Colorado's Extended Producer Responsibility (EPR) program for packaging and paper is moving from planning into implementation. For municipalities, haulers, material recovery facilities (MRFs), and other recycling service providers, the biggest question is no longer what EPR is. It's what you need to do to participate.
As we know, the program shifts the funding of eligible recycling services toward producers and is designed to expand access to recycling across Colorado. Circular Action Alliance (CAA) administers the program and is responsible for establishing service agreements and reimbursing eligible providers for qualifying recycling costs.
For organizations that collect, transport, process, or support recycling services, 2026 is the time to understand the participation process, gather the required information, and prepare for ongoing reporting.
What Are Covered Materials?
In Colorado's EPR program, "covered materials" are the packaging and paper products on CAA's Minimum Recyclable List (MRL) and Additional Materials List (AML).
The MRL includes paper and cardboard, aluminum and steel containers, certain PET containers, cartons, and glass. The AML includes additional eligible packaging and paper products that may be collected through curbside or drop-off programs.
The distinction matters because reimbursement applies only to eligible services involving covered materials. If you're preparing a Request for Reimbursement (RFR), make sure you know which of the materials you collect fall within the current MRL or AML.
Who Can Participate?
CAA's Colorado program includes several categories of service providers.
Local governments. Municipalities and counties can participate if they provide, or want to provide, covered recycling services to residents. Eligible services include curbside collection, drop-off recycling, and recycling education and outreach.
Processors and MRFs. Private businesses, nonprofits, and local governments that receive covered materials, prepare them for market, or deliver them to responsible end markets may qualify as processors. That includes MRFs and other facilities that receive and process covered materials.
Residential haulers. Private businesses and nonprofits that provide subscription-based residential collection, or transport covered materials to designated facilities, may participate through the program's open-market residential collection process. Eligibility and reimbursement depend on the specific services provided and the requirements in CAA's service schedules.
Key Colorado EPR Dates
- December 2025: CDPHE approved CAA's implementation plan.
- January 2026: Producer dues began, and initial forms were due January 16.
- April 13, 2026: Initial local-government RFR deadline.
- Later in 2026: All three RFRs (local government, processing, and open market residential) reopen.
- December 1: Annual education and outreach reporting deadline.
- 2028–2030: Eligibility expands beyond residential service to schools in 2028 and other non-residential entities by 2030.
Missed a deadline? At the time of writing CAA runs the RFR process on a rolling basis, so you can still apply. Check CAA's Colorado reimbursements page for reopening dates.
How Do You Apply?
The process begins with an RFR, which allows CAA to determine which services a provider offers, understand the associated costs and operations, and develop a service agreement.
For local governments, the RFR covers services such as collection, drop-off, and education and outreach. For processors and other providers, it focuses on the specific services they deliver and the information CAA needs to establish reimbursement. Applications and supporting information are submitted through the CAA Service Provider Portal.
What Information Should You Have Ready?
One of the most useful things municipalities and haulers can do now is organize their operational and financial records. CAA's guidance indicates that household counts, tonnage, site details, contract dates, and cost estimates can flow into service agreements and reimbursement calculations.
Depending on your role, have current records covering:
- Number of households or customers served
- Collection service areas
- Recycling tonnage and material volumes
- Drop-off locations and operating information
- Processing or transfer facilities
- Service contracts and contract dates
- Collection, transportation, processing, and other eligible costs
- Service levels, frequencies, and equipment
- Staff or contractor responsibilities
- Education and outreach activities, where applicable
The goal is to make sure what you submit accurately reflects how your recycling program actually operates.
Don't Forget About Reporting
Applying for reimbursement is only part of the process. Participating providers are expected to submit regular activity reports through the Service Provider Portal, which CAA uses to calculate and verify payments. That means record keeping should be an ongoing process, not something assembled only when an application is due.
What Happens After You Apply?
CAA reviews provider information and uses it to establish service agreements. Those agreements can address reimbursement as well as operational expectations, and CAA says they may include provisions for service expansion, rate adjustments, and continuous improvement.
What Should Recycling Operators Be Doing Now?
- Confirm your eligibility. Determine which CAA service-provider category applies to your organization.
- Review the current RFR requirements. They differ for local governments, processors, and residential collectors.
- Gather your operational data. Make sure household counts, tonnage, service areas, facility information, contracts, and costs are current.
- Establish a recordkeeping process. Decide who will track the information needed for ongoing reporting.
- Monitor CAA's deadlines. RFRs are rolling, so watch for current and upcoming windows.
- Use CAA's resources. CAA has published application guides, reporting guidance, webinars, and other materials for providers.
The Bottom Line
Colorado's EPR program represents a major change in how recycling is funded, but for municipalities and haulers the immediate issue is practical: understand the requirements, get your documentation in order, and be ready to participate.
Organizations that already have accurate service, tonnage, contract, and cost information will be better positioned to navigate reimbursement. And because the program is still being implemented, staying current matters, since requirements, application windows, and reporting procedures may evolve as CAA works with providers across the state.
