Producer Responsibility Needs Assessment Progress

MARCH 2024
Based on feedback, Circular Action Alliance (CAA) revised the three proposed recycling scenarios to:

• Create a greater range of options for services offered in the scenarios,
• Provide greater performance improvements in the recycling and collection rates in the medium scenario, 
• Ensure key components related to Materials Recovery Facility (MRF) improvements are included in the low scenario, 
• And address areas of the needs assessment study by geographic region. 

The department also received public comments requesting updates to the proposed scenarios to support expanded drop-off services, particularly for glass and other hard-to-recycle materials, and multiple requests to remove flexible film packaging. 

The updated needs assessment report with the revised scenarios is available on the Producer Responsibility webpage.

FEBRUARY 2024 
The final draft of Colorado’s Needs Assessment report for statewide recycling has been published, and the CDPHE is now accepting feedback on this report. Circular Action Alliance (CAA) initiated this study as part of Colorado’s Producer Responsibility Program for packaging and paper products. The needs assessment is an in-depth study that assessed Colorado’s existing recycling systems and identifies opportunities for improving recycling and collection rates of covered materials.

Access Needs Assessment

CAA contracted HDR Engineering, Inc. and Eunomia Research & Consulting, Inc. (HDR team) to independently collect and analyze the data required to assess the state’s recycling system and needs. To support this assessment, the HDR team gathered data from organizations involved in Colorado’s recycling ecosystem related to the following key elements: 

• Access to services
• Recycling services costs
• Demographic factors & other variables
• Contamination at MRFs & compost facilities
• Non-residential service availability, gaps & costs
• Processing capacity opportunities & Costs
• Minimum recyclables list
• Markets
• Innovative technologies
• Reuse & refill
• Education
• Potential recycling scenarios 
• Compost facilities

The final report will form the basis for a producer responsibility recycling program plan in Colorado. CDPHE welcomes feedback on the draft needs assessment report through Feb. 19. Please submit your feedback by emailing [email protected] with the subject “Needs Assessment Feedback”. For more information about the program, please visit the Producer Responsibility Program webpage. 

In addition to the feedback we encourage our members to submit directly to CDPHE, Recycle Colorado will also submit a letter on behalf of the organization. If you would like to contribute to that letter or submit anonymous or less formal feedback, please use the link below (it will not go to CDPHE).  If you have any questions on the Needs Assessment you can contact Liz ([email protected]).

Provide Feedback to Recycle Colorado Only

JANUARY 2024
Needs Assessment results presented to CDPHE.

NOVEMBER & DECEMBER 2023
In partnership with CAA, HDR and Eunomia Research & Consulting are moving into the analysis, modeling and fact checking phase of the needs assessment, after conducting over 200 stakeholder interviews, completing site visits, and gathering survey responses. Read more.

OCTOBER 2023
Colorado's PRO, Circular Action Alliance, selected HDR Engineering and Eunomia last month to start work on the needs assessment for Colorado Producer Responsibility program for packaging and paper. HDR and Eunomia have been working tirelessly this last month, gathering & sharing information using surveys, webinars, interviews, & tours of recycling facilities in Colorado, to help them understand our recycling systems. With this information, they will develop three scenarios that will help to achieve the intentions of the law and improve recycling access & diversion of materials back into the supply chain.

Recycle Colorado has supported the needs assessment by helping to facilitate webinars and the gathering of information. Be sure to check out the Needs Assessment page to view webinar recordings, access the local government and hauler survey, and stay up to date on the progress. Get Needs Assessment Updates. 

Circular Action Alliance appointed as the Producer Responsibility Organization for Colorado
Read more on the appointment by CDPHE as the Colorado PRO and Meet the Circular Action Alliance Team. Introduction to Circular Action Alliance and EPR Laws Webinar - Access with passcode CAAWebinar1!

If you have any questions, reach out to [email protected].

Proposed changes to the solid waste regulations concerning the producer responsibility program

The updated draft regulations are available on the solid waste proposed rulemaking and stakeholder processes webpage. In addition to providing comments at the upcoming meeting, stakeholders may submit comments on the proposed changes to [email protected] with the subject line “EPR Rulemaking #2 Second Draft Feedback”. Please also indicate which Concept you are providing feedback on.

A formal rulemaking hearing will take place on May 21, 2024. Please visit the Solid and Hazardous Waste Commission webpage for additional information.

For questions about the proposed changes, please contact Darla Arians at[email protected] or 720.693.3542. For more information about the Producer Responsibility Program, please visit our website.