A Needs Assessment is an in-depth study of a jurisdiction’s existing recycling services and infrastructure for managing single-use packaging and paper products. Needs Assessments may be required under a packaging EPR law, as in Colorado, as a first step toward program development. Some states have passed laws requiring a Needs Assessment to be completed prior to the enactment of EPR laws.

The primary purpose of a Needs Assessment is to understand the performance and costs of the current system and define the activities and investment needed to meet the requirements of an EPR law.

The purpose of Colorado’s EPR Needs Assessment was to create a full picture of the current recycling system in the state and provide important information to inform the producer-funded, statewide recycling program created under Colorado’s EPR law. The Needs Assessment evaluated existing recycling services and infrastructure for managing single-use packaging and paper products.

The Needs Assessment also identified gaps in existing services, evaluated opportunities for increasing access to recycling for all Coloradans, and outlined pathways to improving recycling and collection rates of covered materials. Finally, the Needs Assessment established a proposed Minimum Recyclables List based on the current recycling system.

The Colorado Needs Assessment is the country’s first producer-led Needs Assessment under an EPR law for paper and packaging. The Needs Assessment was prepared for CAA by HDR Engineering and Eunomia Research & Consulting, with support from Colorado-based businesses with expertise in recycling and waste management. This included service-disabled veteran-owned business Gryphon Environmental; Colorado-based, woman-owned business LBA Associates, Inc.; Colorado-based, woman-owned business Sandhill Environmental Services; and woman-owned business Start Consulting Group LLC; woman-owned business 4R Sustainability; and Bell & Associates, Inc.

The Needs Assessment process included regular consultation with the Colorado Department of Public Health & Environment (CDPHE) and a state-appointed Advisory Board.

To understand Colorado's existing system and identify gaps, the project team conducted the outreach and data-gathering activities, which included over 250 stakeholder conversations and produced more than 100,000 data points on Colorado's residential recycling and composting services. Activities included:

• Conducting 75 tours and interviews with Colorado recycling service providers;

• Distributing municipal surveys and reviewing the 130 responses received;

• Hosting webinars to various stakeholder groups to encourage participation and seek feedback;

• Conducting extensive desktop research (e.g., visiting and evaluating information from the websites for all 272 municipalities and 64 counties);

• Responding to more than 200 comments from interested stakeholders;

• Participating in 11 Advisory Board meetings (since the Needs Assessment contract was awarded) to provide updates and seek feedback;

• Developing a page with FAQs on Recycle Colorado’s website;

• Distributing an interest form where interested parties could sign up for updates;

• Distributing monthly updates to interested parties;

• Holding ongoing conversations with other key stakeholders, such as local communities and schools, end markets for recyclables, non-profits, and businesses.

CDPHE recommended the medium scenario that was included in the Needs Assessment to the Joint Budget Committee. On April 17, 2024, the JBC approved the recommendation.

Under Colorado’s EPR law, the producer-funded statewide recycling program is expected to provide Coloradans with convenient access to recycling services for all recyclable materials covered under the law, helping to narrow significant gaps in residential recycling. This program will shift the responsibility for funding recycling from local governments and taxpayers to the companies that supply paper and packaging into Colorado, removing a large cost item from municipal budgets and relieving residents who may be paying for subscription-based recycling services.

The program will help Coloradans play a role in creating a circular economy by improving access to recycling services and proper education to ensure recyclable materials don’t end up in landfill. The producer-funded recycling program will create a common, Minimum Recyclables List, which will support consistent education to improve participation, reduce contamination at both recycling and composting facilities, and increase the recycling rate.

The first step in the MRL process was to develop a list of the materials to be evaluated. Based on the description of covered materials within Colorado’s EPR law. The list was further refined to develop the MRL by answering the following questions (see the Element 8 technical memo for more information):

• Whether Colorado MRFs explicitly state they accept and market the material.

• Whether Colorado MRFs have the equipment and operations to effectively process and sort the materials.

• Whether Colorado MRFs identified stable and easily accessible markets for the material.

• Whether in-state or domestic end markets were identified.

The MRL is a list of materials that must be collected in a manner that is as convenient as the collection of solid waste.

The AML includes materials that may be collected in different geographic areas through curbside services, drop-off centers, or other means, but are not required to be collected throughout the state.

Both the MRL and AML will be evaluated annually for inclusion or removal of materials. This evaluation will be done in consultation with Colorado stakeholders.

The Program Plan will include potential upgrades or expansion to MRFs, compost facility upgrades, new drop-off sites and potential improvements to existing transfer stations, or the development of new transfer stations. These upgrades were factored into the scenario modeling, however specific investments will be identified following the selection of a scenario and through the Program Plan.

There will be an additional 410,000 tons of materials recycled annually for a total of 720,000 tons per year by 2035. This will mark a 119% increase from the 2022 baseline. The amount of landfill space saved each year as a result is approximately the equavalent of filling Empower Stadium (Broncos Stadium).

With the JBC’s approval of the recycling scenario recommended by CDPHE, implementation of Colorado’s EPR law will move forward. CAA will develop a program plan aligned with the approved recycling scenario and supported by additional stakeholder input and data collection. The program plan 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.

The purpose of Colorado’s EPR Needs Assessment was to create a full picture of the current recycling system in the state and important information to inform the producer-funded, statewide recycling program created under Colorado’s EPR law. The Needs Assessment evaluated existing recycling services and infrastructure for managing single-use packaging and paper products.

The Needs Assessment also identified gaps in existing services, evaluated opportunities for increasing access to recycling for all Coloradans, and outlined pathways to improving recycling and collection rates of covered materials. Finally, the Needs Assessment established a proposed Material Recyclables List based on the current recycling system.

The Program Plan describes how the PRO will use the findings from the Needs Assessment along with input from other stakeholders to meet the goals of the scenario. It will also address funding details, reporting requirements, and other details.

No, CAA will continue to engage with all system stakeholders throughout Program Plan development. CAA will share more information about engagement opportunities throughout the process.