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Colorado’s EPR programs move from planning to practice

Stefanie ValenticbyStefanie Valentic
September 17, 2026
in Policy Now, Recycling
Colorado flag

PhotoTrippingAmerica/shutterstock

Four years after Colorado’s HB22-1355 was signed, both producer responsibility organizations (PROs) tasked with implementing it are actively signing agreements, building networks and diverting material.

Circular Action Alliance Colorado (CAA Colorado), the state-appointed PRO for packaging and paper products, has entered funding agreements with the city of Cortez, which also covers the town of Dolores, and the town of Oak Creek.

The city of Golden and the city of Thornton are expected to join in the coming months. In addition, CAA Colorado has also established agreements with several recycling collectors and processing facilities as implementation of the Producer Responsibility Program for Statewide Recycling Act continues.

“This is a long-term effort, and we’re encouraged by the progress being made across our state,” said Juri Freeman, CAA Colorado’s executive director, in a statement.

This demonstrates how producer funding is helping expand recycling access, strengthen local infrastructure and support a more consistent statewide recycling system, with additional municipalities expected to join in the coming months.

CAA Colorado has signed service agreements with Apex Waste Solutions, Boulder County, Bruin Waste, Clean Valley Recycling and Ranch Creek Waste. Discussions are underway with Republic Services, Waste Connections of Colorado and Waste Management, the state’s largest haulers, none of which have yet signed on. The PRO is also analyzing tens of thousands of pounds of recycling collected statewide, an effort it says will refine recycling instructions and reduce contamination.

A second, narrower program is running in parallel.

Interchange 360, a trademark used by the Lubricants Packaging Management Association (LPMA), is the PRO designated to handle petroleum and automotive product containers under the same law. It marked six months of operations this month.

Since launching March 11, the nonprofit has built 10 Return Collection Facilities, signed four transportation partners and two processors and diverted approximately 2,500 pounds of empty containers that held products such as motor oil, antifreeze, diesel exhaust fluid and automotive aerosols.

Those containers are excluded from curbside packaging programs because of residual product and handling requirements, and Interchange 360 is now launching a statewide education campaign to steer consumers toward its drop-off network rather than their recycling bins.

“Building a new recycling system from the ground up takes tremendous collaboration,” said David Lawes, CEO of Interchange 360, in a statement. “Over the past six months, our team has worked closely with collection facilities, transporters, processors and stakeholders across Colorado to put the infrastructure in place to safely collect and recycle these materials.”

Both programs trace back to the same 2022 law. HB22-1355, formally codified as the “Producer Responsibility Program for Statewide Recycling Act,” was signed June 3, 2022. It shifted the cost of recycling packaging and paper products from local governments and taxpayers to the producers that sell those materials into the state. CDPHE designated CAA as the packaging and paper PRO in May 2023.

Under the codified statute, C.R.S. 25-17-708(1), “a producer shall not sell or distribute any products that use covered materials in the state unless the producer is participating in the program” — a restriction that took effect July 1, 2025. The first annual producer dues came due January 1, 2026.

The two PROs are working against different timelines from there. CDPHE approved CAA’s final program plan this year, and the statute gave the organization six months from that approval to begin implementation, a deadline that arrived on June 9, 2026. Interchange 360’s individual program plan had its own deadline, March 13, 2026, which is effectively the date its six-month operating window opened. The organization’s own March 11 launch essentially beat that deadline by two days.

The law’s stated goal is to raise Colorado’s packaging and paper recycling rate from 25% to 41% by 2030. Whether that target is reachable depends on how quickly the major national haulers such as Republic, WM and Waste Connections move from “in discussions” to signed agreements, since those companies control much of the collection infrastructure CAA needs to scale.

For now, both PROs emphasized the same message, pushing infrastructure first and consumer education second.

CAA Colorado indicated it anticipates that its ongoing waste characterization work will make that education more precise once it’s ready.

Interchange 360 said that a dedicated, separate system for petroleum containers avoids contaminating the curbside stream CAA is trying to build out.

Tags: EPRLegislation & EnforcementPolicy Now
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Stefanie Valentic

Stefanie Valentic

Stefanie Valentic is an award-winning journalist who has covered the waste and recycling industry for more than five years. Throughout her career, she has led editorial teams and served as a keynote speaker, moderator and panelist at numerous trade shows and conferences.

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