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RE: Support for HB 22-1355, Producer Responsibility Program for Recycling

May 9, 2022

May 9, 2022 

Honorable Jared Polis 

Office of the Governor 

200 E. Colfax Avenue 

Denver, CO 


United States 

RE: Support for HB 22-1355, Producer Responsibility Program for Recycling. 

Dear Governor Polis: 

We at the Pack Green Coalition – a newly-formed industry group that seeks to replace unnecessary plastic in the packaging supply chain with sustainable, environmentally-friendly alternatives – strongly support HB22-1355. This program, which would establish a producer responsibility program in Colorado for consumer packaging and paper products, is urgently needed to address the growing solid waste and recycling crisis facing Colorado’s local governments, taxpayers, and the environment. 

Pack Green advocates for the use of packaging materials that advance the transition to a more circular economy that minimizes and ultimately eliminates environmental waste. For far too long, technological advancement and productivity have followed the “take-make-waste” model, in which natural resources are extracted to manufacture products that are disposed of once their useful life is exhausted. One does not need to be an economist or an environmentalist to recognize that this system is not sustainable in a world with finite resources and scarce viable land. Throw in the ever-worsening climate change and plastic pollution crises, as well as their adverse impacts on Earth’s delicate ecosystems, and the need for change becomes urgent. 

Statewide waste management and recycling programs are fragmented and largely dysfunctional, yet Colorado has been at the forefront of states addressing this broken waste management system. HB22- 1355 – which would enact an Extended Producer Responsibility (EPR) program for packaging and printed paper – proposes a paradigm shift in which the responsibility for end-of-life management of these materials is transferred from local governments, taxpayers, and individual ratepayers to the producers who put them into commerce in the first place. We believe that this EPR approach is the optimal and most comprehensive solution to ensure sustainability and a strong step forward to a circular economy – in which waste and pollution are eliminated, materials and products are circulated at their highest value, and resources are replenished. 

EPR makes sense on two critical levels. As a matter of fundamental fairness, manufacturers have benefitted for centuries – at taxpayers’ expense – from avoiding any financial or logistical burden for the disposition of their economic output once its useful life has been exhausted. Obviously, the proliferation of waste from such output has increased astronomically since the Industrial Revolution and, in particular, post-WWII. Cash-strapped municipalities and their constituents in the United States have had to literally clean up the ensuing mess, while corporate profits are at record highs. On a practical level, EPR has proven in the EU and Canada to be a very effective tool for decreasing waste, increasing recycling rates, and prodding companies to move away from difficult-to-recycle materials and design their products with end of life in mind. 

Under the Colorado proposal, producers would pay to manage the packaging and printed paper they put on the market based on the costs of these materials to the recycling system and their impacts on the environment. Companies that use reusable or recyclable materials would pay less than those who choose materials that cost more to manage and pollute the environment. Further, to be considered “recyclable,” packaging and printed paper must have viable end markets. By taking this approach, HB22-1355 will incentivize brand owners to reduce packaging and paper waste, make packaging and paper easier to reuse or recycle, and boost market demand by using more recycled content, thus fostering a circular economy. This is exactly what the Pack Green Coalition seeks to accomplish. 

An effectively designed EPR program like HB22-1355 will provide the incentives that industry needs to replace fossil fuel-based materials, such as plastic and extruded polystyrene foam, with fiber, starch, and other organic materials. This, in turn, will boost recycling and composting rates dramatically, reduce our dependency on petrochemicals, and help address the plastic pollution crisis. In addition, EPR will provide the funds necessary to modernize and expand recycling infrastructure so that local programs can handle a greater quantity and more types of materials, and ensure that all residents have the opportunity to recycle. 

There is no doubt that Colorado citizens would benefit from this critical transition as greater volumes of recyclable materials are captured and processed, recycling rates increase, local green jobs are created, and a modernized and improved recycling system increases efficiency. HB22-1355 will also lower greenhouse gas emissions from waste and help achieve climate goals across the state, in keeping with the recommendations of Recycle Colorado. 

Pack Green’s mission is to educate consumers, lawmakers, and brand owners about their collective interest to move away from packaging materials that are not sourced from renewable raw materials and are not reusable or recyclable. Further, local governments are suffering from unreasonable burdens to collect, manage, and market recyclable materials. An EPR program for packaging and paper will shift responsibility for recycling from local governments, taxpayers, and ratepayers to producers by requiring them to engage in end-of-life management of their products and packaging. 

We applaud the Colorado legislature’s continued support for EPR for packaging and paper products. The packaging industry must be incentivized to more effectively embrace its environmental stewardship responsibilities. Local recycling systems desperately need to be modernized and improved. The time has come for this much-needed product management paradigm shift. 


James T. Asali 

President and CEO 

Pack Green Coalition

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