Circular Action Alliance submits plan proposal for Colorado’s producer responsibility program

Producer responsibility organization (PRO) Circular Action Alliance (CAA) has submitted its initial plan proposal for 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, sorting 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. CAA predicts this will nearly double the recycling rate for paper and packaging in Colorado.

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

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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 feedback solicited by CAA during a consultation process that engaged more than 2,000 representatives of Colorado business, government, trade association and nonprofits.   

The plan proposal:

• Describes how the organization will track compliance among producers and collaborate with the Colorado Department of Public Health & Environment (CDPHE) to ensure compliance;
• Establishes a uniform statewide list of recyclable materials;
• Sets targets for minimum postconsumer recycled (PCR) content rates for certain types of covered materials, including paper, glass, metal and plastic, that the state will strive to meet by Jan. 1, 2030, and Jan. 1, 2035;
• Sets 2030 and 2035 collection and recycling rates;
• Describes CAA’s approach to due setting, including eco-modulation of dues;
• Describes how CAA will reimburse participating service providers for 100 percent of the net recycling services costs;
• 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;
• Proposes an approach for a statewide education and outreach program; and
• Ensures any covered materials collected for recycling will be transferred to a responsible end market.  

“This milestone marks another significant step toward fulfilling our mission of helping producers navigate EPR compliance while collaborating with communities to reduce waste,” CAA CEO Jeff Fielkow says. “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.”   

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 used and CDPHE approves the plan, that approval would occur near the end of December 2025, with program implementation beginning in 2026, CAA says. If the plan were rejected, CAA has 60 days to resubmit the plan and start the process again.