Producer Responsibility program
Quick links: Program Plan public comment period | Compliance reporting deadlines | Eco-Modulation
IPP | Adopted rulemakings | Resources
Program background
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.
The State of Colorado appointed Circular Action Alliance as the designated Producer Responsibility Organization in May 2023.
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. 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.
Register with Circular Action Alliance (CAA)
Register with LPMA powered by Interchange 360 (LPMA)
Applicable Petroleum and Automotive Products List
Program Plan under department review
On August 14, 2025, CDPHE’s executive director received the Colorado Producer Responsibility Advisory Board’s recommendation memo for Circular Action Alliance’s (CAA) amended draft Program Plan. As per HB22-1355, with CDPHE in receipt of the board’s recommendation and comments from the public, the executive director will have one hundred and twenty days (until December 12th, 2025) to approve or reject the Program Plan. If the executive director rejects the plan, the reason must be based on the failure of the document to comply with the requirements of HB22-1355.
- CDPHE Requirements for CAA Colorado’s Amended Program Plan.
- Summary of and CDPHE responses to public comments on CAA's Program Plan.
- Public comments re: Circular Action Alliance's Amended Program Plan Proposal (pdf portfolio, download and open with Adobe).
- Comments received as presented as a collection of individual PDFs within this portfolio. Select the PDF you wish to view in the navigation pane within Adobe.
- Advisory Board Recommendation for Approval Memo: Plan Proposal.
- Circular Action Alliance - Program Plan Proposal Amendment Request Memo.
- Circular Action Alliance - Amended Program Plan.
- Circular Action Alliance - Amended Program Plan Appendices.
- Circular Action Alliance - Amended Program Plan Submittal letter.
Compliance reporting deadlines
For producers of paper products and packaging materials: By July 31, 2025, you were to have: 1) signed the Participant Producer Agreement (PPA); 2) signed the Colorado State Addendum, and; 3) submitted a supply report to meet the Colorado reporting deadline. If you have not done this yet, you are out of compliance with state statute. To submit a supply report, go to Circular Action Alliance's Producer Portal for Colorado reporting.
For producers of applicable petroleum and automotive products: By July 1, 2025 you were to have registered with LPMA and returned a signed copy of the Colorado Participation Agreement. If you have not done this yet, you are out of compliance with state statute. To register and submit your signed agreement, email memberservices@interchange360.com. Fees dating back to the start of the program will be due within 30 days of submission.
Eco-Modulation public comment period has ended
The public comment period for the eco-modulation rulemaking session has ended. The public comment period was open for 45 days, from Thursday, August 14 to Sunday, September 28. The department will consider all public comments received before presenting the Solid and Hazardous Waste Commission with our proposed amendments on November 18.
Public comment can now be sent directly to the Solid & Hazardous Waste Commission at cdphe.hwcrequests@state.co.us on the proposed rule. The Commission strongly encourages comments be submitted by 11:59 p.m. on November 7th.
More information on our rulemaking sessions and view recordings of past meetings.
- Draft 1 Producer Responsibility Regulations: Section 18.9 Eco-Modulation.
- Draft 2 Producer Responsibility Regulations: Section 18.9 Eco-Modulation.
- Draft 3 Producer Responsibility Regulations: Section 18.9 Eco-Modulation (with track changes).
- Draft 3 Producer Responsibility Regulations: Section 18.9 Eco-Modulation.
- Revised Proposed Amendments to Section 18 Producer Responsibility Regulations.
- Draft Statement of Purpose for Proposed Section 18 Producer Responsibility Regulation Amendments.
LPMA Individual Program Plan approved
LPMA Individual Program Plan approval
The Executive Director of the Colorado Department of Public Health and Environment has approved the Lubricant Packaging Manufacturers Association (LPMA), powered by Interchange 360’s Individual Program Plan. As per HB22-1355, the Producer Responsibility Program for Statewide Recycling Act, the Amended Individual Program Plan is designated as the Final Individual Program Plan, and LPMA powered by Interchange 360 shall begin implementation of this plan within 6 months, or by March 13, 2026.
CDPHE Requirements for LPMA's Amended Individual Program Plan
Public comments re: LPMA's Individual Program Plan
Summary of and CDPHE responses to public comments on LPMA's Individual Program Plan
Advisory Board Recommendation for Approval Memo: Individual Program Plan
Resources
- Approval Process Memorandum.
- CDPHE Approval of HDR Engineering.
- Colorado Needs Assessment - 2025 update.
- Department Position on PCR Free Allocation Mass Balance with Fuel Exclusion.
- Frequently asked questions and answers- Producer Responsibility Program.
- House Bill 22-1355.
- State legislation that authorizes the EPR program.
- Implementation Timeline (subject to change).
- Joint Budget Committee Decision.
- Producer Determination Flow Chart.
- Producer registration, reporting and resources.
- Regulations pertaining to solid waste sites and facilities.
- Statements of Basis and Purpose for Solid Waste Regulations.
- Summary of the act by topic.
Contact
Please send your questions or comments to eprcomments@state.co.us.