CAA’s final plan for Colorado’s EPR system receives approval

The plan to implement Colorado’s House Bill 22-1355, the Producer Responsibility Program for Statewide Recycling Act, has been approved by the Colorado Department of Public Health and Environment (CDPHE), according to a news release issued by the Circular Action Alliance (CAA). 

H.B. 22-1355, which was signed into law in mid-2022, establishes the state’s producer-funded statewide recycling program for packaging and paper products.

Washington-based CAA says the final plan reflects its leadership and the results of collaboration among packaging and paper products producers, CDPHE, local governments, businesses, nonprofits, recyclers and communities across Colorado. The program is projected to more than double the state’s recycling rate for packaging and paper by 2035.  

Following the needs assessment, which was released in early 2024; consultation events attended by thousands of interest-holders; more than 110 hours of public meetings with the Producer Responsibility Advisory Board; public comment; and a series of revisions earlier this year, CAA says the final plan is its pathway to complying with the act.  

Through the final plan, CAA says it will accomplish a number of objectives:  

• fund all the net costs of recycling services provided by participating local governments, recycling companies and nonprofits;
• expand access to convenient recycling services for Colorado households, particularly those in underserved areas;
• more than double Colorado’s recycling rate for packaging and paper by 2035;
• standardize a list of readily recyclable materials and deliver consistent, statewide education; and
• create an efficient and cost-effective recycling system that enhances Colorado’s circular economy.

According to the plan, CAA will leverage existing recycling, reuse and compost systems and infrastructure, promoting new infrastructure where necessary; promote increased use of postconsumer recycled (PCR) content in products and packaging and incentivize packaging design to reduce negative environmental, social and health impacts.

Its key measurable outcomes after five years include increasing recycling rates from an estimated 25 percent (2022 baseline measurement) to 41 percent in 2030, improving processing of compostable covered materials and ensuring continuous improvement related to reuse and refill.

The program sets goals to increase PCR use and includes a pathway to provide producers improved access to PCR through service agreements, incentives and data sharing; establish minimum content targets for various materials; and incentivize market participation. CAA Colorado says it will establish material-specific PCR targets, create mechanisms for waivers when technical or economic feasibility is constrained and collaborate with interested parties to refine its approach over time.  Eco-modulation incentives will be given to producers exceeding these targets.

“The approval of Colorado’s program plan marks another key milestone in the advancement of producer responsibility in the United States,” says CAA CEO Jeff Fielkow. “Launching two statewide programs within six months speaks to the strength of our model and the proven capability of our team and organization. We appreciate the partnership of CDPHE and the contributions from producers, local governments and community stakeholders. Together, we are building a more accountable, accessible recycling system that delivers measurable value and environmental outcomes for Colorado communities.” 

“Producers will participate in a harmonized, transparent system that streamlines compliance. Colorado’s local governments will see meaningful cost relief, and residents will gain more consistent, convenient recycling access,” adds Juri Freeman, CAA’s Colorado executive director. “Together, we are advancing recycling access, strengthening Colorado’s recycling markets and building the foundation for a truly circular economy.”   

With the approval of the final plan, CAA must begin implementation within six months. As part of that implementation, all local governments in Colorado, as well as material recovery facilities, can express interest in participating in the program by filling out an interest form and beginning the request for reimbursement, or RFR, process. Initial forms are due Jan. 16, 2026.   

The program establishes a reimbursement system for collection and postcollection services, with participation from public, private and nonprofit service providers that meet minimum standards for quality, safety and compliance. According to the plan, after submitting an RFR that details their qualifications and compliance with standards and being deemed eligible to have a service agreement with CAA Colorado, service agreements will be negotiated to establish reimbursement terms, performance metrics and data reporting requirements.

Early in 2026, CAA will provide more information on participation and reimbursement for private and nonprofit businesses that provide subscription-based recycling collection services. Also in 2026, funding will become available for compost facilities to lower contamination management costs and improve processing and recovery of certified compostable packaging, CAA says.