ISPA joined a coalition of stakeholders in submitting a letter to Colorado Governor Jared Polis, urging him to reconsider aspects of the Colorado Department of Public Health and Environment’s (CDPHE) new letter outlining requested revisions to Circular Action Alliance’s (CAA) Amended Program Plan. CAA is the producer responsibility organization approved to operate Colorado’s packaging extended producer responsibility (EPR) program. Colorado’s EPR law sets specific post-consumer recycled content (PCR) minimums that differ by packaging material type.

CDPHE’s requested revisions include expanded restrictions on how post-consumer recycled (PCR) content may be verified and calculated under the program. Specifically, CDPHE directed CAA to remove all “credit method” mass balance procedures for calculating PCR in covered materials. The decision to prohibit mass balance credit methods for verifying PCR content removes a widely recognized, third-party audited tool that many companies already rely on to measure PCR. If implemented, this change will raise costs to businesses and make it more difficult for manufacturers and brands to meet Colorado’s EPR program PCR goals.