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 hosted a consultation process from July through September 2024 to support the development of the program plan. The feedback received through that process is being anonymized, compiled, and reviewed to inform the development of initial program plan proposal.
The draft program plan proposal 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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Each company must review the producer definition under each state’s packaging EPR law and determine whether it is a covered producer in California, Colorado, and/or Oregon. CAA is not able to provide legal advice or make this determination for you.
However, CAA has developed guidance to help businesses answer the two primary questions they need to ask that will help determine if they are obligated under the EPR laws:
Is the material associated with my products covered by the EPR laws?
Is my business the responsible producer for those materials?
Please review CAA’s guidance materials for further information.
Please note that CAA guidance is not meant to constitute legal advice, and CAA assumes no responsibility for the decisions made by producers in determining their obligations. CAA suggests that producers work with their attorneys to review the relevant statutes, rules and regulations to determine their responsibilities.
Relevant Statutes:
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To comply with producer registration requirements under California, Colorado, and Oregon EPR laws for paper and packaging products, covered producers must register with CAA unless the producer qualifies for an exemption or the producer intends to submit an individual compliance plan, under applicable law.
Regulations in Colorado required producers to register by October 1, 2024. Producers who did not register by that date may be subject to enforcement. CAA will be submitting a list of registered producers to the Colorado Department of Public Health & Environment following the October deadline. CAA will be submitting a list of registered producers to the Colorado Department of Public Health & Environment as required.
CAA was required to provide the Oregon DEQ with a list of registered producers as part of CAA’s revised program plan, submitted on September 27, 2024.
Producers in these states who missed the deadline need to still register with CAA.
Only registered producers will gain access to CAA’s producer education forums, such as the Producer Working Group (PWG), and receive detailed guidance to support data preparation and reporting.
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ICalifornia, Colorado, Maine, and Oregon EPR laws have different fee collection requirements and timelines. Oregon will be the first state where producers have fee obligations when the program begins on July 1, 2025. Fee obligations in Colorado will begin in January 2026. In California, fee obligations start in January 2027.
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Each state will have specific reporting categories for all materials in scope of the program, whether or not they are determined to be recyclable. Producers will report the type and weight of their covered materials into these categories.
Producers can expect detailed guidance on reporting to be released in late-October 2024. Only registered producers who have a signed a Participant Producer Agreement (PPA) with CAA will be able to access the reporting guidance. The PPA outlines the terms and conditions between producers and CAA and will be available to registered producers in late-October.
In Colorado, producers will begin reporting August 31, 2025, submitting data covering Q1-Q2 of 2025.
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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October 1, 2024
Colorado Regulatory Deadline for Producers to Register with CAA.
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February 1, 2025
CAA submits draft program plan proposal.
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August 2025
CAA Preliminary Deadline for Data Reporting.
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January 1, 2026
Producers Remit Dues to CAA on or before this date.
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Early 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. The Colorado Solid Hazardous Waste Commission approved the final rules on June 14, 2024.
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.
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