Colorado passed its Extended Producer Responsibility law in May 2022, addressing a range of materials, including packaging, packaging-like products, and paper products. Implementation is set for July 2025, with Circular Action Alliance designated as the registered Producer Responsibility Organization (PRO).
According to the legislation, a “producer” is defined as the brand’s manufacturer or, if the brand contracts manufacturing, the manufacturer. For packaging or products produced outside the US, the responsibility will fall on the importer or distributor. Initially set for July 1, 2024, the deadline to register as a producer has been extended to October 1, 2024, to allow compliance with these new regulatory requirements.
Circular Action Alliance’s final plan was approved by the Colorado Department of Public Health & Environment (CDPHE) on December 9, 2025. Implementation is expected in early 2026.
If your company sells into Colorado, this may affect your reporting, internal data collection, packaging decisions, and long-term compliance planning.
Depending on your role in the supply chain, your organization may be considered the obligated producer. That responsibility can fall to the brand owner, trademark owner, licensee, importer, or distributor. For many companies, the real challenge is not just understanding the law — it is figuring out who is responsible internally, what information is needed, and how to prepare without overloading already stretched teams.
EPR is evolving across the U.S. What starts in one state can quickly become part of a much larger operational and financial burden
The best time to prepare is before compliance pressure builds. A practical first step is to confirm whether your company is obligated and identify what data, teams, and systems will be needed to respond.
From there, organizations should begin reviewing:
Getting ahead now can reduce compliance risk, prevent last-minute reporting pressure, and help your team build a more manageable path forward
We help producers make sense of complex EPR requirements and turn them into practical action.
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