Colorado recycling and circular economy goals
The CAA plans to refine its approach over time, including increasing access to kerbside recycling services for around 700,000 additional households by 2030 and improving the state’s recycling rate to 58% for packaging and paper by 2035.
The intended positive economic and environmental impacts of the programme include:
- $31 million in additional annual wages
- Approximately 7,900 new direct and indirect green jobs
- Investments to lay the foundation for a strong and growing circular economy
- Preventing 1.3 million metric tonnes of greenhouse gas emissions each year, equivalent to removing 278,000 cars from the road annually
- Reducing landfill waste by 410,000 tonnes every year
Colorado has had two packaging submissions so far, covering 2024 and 2025 packaging data. The CAA’s plan is to continue with annual submissions, with the reporting deadline set as 31 May each year.
PCR content reporting was added to the 2025 data submissions, reflecting an increased focus on recycling performance in Colorado.
Businesses with obligations in Colorado should establish robust packaging data collection processes to support future reporting requirements and PCR content disclosures.
Obligated packaging
Producers are obligated for packaging that reaches the household waste stream only (primary, primary outer and e-commerce packaging), which means that, in most cases, business-to-business, secondary and transit packaging are exempt.
The CAA’s definition of “packaging material” for Colorado is:
“Any material, regardless of recyclability, that is intended for single or short-term use and is used for the containment, protection, handling, or delivery of products to the consumer at the point of sale, including through an internet transaction.”
Packaging material comprises cartons, flexible foam, glass, metal, paper, plastic, rigid packaging and other materials.
Producers are also obligated for paper products sold in the state of Colorado. The CAA’s definition of paper products is:
“Paper and other cellulosic fibres, whether or not they are used as a medium for text or images.”
Examples include:
- Flyers
- Brochures
- Booklets
- Newspapers
- Magazines
- Exemptions
There are several exempt materials that are not included within the Colorado regulations. These include:
- Packaging for drugs, medical devices and nutritional supplements
- Specific examples of paper and paper products
- Hazardous products
- Food service packaging
- Durable packaging
Additionally, producers can be exempt in the state of Colorado if they fall under certain criteria, including:
- Producers with gross total revenue below approximately $5 million to $5.5 million
- Producers that use less than one tonne of obligated materials sold or distributed within or into the state in the previous year
- Local governments or non-profit organisations
- Construction businesses
More information regarding these exemptions can be found on the Circular Action Alliance website: Colorado – Circular Action Alliance
Key takeaways
- Producers are only obligated for packaging that reaches the household waste stream
- Submissions are currently annual and the reporting deadline is 31 May
- Colorado packaging regulations will continue to evolve over time
- PCR content will become increasingly significant in Colorado reporting. Collection of this data will be important
- There are a number of exclusions that producers need to be aware of
How Valpak can help
At Valpak, we assist businesses in collecting, verifying and reporting Colorado submissions for Extended Producer Responsibility (EPR) compliance.
If you are overseeing multiple suppliers, incorporating post-consumer recycled (PCR) information into packaging data, or preparing for new regulatory requirements, our specialists can help you establish the necessary processes and governance.
We work with businesses across sectors to:
- Produce and calculate EPR obligations for Colorado and other state regulations
- Prepare for current and emerging regulatory requirements
- Verify supplier data for accuracy and compliance
Ready to prepare for Colorado reporting?
Colorado’s packaging regulations will continue to evolve as the CAA works to improve recycling outcomes and support a circular economy. Delaying action until regulations become mandatory may disadvantage your business. Early preparation helps ensure clearer data, more efficient compliance and stronger sustainability credentials.
Whether you need support with packaging data collection, international compliance requirements or emerging EPR regulations across multiple jurisdictions, Valpak can help.
Contact our specialists to assess your current position, identify reporting gaps and prepare for future regulatory requirements.