What Producers Need to Know About Colorado’s Producer Responsibility Act
This blog post is written by Juri Freeman, Colorado Executive Director at Circular Action Alliance
For producers, Extended Producer Responsibility (EPR) isn’t just about compliance — it’s an opportunity to lead impactful change. Colorado’s groundbreaking packaging EPR program promises long-term benefits like a more consistent and efficient recycling system, increased access to recycled materials (which helps stabilize prices), and a dramatic reduction in packaging waste. And the best part? It’s led by producers, for producers—putting industry voices at the center of solutions. With the Colorado reporting deadline set for July 31, 2025, now is the time for producers to register, get informed, and start preparing.
A New Era of Producer Responsibility in Colorado
Colorado’s EPR program for packaging and paper is the first in the nation to fully fund recycling system costs, and it sets ambitious goals: by 2030, the program aims to significantly increase recycling access and overall recycling rates. As outlined in the Program Plan Proposal, nearly all Colorado residents should have access to convenient recycling for packaging and paper products within five years. This expansion will benefit consumers and producers alike by creating a more effective statewide recycling system.
CAA is the producer-led nonprofit Producer Responsibility Organization (PRO) implementing Colorado's Act. CAA’s goal is to support brands in meeting their obligations with tools, resources, and hands-on guidance every step of the way.
Am I a Producer?
Not sure if you’re considered a “producer” under Colorado’s law? Start by asking these two key questions from the Producer Resource Center:
Do you sell, offer for sale, or distribute packaging or paper products into Colorado?
Do you own the brand of the product or packaging?
If the answer is yes, there’s a good chance you’re a producer under the law. As outlined in this helpful guidance, producers may include manufacturers, brand owners, importers, and distributors—essentially anyone introducing covered materials into the Colorado marketplace.
Keep in mind that this is general guidance. Determining your obligation requires a closer look at your operations—and a conversation with your legal counsel. CAA offers resources and support, but it’s always a good idea to consult an attorney for specific compliance questions.
Why Registration and Reporting Matter
Registration is more than a formality—it’s a cornerstone of successful producer representation.
By registering, producers ensure their voices are heard throughout the decision-making processes. And, failing to register has real consequences: under Colorado law, producers not participating in the program are prohibited from selling or distributing covered products in the state beginning July 1, 2025. That could mean loss of market access, enforcement actions, or financial penalties.
There are also reputational risks. Consumers, investors, and regulators increasingly expect companies to take responsibility for the environmental impact of their products. EPR compliance shows leadership and accountability—key traits for any forward-thinking brand.
How to Register and Report
Ready to get started? The process is straightforward, and CAA has designed it with producers in mind.
First, complete your registration and sign the Producer Participation Agreement (PPA). This formalizes your partnership with CAA and ensures your obligation with EPR regulations. The Colorado State Addendum (COSA) is available for signature, officially establishing your producer obligations and enabling you to submit required reporting data.
With the Colorado reporting portal now open, you'll have clear, step-by-step instructions to help you meet the July 31, 2025 deadline. Once registered with signed agreements, you'll gain access to robust support from CAA's Producer Services team—including webinars, detailed guidance, and personalized help tailored to your company's needs.
Don’t Wait—CAA Is Here to Help
It’s not too late to get on board. CAA is here to help producers meet their obligations and succeed in Colorado’s EPR program. The bottom line? Get registered and you won’t have to go it alone — CAA’s here to help. For any questions along the way, please reach out to our Producer Services team at producer.support@circularaction.org.