Register with CAA by October 1 for EPR Compliance
Overview
To comply with Colorado’s Extended Producer Responsibility (EPR) law for packaging (HB22-1355), producers must register with Circular Action Alliance (CAA) by October 1, 2024, for EPR compliance.
Registration by October 1 is mandatory under the law in Colorado, with potential negative consequences for lack of compliance.
If you’re unsure whether your company must report packaging or paper data in Colorado or elsewhere, read more or contact Reverse Logistics Group (RLG). Our EPR Impact Analysis can clarify your company’s compliance obligations.
What is Circular Action Alliance?
Circular Action Alliance (CAA) is a non-profit that fosters a circular economy by working with producers, retailers, and governments. The alliance supports waste management, promotes recycling, and encourages responsible disposal, especially for packaging and paper products.
CAA is expected to form Producer Responsibility Organizations in multiple states that have passed (or will pass) EPR laws for packaging and paper. CAA is currently active in:
- Colorado
- California
- Oregon
- Maryland
By registering with CAA, producers join a multi-state system designed to increase material recycling and reduce landfill waste, improving resource efficiency.
In Colorado, packaging EPR is overseen by the Colorado Department of Public Health & Environment, which is working with CAA to implement HB22-1355.
Who Needs to Register with CAA in Colorado?
The term “producers” refers to parties obligated under EPR laws. This includes brand holders, manufacturers, sellers, importers, distributors, and white-label retailers. Others whose products contribute to packaging waste in Colorado also qualify. Certain publishers and paper producers may also need to register.
The registration process ensures that producers join a collective program responsible for managing their products’ end-of-life.
Registration with Circular Action Alliance isn’t just for large corporations; small and medium-sized enterprises (SMEs) must comply as well.
The location of a company’s headquarters does not impact registration requirements. All producers must register, regardless of physical location in EPR-affected states.
Colorado’s EPR law aims to create a unified approach to waste management, regardless of a business’s size or location.
What If My Company Doesn’t Register with CAA by October 1?
Producers who miss the October 1 registration deadline in Colorado may face penalties, including fines and selling restrictions. The government and Circular Action Alliance set this deadline to accelerate responsible waste management practices across the state.
Benefits of Registration
By registering, producers not only comply with regulatory requirements but also contribute to several positive outcomes, including:
Environmental Impact: Responsible producers can help reduce their environmental footprint by ensuring their packaging and products are properly recycled and reused. Eco-modulation, a policy that rewards sustainability, is expected to incentivize sustainable design and waste reduction.
CAA Working Group: Registered producers will be given access to certain CAA meetings, including the opportunity to ask questions or voice concerns.
How to Register
Producers can register on the Circular Action Alliance’s website or contact RLG for assistance. Here’s an overview of the information needed for registration with CAA. Please refer to the source websites for the most current details. According to CAA’s website, a company should know:
- Whether it has obligations under any EPR laws in states that are affiliated with CAA
- Where obligations may occur
- Company legal business name and primary contact info
Currently, there are no registration fees for Colorado. A parent company should register instead of multiple registrations for subsidiaries. Registering with CAA also covers Oregon, California, and Colorado, eliminating the need for separate registrations in those states.
Producers should start early to avoid last-minute complications that could delay the registration process and result in missed deadlines.
Next Steps for Producers
With the deadline approaching, producers must act quickly to ensure compliance. Failing to register can lead to legal repercussions and missed opportunities to contribute to the growing circular economy
If you’re unsure whether your company must report packaging data under EPR laws, contact Reverse Logistics Group (RLG). Our EPR experts can help you determine if your products are covered on a state-by-state basis.
Packaging EPR Laws Are Here to Stay
Registering with CAA before the October 1, 2024 deadline is crucial for complying with EPR laws for packaging in the United States. Producers must prepare for this requirement. Maine and Minnesota have already passed EPR laws, while Maryland and Illinois have completed needs assessments to support future packaging EPR legislation. More states are expected to adopt EPR laws for packaging in the coming months and years.
EPR laws for packaging aim to enhance sustainability through eco-modulation policies. The better prepared your company is, the less it will pay in EPR fees as these laws expand across the United States.
Discover how RLG experts can save your company time and effort while reducing costs and mitigating risks. Contact us today.
About Reverse Logistics Group (RLG): We provide EPR compliance services to companies in the United States and 80 other countries. Furthermore, as part of the Reconomy brand family, we boast over 30 years of EPR compliance experience. Additionally, our product packaging databank includes 50 million SKUs, thanks to our strong relationships with leading CPG brands. So, contact us today to learn more about RLG.
Editor’s Note: This article is for informational purposes only and is not legal advice. We guarantee accuracy only at the time of publication. For the latest information, please visit primary sources or contact our EPR compliance experts.
