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Producer Responsibility program

En Español

On June 3rd, 2022, the Producer Responsibility Program for Statewide Recycling Act, House Bill 22-1355 was signed into law. 

HB 22-1355 sets up a Producer Responsibility program that requires companies that sell products in packaging, paper products to fund a statewide recycling system to recycle those materials. These companies will form an independent non-profit organization, called a Producer Responsibility Organization, to coordinate, fund, and manage this statewide recycling system.

By July 31, 2025, obligated producers must sign the Participant Producer Agreement (PPA) and the Colorado State Addendum, login to the Producer Portal, and report by July 31 to meet the Colorado reporting deadline.

Regulations pertaining to solid waste sites and facilities

Statements of Basis and Purpose for Solid Waste Regulations

Apply to become a retail representative for Colorado’s Producer Responsibility Advisory Board

The Producer Responsibility Program for statewide recycling is accepting applications for a retail representative to serve as a member of the Producer Responsibility Advisory Board. We are accepting applications until the seat is filled.

The program requires companies that sell products in packaging and paper products to fund a statewide recycling system to recycle those materials.

One of the program objectives is to develop a convenient, cost-effective statewide recycling system that provides free and equitable recycling to all residents. The advisory board will ensure that the program equitably meets the needs of local Colorado communities and businesses.

The retail representative who will serve as a member of the advisory board must represent a retailer's association a retailer that is not a producer. They are required to have relevant knowledge and expertise in recycling programs or the impacts of covered materials on the state and the environment.

If you or someone you know is interested in applying, please complete or share the advisory board application.

For questions about the application process, or to submit your application, contact EPRcomments@state.co.us.

Advisory Board application link 

Notice to producers: Important dates

By July 1, 2025, a producer cannot sell or distribute products that use covered materials in Colorado unless they participate in the Producer Responsibility Program. 

Register with Circular Action Alliance (CAA)

Register with LPMA powered by Interchange 360 (for petroleum and automotive products on its Applicable Products List)

CAA

The Colorado reporting deadline is July 31, 2025. Producers who are obligated in Colorado will need to submit a supply report to CAA by July 31. Producers must pay the producer responsibility dues on “covered materials” annually to the PRO in January 2026, and each year thereafter. Producers are also required to keep records and report data to document compliance with the Act and rules.

On June 2, 2025, Circular Action Alliance will open the Producer Portal for Colorado reporting, which must be complete by July 31, 2025. As a reminder, Producers will need to sign the Colorado State Addendum (COSA) before submitting a supply report. The COSA will also be available starting June 2.

LPMA

To register with LPMA and comply with the law, producers must return a signed copy of the Colorado Participation Agreement to memberservices@interchange360.com by July 1. Fees dating back to the start of the program will be due within 30 days of submission.

Notice to stakeholders: Amended plan proposal under review

Circular Action Alliance submitted its amended Program Plan Proposal to the department on June 30, 2025. The plan is currently under review by the Producer Responsibility Advisory Board, who have 45 days (August 14th) to review the revised document and send its recommendation for approval or rejection to the department. Once we are in receipt of the board's final recommendation, we will begin accepting formal public comments on the amended plan. We will notify stakeholders when a recommendation has been received and the public comment period opens.

Notice to stakeholders: IPP approval recommendation memo submitted to CDPHE: Public comment period now closed

On May 14, 2025, Colorado’s Producer Responsibility Advisory Board submitted its approval recommendation memo for LPMA Powered by Interchange 360’s amended Individual Program Plan (IPP). As per HB22-1355, with CDPHE (the Department) in receipt of the board’s recommendation, the Executive Director (ED) will have one hundred and twenty days (until September 11th) to approve or reject the IPP. If the ED rejects the IPP, the reason must be based on the failure of the IPP to comply with the requirements of the Act.

The public comment period for the amended plan proposal is now closed after being open for 30 days (May 20 to June 19). The Department will consider all public comments received during this time before deciding whether to approve or reject the plan.

Amended LPMA individual program plan

Individual Program Plan updates in response to the Advisory Board amendment request and additional comments

Advisory Board Recommendation for Approval Memo: Individual Program Plan

Producer Responsibility Organization

The State of Colorado appointed Circular Action Alliance as the designated Producer Responsibility Organization in May 2023.

Circular Action Alliance website

Producer Responsibility Organization designation press release

Producer registration, reporting and resources

CDPHE Approval of HDR Engineering

Plan proposal

By February 3, 2025, Circular Action Alliance will submit a Plan Proposal for the program to the advisory board. The proposal will detail program operations, material collection/processing strategies, funding/reimbursement mechanisms, education and outreach, and end-market development for recycled materials. 

Once submitted, the Producer Responsibility Advisory Board will have 90 days to conduct a comprehensive review of the plan to ensure it complies with HB 22-1355 requirements.