CAA Colorado adds 13 recycling facilities, says more than 400,000 households have no-cost recycling as 2027 dues rise

How Colorado's producer-funded system is meant to work

Colorado’s Producer Responsibility Program for Statewide Recycling Act, HB22-1355, makes companies that sell packaging and paper products fund a statewide recycling system. SPI tracks it as PR-US-003 in the SPI Regulation Tracker for the United States.

The money flows one way. Producers pay dues to CAA, and the signed act requires the plan to include reimbursement rates covering 100% of service providers’ net recycling services costs, under section 25-17-705(4)(j). The organisation may use up to 5% of producer dues for administration, under section 25-17-705(4)(i)(II).

Service providers have to earn that money. Section 25-17-706(2)(a) makes providers eligible for payment only if they collect all readily recyclable materials in a way that supports the plan’s targets, although the executive director can grant an exception. The act also required CAA to begin implementing the final plan within six months of approval.

CDPHE’s programme page says CDPHE’s executive director approved CAA’s plan in December 2025, and CAA’s Colorado page gives the date as 9 December 2025. CDPHE says the approved plan is projected to bring no-cost recycling to an estimated 700,000 more households, and that free services are expanding in phases through 2030.

CAA’s Colorado page sets out the producer side of that timetable. Producers had to register with CAA by 1 October 2024, report supply data by 31 July 2025 and remit dues on or before 1 January 2026, and CAA was to remit its first administrative dues to CDPHE by 30 June 2026. The same page says CAA began implementation in early 2026.

The targets differ slightly by document. CAA’s Final Plan Overview sets a recycling rate of 41% by 2030 and 55% by 2035, from 25% in 2022. CDPHE’s page projects a rise from 25% to 58% by 2035. SPI has not yet confirmed which figure the final plan text uses for 2035.

What changed in October

1 October: the 2027 dues. CAA’s 2027 Colorado dues schedule set the rates producers will pay next year. It says that in 2027 producers will receive two invoices for annual dues, 50% in January and 50% in July. It also states that 92 cents of every dollar of producer dues goes directly to collection, processing and education and outreach.

The rate moves. Against the 2026 schedule of 13 October 2025, final dues rise on all 14 common lines SPI compared. Corrugated cardboard moves from 8.0 to 10 cents a pound and HDPE and LDPE film from 48.0 to 62 cents. The 2027 schedule says rates reflect producer-reported supply data, projected programme costs and regulatory requirements, but it does not explain the changes line by line.

Small producers. Optional flat dues for producers supplying 10 tons or less rise from four bands of $800 to $3,600 a year in 2026 to $900 to $4,100 in 2027. By SPI’s calculation, the top band rises 13.9% and the lowest 12.5%.

22 October: 13 facilities. CAA Colorado’s release, datelined Denver, said 13 additional recycling processing facilities had joined. It says the combined capacity of participating facilities is more than 200,000 tons a year, “helping set the stage for CAA Colorado to meet program plan goals.”

The agreements. The release lists Apex Waste Solutions, the City of Thornton, Ranch Creek Waste and Waste Management as recent agreements. It does not say which are collection agreements and which are processing agreements, or which of the 13 facilities each operates.

The household count. With the latest collection agreements, the release says, more than 400,000 Colorado households have access to no-cost recycling at home. Service start dates vary by community and provider, and residents are told to contact their local provider.

How it built up. CAA’s 16 September release announced funding agreements with the City of Cortez, on behalf of Cortez and the Town of Dolores, and the Town of Oak Creek. It said Golden and Thornton were expected to join, so Thornton has moved from expected to signed in five weeks.

What did not change. The release does not alter any dues date, and CDPHE’s page still says dues are owed in January 2026 and each year after. SPI’s Ledger analysis of the Oregon and Colorado schedules prices a fixed 100-tonne basket at USD 22,883.79 in Colorado for 2026 and USD 28,726.05 for 2027, a 25.5% rise by SPI’s calculation.

What the release says, and what it leaves open

The 22 October release is short on detail, and producers reading it for budget purposes should separate what CAA states from what it does not. The table sets out the main points, with the 2027 dues lines that fund the work.

Capacity is a combined figure. The 200,000 tons covers all of Colorado’s participating facilities, not only the 13 added on 22 October. The release does not give a total number of participating facilities, so SPI has not yet confirmed what the 13 add on their own.

The households are a count of access, not of new service. The release says more than 400,000 households have access to no-cost recycling through the programme. It does not say how many already had kerbside recycling paid for by residents or towns before the agreements. CDPHE’s estimate of 700,000 more households measures added access under the full plan, so the two figures are on different bases and are not compared here.

The facilities are unnamed. The release names four counterparties but not the 13 facilities or their locations. It links to a list of participating service providers on RecycleOn, CAA’s education and outreach site, which SPI has not yet reconciled with the release.

Timing is local. CAA says service start dates vary by community and provider. For a producer, that means no statewide date on which dues turn into collection, and no figure in the release for 2026 payments to service providers.

The eco-modulation layer. The 2027 schedule applies a 5% malus for materials that disrupt recycling and a 5% bonus for high recycling rates, automatically from supply data. On corrugated cardboard the bonus is 1 cent a pound in 2027; HDPE and LDPE film carries neither malus nor bonus. CAA said it would post detailed Colorado eco-modulation guidance, including CDPHE bonus benchmarks, by 1 October 2026.

Who gets paid and who pays for 2027

WM and the named haulers. WM, Apex Waste Solutions and Ranch Creek Waste are the companies the release names, and the statute entitles eligible providers to reimbursement of 100% of net recycling services costs. Apex Waste Solutions and Ranch Creek Waste already had service agreements by 16 September, CAA’s earlier release says, together with Boulder County, Bruin Waste and Clean Valley Recycling.

Towns and cities. Thornton joins Cortez, Dolores and Oak Creek as named local governments in the programme. For a city, the agreement shifts recycling costs from residents or the municipal budget to producer dues, within the plan’s reimbursement rates.

Paper and corrugated producers. Corrugated cardboard pays 10 cents a pound in 2027, up 25% on 2026. By SPI’s calculation, a producer with 100,000 pounds of corrugated in Colorado would owe $10,000 in 2027 against $8,000 in 2026, with $5,000 on the January invoice.

Flexible packaging users. HDPE and LDPE film pays 62 cents a pound and plastic laminates 78 cents in 2027. SPI’s Packaging Buyers Database profiles list film and pouch formats from brands including Kimberly-Clark (Huggies diaper film), General Mills (film liners and pet food bags) and Reckitt (Finish pouches) as covered materials under PR-US-003.

Rigid plastics and metals. Clear HDPE bottles rise from 14.0 to 22 cents a pound and steel containers from 7.0 to 11 cents. SPI’s profiles place Nestlé’s Tidy Cats pails and jugs and General Mills’ Progresso steel cans in the programme.

A film-heavy example. By SPI’s calculation, a brand with 20,000 pounds of HDPE and LDPE film in Colorado would owe $12,400 in 2027 against $9,600 in 2026, and $6,200 on each 2027 invoice. The same weight in plastic laminates would cost $15,600 at 2027 rates.

Small producers. Those supplying 10 tons or less can pay a flat $900 to $4,100 in 2027. CDPHE is consulting on the inflation-adjusted dollar threshold that exempts producers, and SPI has not yet confirmed the current amount.

The release’s capacity and household figures are CAA’s own statements. SPI has not yet confirmed them against CDPHE data or CAA’s first annual report.

What the 28 October board meeting can and cannot settle

CDPHE’s advisory board page lists the 28 October 2026 meeting from 1:30 to 4:30 p.m., held virtually and in person. Stakeholders and the public may observe and give public comment, Spanish interpretation will be provided, and up to 12 members of the public can attend in person after signing up.

The page links agendas for 28 October in English and Spanish. SPI has not yet confirmed the agenda, so it cannot say whether the 22 October agreements, the 2027 dues schedule or CAA’s reporting are listed for discussion.

The board advises rather than decides. It was created under C.R.S. 25-17-704(1), and its listed duties include reviewing the needs assessment and CAA’s plan proposal, recommending whether CDPHE’s executive director approves a plan or amended plan, reviewing CAA’s annual report and consulting on the minimum recyclable list.

It has met most months this year. The page lists meetings on 14 January, 11 February, 8 April, 13 May, 10 June, 8 July, 12 August and 9 September 2026, with the 11 March meeting cancelled, followed by 18 November and 9 December.

The pinch point is turning dues into dated service

The constraint is timing. Producers pay on a fixed calendar, 50% of 2027 dues in January and 50% in July, while service starts community by community with no published dates. CAA’s release gives none, and CDPHE says services may not yet be available in every area.

The statute ties the two together through reimbursement. Providers are paid only if they collect all readily recyclable materials in line with the plan, and the plan must cover 100% of their net costs. A faster roll-out therefore lifts programme costs, and CAA’s 2027 schedule says rates reflect projected programme costs.

Scope widens later. CAA’s plan overview says the programme adds schools, government buildings and small businesses by 2030, and that recycling should be as convenient as trash pickup by then. Each step adds collection that dues have to fund, and the release gives no figure for how far the 400,000 households already go towards CDPHE’s estimate of 700,000 more households under the full plan.

The oversight point is the board. CDPHE’s advisory board page says the board reviews CAA’s annual report under section 25-17-709(2)(a), and consults on the minimum recyclable list. That review is where the 200,000 tons and 400,000 households can be tested against dues collected.

The programme is also under legal challenge. As SPI reported on 25 October, NAW’s federal suit against Colorado’s law has a pending preliminary injunction motion, and the Auto Care Association moved on 15 October to join it over dues paid to both CAA and a separate lubricant packaging programme. The 22 October release does not mention the case, and SPI has not yet confirmed a hearing date.

How Colorado compares with other CAA states

CAA is the PRO in Oregon, Colorado, California and Minnesota, but the four states sit at different stages. Oregon DEQ’s producer page says DEQ approved CAA’s 2025 to 2027 plan on 21 February 2025 and that CAA could charge fees from 1 July 2025. It also says fee rates will change annually.

Oregon’s reporting rhythm is also set out on DEQ’s page. From 31 May 2026, producers report the prior year’s supply data to CAA by 31 May each year, and CAA’s annual report to DEQ is due each 30 June. Colorado’s statute gives CDPHE’s board a similar annual report to review, which is where Colorado’s service figures will first be tested.

California is a plan behind. CalRecycle’s SB 54 page says the permanent regulations took effect on 1 May 2026 and that CAA submitted its PRO plan on 13 October 2026, that CalRecycle has 75 days to review it, and that public comment on the plan runs until 13 November 2026.

Minnesota is earlier still. The MPCA’s Act page says it accepted CAA as PRO, that the first stewardship plan comes in 2027 to 2028, and that producer funding of service costs starts in 2029 to 2032, reaching at least 90% by 2031. A draft 2026 needs assessment is open for comment through 13 November.

Colorado’s dues are higher than Oregon’s for 2027 on SPI’s basket, a reversal of 2026, because Oregon’s 2027 rates hand back reserves while Colorado’s carry none, as the Ledger fee schedule analysis sets out. The US state packaging EPR overview covers the other states.