado. “While there are several steps yet to reach a finalized plan, we look forward to driving Colorado’s circular economy through continued collaboration.”  

“This milestone marks another significant step toward fulfilling our mission of helping producers navigate EPR compliance while collaborating with communities to reduce waste,” said Jeff Fielkow, CAA’s Chief Executive Officer. “With Colorado working to launch its program in 2026 and several other states preparing for implementation, CAA is proud to be at the forefront of advancing producer responsibility for paper and packaging nationwide.”   

Next Steps  

Colorado’s Producer Responsibility Advisory Board – created as part of the law and comprised of 13 industry experts – has 90 days to review the Plan for compliance with the law and provide feedback. 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 is expected to open public comment September through December. 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. If the plan were rejected, CAA has 60 days to re-submit the Plan and start the process again. Visit CircularActionAlliance.org to learn more about the Colorado milestones.   

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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 led by 20 producers representing the food, beverage, consumer goods, and retail industries.