Colorado state capitol building at sunset.

Colorado’s Producer Responsibility Organization Circular Action Alliance released a needs assessment that lays out accepted recyclable lists, models the effects of several improvement scenarios and evaluates access to services and costs. | Joseph Sohm/Shutterstock

In another step toward implementation of extended producer responsibility for packaging, Colorado regulators published a report laying out which materials would be covered and exploring different options for how the program could operate.

Carried out by producer responsibility organization (PRO) Circular Action Alliance (CAA), HDR Engineering and Eunomia Research and Consulting, the needs assessment creates accepted recyclable material lists, models the effects of several improvement scenarios and evaluates access to services and costs. It was published by the Colorado Department of Public Health & Environment (CDPHE).

The assessment looked at Colorado as four regions, based on socioeconomic and geographic factors: the Western Slope, the Mountains, the Front Range and the Eastern Plains. It used 75 tours and interviews with service providers, end markets and other stakeholders, 130 municipal surveys and many comments, meetings and discussions to generate more than 100,000 data points. 

Public feedback on the draft is accepted through Feb. 19. Email comments to [email protected] with the subject “Needs Assessment Feedback.” 

Acceptance lists 

One element of the assessment was the creation of a minimum recyclables list, as well as an additional materials list. The minimum list is materials that must be collected in a manner that is as convenient as the collection of solid waste. The additional list is materials that may be collected through either curbside services, drop-off centers or other means but is not required. 

By statute, the lists had to be based on the availability of recycling services, recycling collection and processing infrastructure and end markets. 

The proposed minimum list includes: 

  • Uncoated paper for general use; 
  • “Low grade” printing and writing paper; 
  • Other printed paper; 
  • Newspaper and newsprint; 
  • Magazines and other coated paper; 
  • Bound directories; 
  • Packaging paper; 
  • Corrugated cardboard (except wax-coated); 
  • Kraft packaging; 
  • Paperboard boxes and packaging; 
  • Molded pulp packaging (excluding food containers); 
  • Gable-top cartons;
  • Aseptic cartons; 
  • Non-metalized gift wrap; 
  • Clear PET bottles, jars and jugs (including transparent green or blue);
  • Clear PET thermoform containers (including transparent green or blue); 
  • Natural HDPE bottles, jars and jugs; 
  • Colored HDPE bottles, jars and jugs; 
  • Other polyethylene packaging (except pails and lids and squeezables); 
  • Polypropylene packaging (except for large pails and lids); 
  • Steel and aluminum aerosol containers;
  • Steel containers; 
  • Aluminum beverage and non-beverage containers; 
  • Clear or colored glass. 

The proposed additional list includes: 

  • Shredded paper (bagged); 
  • Molded pulp food serviceware; 
  • Paper cups, both coated and uncoated; 
  • Other poly-coated packaging; 
  • Paper laminate; 
  • Paper “cans” with steel ends; 
  • Colored opaque PET bottles, jars and jugs; 
  • Colored opaque PET thermoform containers; 
  • PE squeezable tubes; 
  • Colored LDPE nursery containers; 
  • PP nursery containers; 
  • LDPE/HDPE film; 
  • Other aluminum packaging; 
  • Other metal packaging.


The needs assessment used 2022 as a baseline year for recycling and then modeled improvements in 2030 and 2035 based on three sets of changes, which would result in a “low,” “medium” or “high” recycling rate scenario. In 2022, the state had a recycling rate between 22% and 28% for covered packaging from covered entities.

In the low scenario, the state could achieve a recycling rate between 32% and 38% in 2030 and between 47% and 53% in 2035. Changes would include making any new collection service biweekly and keeping current service collection frequency the same; making minor changes to collection routes for efficiency; planning to collect material on the additional list by 2035; requiring glass collection be offered in any new recycling services that start up; and adding MRF capacity based on new volume but not investing in advanced technology. 

In the medium scenario the recycling rate would be between 34% and 40% in 2030 and 51% and 57% in 2035. That scenario would include making new collection service biweekly and keeping current service collection frequency the same; making moderate changes to collection routes for efficiency; planning to collect material on the additional list by 2035; collecting glass curbside for both new and existing service; and adding MRF capacity based on new volume, greater investment in infrastructure, including drop-off sites, and making advanced technology upgrades. 

Finally, in the high scenario, the recycling rate could hit between 39% and 45% in 2030 and 54% and 60% in 2035, but that requires making new and existing collection services weekly; making major changes to collection routes for the greatest efficiencies; planning to collect material on the additional list by 2030, including curbside flexible plastic collection; collecting glass curbside for both new and existing service; and a high level of investment in infrastructure at MRFs and drop-off sites, including advanced technology. 

“There may be other factors that impact the ability of CAA to implement on schedule that could affect performance,” the report noted, including when CDPHE approves the program plan and the time needed to implement collection and processing improvements. 

System costs 

All of those changes come at a price – which producers are expected to cover. The needs assessment found that in 2022, the total system cost was between $80 million and $140 million.

By 2023, the system cost could be between $130 million and $200 million in the low scenario, $130 million and $210 million in the medium scenario and between $150 million and $240 million in the high scenario.

In 2035, those costs could be between $160 million and $250 million, $160 million and $260 million and $180 million and $290 million, respectively. 

Costs include contractual terms, service option levels, frequency and materials collected. The report noted that most of Colorado is serviced by subscription-based, cart-based, open-market hauling.

Some state-specific cost challenges are the strict laws on truck weight-to-axle ratios on mountain roads, the steep and rugged roads in the Mountain and Western Slope regions, which increase fuel usage and truck maintenance costs, and high wildlife activity which requires special containers and more frequent services in rural areas, the report added. 

Upgrading existing MRF infrastructure to the levels in the scenarios would cost between $85 million and $100 million overall, the report found. To upgrade composting facility infrastructure, the price tag is about $49 million, and to make capital upgrades to existing transfer stations, it would cost between $1.3 million and $2.3 million per transfer station.

If the PRO wanted to make it so existing transfer stations can accept compostable materials, that would cost between $1 million and $2.3 million per transfer station. 

Collection services

The report evaluated residential and non-residential covered services. It found that for residential, single-stream recycling is the most common curbside collection method, followed

by dual-stream, with glass separated from other materials. 

About two-thirds of residents live in municipalities that provide single-stream recycling, but about 95% of households in municipalities have access to curbside garbage collection.

Colorado’s EPR legislation requires that recycling collection should be as convenient as trash collection. Therefore, about 31% of households in evaluated municipalities would get curbside recycling services added, or 500,000 additional households. Outside of municipalities, in census-designated places and rural areas, an additional 100,000 to 200,000 households would receive service. 

The most significantly impacted region would be the Eastern Plains region, where currently 18% of households in municipalities receive curbside recycling services. That would increase to 38% under the modeled plan. 

Non-residential covered entities are hotels and other accommodations, event spaces and stadiums, food and drink establishments, small businesses, schools, outdoor and indoor public places and government buildings.

The needs assessment found that recyclable materials ranged from 20% to 50% of the total waste generated at hotel accommodations and ski resorts, and was around 35% at restaurants. 

“Events and stadiums frequently have recycling infrastructure and signage to help attendees properly sort materials,” the report noted. “However, some technically recyclable materials get thrown out as garbage because they are too contaminated with food, as there is no infrastructure for rinsing containers.” 

End Markets 

The report found that glass is the only collected material with a Colorado end market that could accommodate increased volume. Major end markets include Glass to Glass, O-I Glass and Rocky Mountain Bottling Company. 

Steel mills in the state do not accept steel or tin cans and the nearest end market for those materials is approximately 850 miles from Denver. There are also no local markets for aluminum in Colorado.

For paper, markets can be relatively close to Colorado if the material is sorted into ISRI standard bale grades, the report added, although there are no paper mills in the state.  

As for plastics, end markets for post-consumer plastic material are limited in the state, though there are some facilities for post-industrial materials. 

The report also delved into composting capacity and access; education access; the 52 existing reuse and refill operations in the state; new technology options; MRF processing capacity; contamination and state demographics.

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