Skip to content
Specialized Packaging Market Intelligence and Strategic AdvisoryPackaging Intelligence. Clearer Decisions. Stronger Growth.

SPI NewsUnited States · Packaging EPR

Colorado's EPR advisory board meets 28 October with three sessions left before CAA's first annual report and 2027 amendment window

Colorado’s 13-member packaging EPR advisory board meets on 28 October and twice more in 2026; under the statute, CAA’s first annual report of 17 required elements is due before 31 March 2027, on SPI’s reading.

By the SPI teamPublished 15 min read

After the 28 October meeting, Colorado's statute and rules set dated reviews from January 2027 to the 2030 plan renewal
  • past
  • next
After the 28 October meeting, Colorado's statute and rules set dated reviews from January 2027 to the 2030 plan renewal12 dated items from 9 Dec 2025 to 1 Feb 2030.2025202620272028202920302031Today9 Dec 2025: CDPHE's executive director approves CAA's 2026 to 2030 plan30 Jun 2026: CAA remits its first administrative dues to CDPHE28 Oct 2026: Advisory board business meeting, 1:30 to 4:30 p.m.18 Nov 2026: Advisory board meeting, 12:30 to 2:30 p.m.9 Dec 2026: Advisory board meeting, 12:30 to 2:30 p.m.1 Jan 2027: Executive director's annual eco-modulation bonus schedule due31 Mar 2027: CAA's first annual report to the board, on SPI's reading1 Jul 2027: Annual inflation adjustment of the small producer threshold1 Aug 2027: CAA's annual reimbursement of CDPHE costs due2028: Schools added to reimbursement; first consumer cost review1 May 2029: Updated needs assessment due1 Feb 2030: Updated five-year plan proposal due, on SPI's readingAfter the 28 October meeting, Colorado's statute and rules set dated reviews from January 2027 to the 2030 plan renewal12 dated items from 9 Dec 2025 to 1 Feb 2030.2025202620272028202920302031Today9 Dec 2025: CDPHE's executive director approves CAA's 2026 to 2030 plan30 Jun 2026: CAA remits its first administrative dues to CDPHE28 Oct 2026: Advisory board business meeting, 1:30 to 4:30 p.m.18 Nov 2026: Advisory board meeting, 12:30 to 2:30 p.m.9 Dec 2026: Advisory board meeting, 12:30 to 2:30 p.m.1 Jan 2027: Executive director's annual eco-modulation bonus schedule due31 Mar 2027: CAA's first annual report to the board, on SPI's reading1 Jul 2027: Annual inflation adjustment of the small producer threshold1 Aug 2027: CAA's annual reimbursement of CDPHE costs due2028: Schools added to reimbursement; first consumer cost review1 May 2029: Updated needs assessment due1 Feb 2030: Updated five-year plan proposal due, on SPI's reading
  1. CDPHE's executive director approves CAA's 2026 to 2030 planpast
  2. CAA remits its first administrative dues to CDPHEpast
  3. Advisory board business meeting, 1:30 to 4:30 p.m.next
  4. Advisory board meeting, 12:30 to 2:30 p.m.next
  5. Advisory board meeting, 12:30 to 2:30 p.m.next
  6. Executive director's annual eco-modulation bonus schedule duenext
  7. CAA's first annual report to the board, on SPI's readingnext
  8. Annual inflation adjustment of the small producer thresholdnext
  9. CAA's annual reimbursement of CDPHE costs duenext
  10. 2028Schools added to reimbursement; first consumer cost reviewnext
  11. Updated needs assessment duenext
  12. Updated five-year plan proposal due, on SPI's readingnext

Source: CDPHE advisory board and programme pages; C.R.S. 25-17-704, 705, 709, 713 and 715; 6 CCR 1007-2 Part 1 Section 18; CAA Colorado page and amended plan; SPI calculation, checked 14 Oct 2026.

Show the data
After the 28 October meeting, Colorado's statute and rules set dated reviews from January 2027 to the 2030 plan renewal
DateLabelCategoryLink
2025-12-09CDPHE's executive director approves CAA's 2026 to 2030 planpasthttps://circularactionalliance.org/colorado
2026-06-30CAA remits its first administrative dues to CDPHEpasthttps://circularactionalliance.org/colorado
2026-10-28Advisory board business meeting, 1:30 to 4:30 p.m.nexthttps://cdphe.colorado.gov/hm/epr-advisory-board
2026-11-18Advisory board meeting, 12:30 to 2:30 p.m.nexthttps://cdphe.colorado.gov/hm/epr-advisory-board
2026-12-09Advisory board meeting, 12:30 to 2:30 p.m.nexthttps://cdphe.colorado.gov/hm/epr-advisory-board
2027-01-01Executive director's annual eco-modulation bonus schedule duenexthttps://colorado.public.law/statutes/crs_25-17-709
2027-03-31CAA's first annual report to the board, on SPI's readingnexthttps://colorado.public.law/statutes/crs_25-17-709
2027-07-01Annual inflation adjustment of the small producer thresholdnexthttps://cdphe.colorado.gov/hm/epr-program
2027-08-01CAA's annual reimbursement of CDPHE costs duenexthttps://regulations.justia.com/states/colorado/1000/1007/rule-6-ccr-1007-2/part-1/part-b/section-6-ccr-1007-2-18
2028Schools added to reimbursement; first consumer cost reviewnexthttps://colorado.public.law/statutes/crs_25-17-709
2029-05-01Updated needs assessment duenexthttps://colorado.public.law/statutes/crs_25-17-705
2030-02-01Updated five-year plan proposal due, on SPI's readingnexthttps://colorado.public.law/statutes/crs_25-17-705

Key takeaways

  • CDPHE’s advisory board page lists a business meeting on 28 October 2026 from 1:30 to 4:30 p.m., online and in person with Spanish interpretation, and further meetings on 18 November and 9 December from 12:30 to 2:30 p.m.
  • C.R.S. 25-17-704 gives the board 13 voting and 2 nonvoting members and seven duties, from reviewing the needs assessment to recommending whether CDPHE’s executive director approves or rejects a plan or amended plan.
  • C.R.S. 25-17-709 requires CAA to send the board an annual report with 17 elements before 31 March of the programme’s second year, and the board forwards it to the executive director with its comments.
  • C.R.S. 25-17-705(6) lets CAA propose plan amendments each year through the annual report, and CDPHE can request an amendment at least 60 days before the report deadline.
  • SPI analysis: if the first report falls due on 31 March 2027, the 9 December meeting is the last scheduled session before CAA must consult the board on any amendments, by 1 March 2027 by SPI’s calculation.
Colorado's advisory board has 13 voting seats, meets three more times in 2026 and reviews a 17-element annual report due before 31 March 2027

13

Voting seats on the board

plus 2 nonvoting seats, for CDPHE and CAA

C.R.S. 25-17-704; CDPHE members page

3

Board meetings left in 2026

28 Oct, 18 Nov and 9 Dec

CDPHE advisory board page

17

Required elements in CAA's annual report

first report before 31 Mar 2027, on SPI's reading

C.R.S. 25-17-709(2)(a)

Source: CDPHE advisory board and members pages, consulted 27 Oct 2026; C.R.S. 25-17-704 and 25-17-709; SPI reading of the statute, checked 30 Oct 2026.

The Colorado Department of Public Health and Environment (CDPHE) said its Producer Responsibility Advisory Board will hold a business meeting on 28 October 2026, from 1:30 to 4:30 p.m., online and in person, with sessions to follow on 18 November and 9 December.

For producers paying dues in Colorado, the board matters less for any single meeting than for what the law sends to it next. C.R.S. 25-17-709 requires Circular Action Alliance (CAA), the state’s producer responsibility organisation (PRO), to send the board a progress report with 17 required elements before 31 March of the programme’s second year. CAA’s Colorado page lists implementation as starting in early 2026, so that points to 31 March 2027, on SPI’s reading of the statute.

The two earlier SPI reports covered the federal lawsuit and the lubricant packaging overlap (25 October) and CAA’s 13 new recycling facilities and 2027 dues (26 October). This piece sets out the board’s role, the reviews the statute and the Section 18 rules give it in 2027 and beyond, and the dated calendar ahead.

What the advisory board is and what it is not

The board is a statutory adviser, not a regulator. C.R.S. 25-17-704 created it within CDPHE, with 13 voting members and 2 nonvoting members, all appointed by the department’s executive director. The nonvoting seats belong to the department and the PRO.

The 13 voting seats are fixed by type. Three go to local government: a municipality or city and county, a county, and a local government outside the Front Range. The others cover a materials recovery facility, a hauler, a non-profit, a packaging supplier that is not a producer, a recycled paper manufacturer, a business group, a retailers’ association, a compost facility, an environmental justice expert and a landfill or transfer station that runs a public recycling programme.

The statute sets a floor for how often it meets. It must hold annual meetings and can meet more often at the request of the chair or of at least seven voting members, and it is subject to the Colorado Sunshine Act and the Colorado Open Records Act. In practice it has met most months: the 28 October session is its ninth business meeting of 2026, by SPI’s count from CDPHE’s meeting list, with the March meeting cancelled.

Decisions sit elsewhere. CDPHE’s executive director approves or rejects plans and amendments, the Solid and Hazardous Waste Commission adopts rules, and section 25-17-705(7) says the PRO may not decide whether any person complies with the law. The board’s tool is the recommendation, made in public and on the record.

The department sets out the terms for the next session on its advisory board page.

“Stakeholders and members of the public are welcome to observe the meeting and provide public comment.”

Colorado Department of Public Health and Environment, advisory board page, notice of the 28 October 2026 meeting, consulted 27 October 2026

What is scheduled between now and December

28 October: the business meeting. CDPHE’s page says the board will meet from 1:30 to 4:30 p.m., online and in person. Up to 12 members of the public may attend in person after signing up through a form, online attendees register through Zoom, and the meeting will include Spanish interpretation1.

The agenda. CDPHE has posted an agenda for 28 October in English and Spanish on its document system. SPI has not yet confirmed the agenda items, so this piece does not say which reports, rule packages or plan matters the board will take up on the day.

Length. At three hours, the 28 October slot is longer than the two that follow. CDPHE lists 18 November and 9 December from 12:30 to 2:30 p.m., and its page shows no agenda link for either date as of 27 October.

Meeting record. For each 2026 meeting from January to August, CDPHE’s page lists a summary, an agenda and a recording, most with Spanish versions; 9 September shows an agenda and a recording. Materials before January 2025 are available by request to the programme, the page says.

Seats up for renewal. CDPHE’s members page shows one voting seat, the environmental justice seat held by GreenLatinos, with a term ending on 31 December 2026. Six more seats end on 31 December 2027 and six on 31 December 2028. The board page says there are no current vacancies.

Rules in the pipeline. CDPHE’s rulemaking page lists a proposed amendment to Section 1.8 of the solid waste rules on the producer dollar limit exemption, alongside an adopted Section 1.8 CPI rulemaking and the final Section 18 amendments. The commission’s hearings page lists no producer responsibility hearing for the rest of 2026, and SPI has not yet confirmed a hearing date for the proposed Section 1.8 change.

CAA’s own board. Separately, CAA’s Colorado page gave notice that the Colorado State Board for Circular Action Alliance would meet on 5 October 2026. That is CAA’s governing board, not the state advisory board, and the page does not set out its powers.

The 28 October session runs three hours, against two hours for each of the two meetings that follow Unit: hours, scheduled meeting length
The 28 October session runs three hours, against two hours for each of the two meetings that follow3 bars. Largest: 28 Oct 2026, 3.28 Oct 202628 Oct 2026: 3 hours, scheduled meeting length318 Nov 202618 Nov 2026: 2 hours, scheduled meeting length29 Dec 20269 Dec 2026: 2 hours, scheduled meeting length2The 28 October session runs three hours, against two hours for each of the two meetings that follow3 bars. Largest: 28 Oct 2026, 3.28 Oct 202628 Oct 2026: 3 hours, scheduled meeting length318 Nov 202618 Nov 2026: 2 hours, scheduled meeting length29 Dec 20269 Dec 2026: 2 hours, scheduled meeting length2

Source: CDPHE advisory board page, consulted, checked 30 Oct 2026.

Scheduled times as listed by CDPHE, Mountain Time. In time order. Actual running times may differ.

Show the data
The 28 October session runs three hours, against two hours for each of the two meetings that follow (hours, scheduled meeting length)
MeetingScheduled hours (hours, scheduled meeting length)
28 Oct 20263
18 Nov 20262
9 Dec 20262

What the statute and Section 18 give the board to review

The board’s seven duties are listed in C.R.S. 25-17-704 and repeated on CDPHE’s page with their statutory references. Most of the work tied to the 2026 to 2030 plan is now in the review phase rather than the design phase. The table sets out each duty, where it comes from and when it next applies.

The board's seven statutory duties: three come round each year, and the needs assessment and plan renewal return in 2029 and 2030
DutyStatutory basisWhat it means in practiceNext time it applies
Advise CAA during the needs assessment25-17-705(3)(b)Consulted throughout the assessment and the choice of scenarioUpdated assessment due by 1 May 2029
Review the needs assessment25-17-705(3)(c)Receives the results before the executive director2029 update
Review the plan proposal25-17-705(4) and (5)90 days to recommend amendments or forward the planUpdated plan due by 1 Feb 2030, on SPI's reading
Consult on plan amendments25-17-705(6)CAA consults the board at least 30 days before filing the annual reportBy 1 Mar 2027, on SPI's reading
Recommend approval or rejection25-17-704 and 25-17-705(5)Forwards plans and amendments to the executive director with a recommendationWith each amendment cycle
Review the annual report25-17-709(2)(a)Reviews the report and forwards it with commentsBefore 31 Mar 2027, on SPI's reading
Consult on the minimum recyclable list25-17-706(1)Consulted when CAA updates the list and its additional materials listAs conditions change

Source: C.R.S. 25-17-704, 25-17-705, 25-17-706 and 25-17-709; CDPHE advisory board page; 6 CCR 1007-2 Part 1 Section 18 (text current through 10 June 2025); SPI reading of the dates, checked 30 Oct 2026.

Summary of statute and rule text. Dates marked as SPI's reading depend on how the statute's second year of implementation is read; CDPHE has not published a first report date. Not legal advice.

The annual report. Section 25-17-709(2)(a) says that before 31 March of the programme’s second year, and by 31 March each year after, CAA submits a progress report to the board covering the preceding calendar year. The board must review the report and forward it to the executive director, who posts it on CDPHE’s website.

Which year counts. The statute does not define the start of implementation. Section 25-17-705(5)(c)(II) requires CAA to begin implementing within six months of approval, and the approval date of 9 December 2025 puts that at 9 June 2026, by SPI’s calculation. CAA’s Colorado page lists implementation as early 2026. SPI has not yet confirmed whether CDPHE treats 2027 as the second year.

The amendment cycle. Section 25-17-705(6) lets CAA submit proposed amendments to the board each year for inclusion in the annual report. At least 60 days before the report deadline, CDPHE may ask CAA to amend the plan to address a specific concern, and at least 30 days before filing the report CAA must consult the board on any amendments.

Counting back from 31 March 2027. By SPI’s calculation, the 60-day mark falls on 30 January 2027 and the 30-day mark on 1 March 2027. Rule 18.1.3 applies C.R.S. 2-4-108 to deadlines that fall on weekends or holidays, and 30 January 2027 is a Saturday.

What an amendment does not do. Under section 25-17-705(6)(b), CAA keeps running the programme under the final plan while an amendment is pending, and a rejected amendment does not relieve that duty. Rule 18.5.3 says a routine annual dues update does not need a plan amendment, and that CAA may seek provisional approval of an urgent dues change, with CDPHE responding within 30 days.

When the report shows a gap. Section 25-17-709(3) lets the executive director require an amendment if an annual report shows the plan is not on track to meet its minimum collection, recycling or recycled content rates. That makes the first report the first formal test of the plan’s targets.

What the first annual report must contain

Section 25-17-709(2)(a) lists 17 elements for each report, and rule 18.5.5 adds that it must meet the statute’s requirements. Rule 18.1.5 requires an annual independent financial audit, with a copy filed with the report due before 31 March of the programme’s second year.

The table groups the 17 elements by what they let the board test. Each covers the preceding calendar year, so a report filed before 31 March 2027 would cover 2026, the first year in which dues were paid.

CAA's annual report must cover 17 elements, from dues collected by material to reserve fund status and the board's own feedback
GroupStatutory elementsWhat the board can test
Plan progress(I) progress on each plan element; (VII) collection, recycling and recycled content rates and efforts toward targetsWhether the plan is on track for its 2030 targets
Producers and supply(II) producers, brands and covered materials; (III) non-participating or noncompliant producers; (IV) total weight of covered materials sold in ColoradoWho is paying and who is not
Money(V) dues collected, dues schedule by weight and material and reasons for changes; (XIII) independent audit; (XIV) reserve fund status and adequacyHow dues moved and why
Service(VI) weight collected and recycled by material, collection method, county and area; (X) names, locations and hours of collection services; (VIII) reimbursement rate schedules and disputesWhere service exists and what providers are paid
Markets(XI) responsible management and end markets; (XII) end markets and effects of non-mechanical processingWhere material goes after collection
Outreach(IX) education and outreach activities and evaluation resultsWhether the June 2026 campaign reached residents
Plan changes(XV) plan amendments; (XVI) minimum recyclable list updates; (XVII) the board's feedback on amendmentsWhat changed in the plan, and the board's view

Source: C.R.S. 25-17-709(2)(a), text via colorado.public.law, consulted 27 Oct 2026; 6 CCR 1007-2 Part 1 rules 18.1.5 and 18.5.5, checked 30 Oct 2026.

Grouping by SPI. Element numbers follow the statute. Summary only, not the full statutory wording.

Exemptions. The same section requires a report, within two years after the final plan is submitted, to evaluate how the exemptions in section 25-17-713(1) affect programme performance and the dues schedule. SPI has not yet confirmed whether CDPHE expects that evaluation in the 2027 or the 2028 report.

The state’s own report. Section 25-17-709(2)(c) requires the executive director to compile the PRO and individual plan reports into an annual general report to the governor, presented to legislative committees under the SMART Government Act. SPI has not yet confirmed a 2027 hearing date.

Lubricant packaging. Interchange 360 runs the separate individual plan for automotive lubricant packaging, which CDPHE approved in September 2025 and which began in March 2026, CDPHE’s programme page says. Section 25-17-709(2)(b) requires each such plan to report to the board on a similar schedule, before 31 March of its second year.

Industry reaction

The bonus schedule. Section 25-17-709(1)(d), as enacted by HB22-1355, requires the executive director to develop an eco-modulation bonus schedule by 1 January 2026 and each year after, designed to reduce dues for producers that meet benchmarks set by rule5.

The next schedule is therefore due by 1 January 2027, and the statute requires the executive director to consult CAA and the board on it, so the board’s November and December meetings are the last scheduled sessions before that date.

“Colorado’s Act requires CDPHE to adjust the de minimis small producer exemption based on the Bureau of Labor’s Consumer Price Index annually by July 1.”

Circular Action Alliance, PRO, Colorado programme page, consulted 27 October 2026

The statute’s base figure is USD 5 million in gross revenue, and the February 2026 committee briefing put the current small business exemption at less than USD 5.6 million or less than 1 ton of packaging and paper a year; the next adjustment falls by 1 July 2027.

“In 2028, CAA Colorado will begin to reimburse recycling services for schools, progressively expanding reimbursement for other nonresidential covered entities by 2030.”

Circular Action Alliance, PRO, Colorado Amended Program Plan, 1 July 2025

Section 25-17-705(4) requires the plan to set out a timeline for nonresidential expansion that begins no later than 2028, so the schools step is a statutory floor that the 2027 annual report and amendments must plan for.

Consumer costs. Section 25-17-709(4) of the act requires CDPHE to review the programme’s consumer cost impacts at least every three years, starting in 20285.

The review covers price rises on covered products against other states, local government spending and household spending on recycling and trash, and its outcome goes into CDPHE’s annual general report.

CAA’s amended plan describes the board as reviewing the programme and consulting with CAA on amendments, and says CAA took part in more than 44 board meetings and technical work sessions while the plan was developed.

SPI has not yet confirmed a published statement from a board member organisation, producer trade body or local government on the 28 October agenda.

Who sits at the table and what each side has at stake

The board’s members are organisations, and CDPHE’s members page names each one with its seat type and term. Their interests differ, because the plan pays some of them and charges others.

Haulers and processors. Republic Services holds the hauler seat to 2028, while Waste Connections holds the landfill with recycling seat and Bruin Waste Management the materials recovery facility seat, both to 2027. Section 25-17-705 requires reimbursement rates to cover 100% of net recycling service costs, and element (VIII) of the annual report requires the rate schedules and any rate disputes.

Local governments. The City of Grand Junction (municipality, to 2028), Saguache County (county, to 2027) and the City of Steamboat Springs (non-Front Range local government, to 2028) hold the three local seats, and Steamboat Springs is listed as vice-chair. The February 2026 committee briefing said local governments would be reimbursed for 100% of eligible net recycling costs.

Packaging and paper. TOPPAN Packaging Americas holds the packaging supplier seat and the Glass Packaging Institute the trade association seat, both to 2028; the American Forest and Paper Association holds the recycled paper seat to 2027. CAA’s plan sets 2030 recycled content targets of 40% for paper and paper packaging and 30% for glass packaging.

Retail, compost and community seats. Wolf Strategies holds the retailers’ association seat and A1 Organics the compost seat, both to 2027. A non-profit seat runs to 2028 and the environmental justice seat, held by GreenLatinos, to 31 December 2026.

Producers. Producers have no voting seat; CAA sits as a nonvoting member. The February briefing said 2,100 producers had registered with CAA Colorado as of January 2026, and their route into the board’s work is public comment and CAA’s reporting. SPI’s Packaging Buyers Database profiles list brands with Colorado-covered formats under PR-US-003.

Who holds the 13 voting seats: six terms end in 2027, six in 2028 and one on 31 December 2026
Seat typeOrganisationTerm endsWhat the plan does for or to this group
MunicipalityCity of Grand Junction2028Reimbursement of net recycling costs
CountySaguache County2027Reimbursement of net recycling costs
Non-Front Range local government (vice-chair)City of Steamboat Springs2028Reimbursement of net recycling costs
Materials recovery facilityBruin Waste Management2027Paid under reimbursement rate schedules
HaulerRepublic Services2028Paid under reimbursement rate schedules
Landfill with recyclingWaste Connections2027Paid under reimbursement rate schedules
Compost facilityA1 Organics2027Compost funding expected later in 2026, per the Feb 2026 briefing
Packaging supplierTOPPAN Packaging Americas2028Customers' dues set per pound of material
Recycled paper manufacturerAmerican Forest and Paper Association202740% recycled content target for paper by 2030
Trade associationGlass Packaging Institute202830% recycled content target for glass by 2030
Retailers' associationWolf Strategies2027Retailers can be obligated producers for own brands
Non-profitListed by CDPHE2028Education and outreach consultation
Environmental justiceGreenLatinos2026Service to underserved areas

Source: CDPHE Producer Responsibility Advisory Board members page, consulted 27 Oct 2026; C.R.S. 25-17-704, checked 30 Oct 2026.

Organisations as listed by CDPHE. The non-profit seat is shown by type only because CDPHE's page lists two organisation names for it. Term dates are 31 December of the year shown. No figures here are added or ranked.

The pinch point is a report deadline nobody has dated

The constraint on the next five months is a single undefined phrase. The annual report, the amendment window and the department’s 60-day request right all count from the second year of the programme’s implementation, the statute’s wording, and neither the statute nor Section 18 puts a calendar date on it.

If CDPHE reads 2026 as year one, the cycle starts now. The department’s request window would close on 30 January 2027, CAA’s consultation with the board would fall by 1 March and the report would land before 31 March 2027, by SPI’s calculation. The board’s three remaining 2026 meetings would then be the run-up.

If CDPHE reads implementation as starting from June 2026, the first report could slip to 2028. That would leave 2026 dues, the June 2026 outreach campaign and the first service agreements without a statutory report for more than a year. SPI has not yet confirmed CDPHE’s reading.

SPI analysis

Producers should plan as if the 2027 date holds. The first report must set out dues collected by material and the reasons for changes, so the 2027 rate increases reported on 26 October will be explained to the board on the record in the first cycle either way.

How Colorado's board compares with Oregon's and Minnesota's

Each of the three CAA states compared here has an appointed advisory body, but their size and timing differ. Oregon’s Recycling System Advisory Council has 17 voting members appointed by the Governor and two nonvoting legislators, and lists four vacancies. It advises DEQ and PROs on the statewide collection list and plans, reviewed a 2026 CAA plan amendment on responsible end markets, and meets next on 18 November 2026.

Minnesota’s board is earlier in its cycle. The MPCA’s Act page says the agency appoints a packaging EPR advisory board that gives input on needs assessments, reviews and comments on the stewardship plan and on PRO annual reports. Comments on Minnesota’s draft 2026 needs assessment close on 13 November, and the first plan comes in 2027 to 2028.

Colorado's board is fixed at 13 voting seats by statute; Oregon's council has 17, and Minnesota's first plan review comes in 2027 to 2028
ItemColoradoOregonMinnesota
BodyProducer Responsibility Advisory BoardRecycling System Advisory CouncilPackaging EPR advisory board
Appointed byCDPHE executive directorGovernorMPCA
Voting members13, plus 2 nonvoting17, plus 2 nonvoting legislatorsSPI has not yet confirmed
Reviews PRO annual reportsYes, before 31 Mar each yearReviews CAA financial reportYes
Plan stage2026 to 2030 plan in forceCAA plan in force, 2026 amendment reviewedFirst plan in 2027 to 2028
Next meeting on record28 Oct 202618 Nov 2026SPI has not yet confirmed

Source: CDPHE advisory board and members pages; C.R.S. 25-17-704; Oregon DEQ Recycling System Advisory Council page; MPCA Packaging Waste and Cost Reduction Act page; all consulted, checked 30 Oct 2026.

Different laws and programme stages. Shown side by side for structure and timing only. No fees are compared or summed. SPI's Minnesota report of 21 Oct covers that board's first work.

Colorado’s board is the only one of the three whose size and seat types are written into statute with a reserved place for an environmental justice expert. SPI’s report on Minnesota’s board of 21 October covers that body’s first work on mixed waste processing.

SPI analysis

Multi-state producers can treat Colorado’s 2027 report cycle as the first full test of a CAA annual report before a statutory board. Oregon’s council has seen CAA’s financial reporting, but Colorado’s 17-element list is the more detailed public template.

The longer calendar: 2027 to 2030

1 January 2027: eco-modulation bonus schedule. Section 25-17-709(1)(d) requires the executive director to develop the bonus schedule each year, for producers that meet benchmarks set by rule, after consulting CAA and the board. CAA must then reduce dues in line with it. CDPHE says the commission approved producer eco-modulation rules in Section 18.9 and dues factors in Section 18.2.7 in November 2025; SPI has not yet confirmed the adopted text.

30 June and 1 August 2027: the state’s costs. Section 25-17-715 requires CDPHE to tell CAA by 30 June each year what it spent the previous year, including on the board, and CAA then sends that amount from dues to the state treasurer. Rule 18.10 sets the annual reimbursement date at 1 August 2027 and each year after.

1 July 2027: the threshold. Section 25-17-713(2) requires the commission to adjust the USD 5 million revenue threshold by rule on 1 July each year, using the Denver-Aurora-Lakewood consumer price index. The 1 ton threshold is not indexed.

2028: schools and consumer costs. CAA’s amended plan begins reimbursing school recycling in 2028, with government buildings and public places before 2030 and hospitality and small businesses in 2030. The first consumer cost review also starts in 2028.

2029: needs assessment and second PRO. CAA must hire an independent third party, approved by the executive director, to update the needs assessment by 1 May 2029, with any change of scope by 15 April 2029. Rule 18.7.2 opens requests for an additional PRO from 1 January 2029.

2030: renewal. The plan covers 2026 to 2030, and section 25-17-705(4) requires updated plan proposals on 1 February every five years. If every review window ran to its limit, a proposal filed on 1 February 2030 would reach a decision on 13 December 2030, by SPI’s calculation.

If each window ran to its limit, a plan filed on 1 February 2030 would take 315 days to reach a decision, by SPI's calculation Unit: calendar days, statutory maximum for each step
If each window ran to its limit, a plan filed on 1 February 2030 would take 315 days to reach a decision, by SPI's calculation4 bars. Largest: Executive director decides, 120.Board reviews planBoard reviews plan: 90 calendar days, statutory maximum for each step90CAA files amended planCAA files amended plan: 60 calendar days, statutory maximum for each step60Board forwards amended planBoard forwards amended plan: 45 calendar days, statutory maximum for each step45Executive director decidesExecutive director decides: 120 calendar days, statutory maximum for each step120If each window ran to its limit, a plan filed on 1 February 2030 would take 315 days to reach a decision, by SPI's calculation4 bars. Largest: Executive director decides, 120.Board reviews planBoard reviews plan: 90 calendar days, statutory maximum for each step90CAA files amended planCAA files amended plan: 60 calendar days, statutory maximum for each step60Board forwards amended planBoard forwards amended plan: 45 calendar days, statutory maximum for each step45Executive director decidesExecutive director decides: 120 calendar days, statutory maximum for each step120

Source: C.R.S. 25-17-705(5); 6 CCR 1007-2 Part 1 rule 18.5.2; SPI calculation, checked 30 Oct 2026.

In the order the steps run. Maximum periods under the statute; steps can finish sooner. The 8-day posting runs alongside board review and is not added. A rejected plan restarts with a 60-day resubmission. Dates by SPI's calculation from a 1 Feb 2030 filing.

Show the data
If each window ran to its limit, a plan filed on 1 February 2030 would take 315 days to reach a decision, by SPI's calculation (calendar days, statutory maximum for each step)
StepDays (calendar days, statutory maximum for each step)
Board reviews plan90
CAA files amended plan60
Board forwards amended plan45
Executive director decides120

The renewal plan will rest on the plan’s targets. CAA’s amended plan sets a total collection rate of 44% by 2030 and 59% by 2035, from 29% in 2022, and a recycling rate of 41% by 2030 and 55% by 2035, from 25%. CDPHE’s programme page projects the paper and packaging recycling rate rising from 25% to 58% by 2035 under the programme, and the plan projects about 570,000 tons collected and 530,000 tons recycled a year by 2030.

What it means for you

SPI analysis

These points are about business planning and follow from the statute, rules and CDPHE pages above. They are not legal advice; questions on obligations belong with counsel.

  • Brand owners: treat the 28 October, 18 November and 9 December meetings as the public window before the 1 January 2027 bonus schedule, and register through Zoom to comment.
  • Finance teams: expect CAA’s first annual report, on SPI’s reading due before 31 March 2027, to set out 2026 dues collected by material and the reasons for 2027 rate changes.
  • Packaging buyers: the 2030 recycled content targets, 20% for rigid plastic, 5% for flexible plastic and 40% for paper, are what the report will measure progress against.
  • Retailers: check own-brand packaging against the producer rules, since the retailers’ association seat is the only retail voice on the board.
  • Small producers: watch the 1 July 2027 threshold adjustment against the USD 5.6 million figure in the February 2026 briefing.
  • Waste and recycling firms: the reimbursement rate schedules and rate disputes go into the annual report, so filed disputes become part of the board’s record.
  • Investors: ask consumer goods holdings how they track Colorado’s 2027 amendment cycle, given that CDPHE can request changes at least 60 days before the report deadline.

Follow PR-US-003 in the SPI Regulation Tracker for the United States and its Colorado record, and check company pack formats in the Packaging Buyers Database.

What to watch next

  • 28 Oct 2026: advisory board business meeting, 1:30 to 4:30 p.m., online and in person, with public comment and Spanish interpretation.
  • 18 Nov 2026: advisory board meeting, 12:30 to 2:30 p.m.; Oregon’s council also meets that day.
  • 9 Dec 2026: advisory board meeting, 12:30 to 2:30 p.m., the last on CDPHE’s 2026 list.
  • 31 Dec 2026: the environmental justice seat’s term ends, CDPHE’s members page shows.
  • 1 Jan 2027: the executive director’s annual eco-modulation bonus schedule is due under section 25-17-709(1)(d).
  • 30 Jan 2027: last day for a CDPHE amendment request if the first report is due on 31 March 2027, by SPI’s calculation.
  • 31 Mar 2027: CAA’s first annual report to the board, on SPI’s reading of the statute.
  • 1 Jul 2027: annual inflation adjustment of the small producer revenue threshold.

FAQ

When does Colorado's EPR advisory board meet next?

CDPHE’s page lists a business meeting on 28 October 2026 from 1:30 to 4:30 p.m., online and in person. Two more meetings follow on 18 November and 9 December 2026, each from 12:30 to 2:30 p.m.

Does the advisory board approve CAA's plan or dues?

No. Under C.R.S. 25-17-704 and 25-17-705, the board reviews plans and amendments and recommends approval or rejection, and CDPHE’s executive director decides. Rule 18.5.3 says a routine annual dues update does not need a plan amendment.

When is CAA's first Colorado annual report due?

Section 25-17-709(2)(a) sets the deadline before 31 March of the programme’s second year. CAA lists implementation as starting in early 2026, which points to 31 March 2027 on SPI’s reading, but CDPHE has not published a date.

How can a producer raise a point with the board?

CDPHE says stakeholders and the public may observe meetings and give public comment. For 28 October, up to 12 people can attend in person after signing up, and others register through Zoom.

What happens in 2029 and 2030?

CAA must commission an updated needs assessment by 1 May 2029, and requests for an additional PRO open on 1 January 2029. The 2026 to 2030 plan is then renewed, with an updated proposal due on 1 February 2030 on SPI’s reading of section 25-17-705(4).

Sources

  1. Colorado Department of Public Health and Environment, Producer Responsibility Advisory Board, undated page (consulted 2026-10-27)
  2. Colorado Department of Public Health and Environment, Producer Responsibility Advisory Board members, undated page (consulted 2026-10-27)
  3. Colorado Department of Public Health and Environment, Producer Responsibility Program, undated page (consulted 2026-10-27)
  4. Colorado Department of Public Health and Environment, Solid waste proposed rulemakings and stakeholder processes, undated page (consulted 2026-10-27)
  5. Colorado General Assembly, HB22-1355, signed act (C.R.S. 25-17-701 to 25-17-716), signed 3 June 2022 (consulted 2026-10-27)
  6. Colorado Revised Statutes, section 25-17-704, text via colorado.public.law (consulted 2026-10-27)
  7. Colorado Revised Statutes, section 25-17-705, text via colorado.public.law (consulted 2026-10-27)
  8. Colorado Revised Statutes, section 25-17-709, text via colorado.public.law (consulted 2026-10-27)
  9. Colorado Revised Statutes, section 25-17-715, text via colorado.public.law (consulted 2026-10-27)
  10. Code of Colorado Regulations, 6 CCR 1007-2, Part 1, Section 18, text via Justia Regulations, current through 10 June 2025 (consulted 2026-10-27)
  11. Circular Action Alliance, Colorado Amended Program Plan, submitted 1 July 2025 (consulted 2026-10-27)
  12. Circular Action Alliance, CAA Colorado Final Plan Overview, undated (consulted 2026-10-27)
  13. Circular Action Alliance, Circular Action Alliance Colorado, undated page (consulted 2026-10-27)
  14. CDPHE and Circular Action Alliance Colorado, Colorado’s Extended Producer Responsibility Program (HB 22-1355), briefing for the House Transportation, Housing and Local Government Committee, 3 February 2026 (consulted 2026-10-27)
  15. Oregon Department of Environmental Quality, Oregon Recycling System Advisory Council, undated page (consulted 2026-10-27)
  16. Minnesota Pollution Control Agency, Packaging Waste and Cost Reduction Act, undated page (consulted 2026-10-27)

Go deeper

More from SPI News

All articles
  1. Global · Corrugated and containerboard

    Smurfit Westrock cut its 2026 EBITDA estimate to about $4.7 billion as freight and energy costs rose about $700 million

    Smurfit Westrock expects 2026 adjusted EBITDA of about $4.7 billion, down from the $4.9 billion to $5.1 billion it gave in July, after its third quarter came in at $1,205 million; its…

    14 min read

  2. United States · Rhode Island

    Rhode Island’s draft EPR and bottle bill study models 13% to 47% diversion across five plans; hearing 4 November

    A draft analysis for RI DEM puts net costs for five modelled plans at USD 13.2 million to USD 77.0 million at full implementation; DEM holds a public hearing on 4 November…

    14 min read

  3. United Kingdom · Recycling and packaging reform

    Diverting 80% of PET and aluminium to deposit return could cut UK MRF material income over 30%, CIWM says

    CIWM's expert group says PET and aluminium are about 12% of a tonne of dry mixed recycling but about 39% of material income, and asks for deposit return, due 1 October 2027,…

    14 min read

ClosingAsk the SPI team

Ask the SPI team

What changes for your packaging next quarter?

Tell us your markets and materials. The SPI team walks you through the rules and buyer commitments that affect them.

Prefer email? Write to sales@strategicpackaginginsights.com.

Questions people bring
  1. Q1

    Which packaging rules apply to us in each market we sell in?

    We map each market's EPR, tax, ban, recycled-content, labelling and deposit rules against your materials and formats, and show which are in force, adopted or only proposed.

  2. Q2

    What could EPR fees and plastic taxes cost us next year?

    We apply published fee tables and tax rates to your tonnages and recycled content, and show the result as scenarios with every rate sourced.

  3. Q3

    Can you tell us when a rule changes?

    Yes. The free tracker alerts cover rule changes by country; a monitoring retainer adds monthly notes on what the changes mean for your portfolio.