The Auto Care Association has formally raised objections regarding the rollout of Colorado’s Extended Producer Responsibility (EPR) legislation, citing operational friction caused by dual compliance structures. Under the current state framework, automotive aftermarket businesses risk facing redundant audits and compounding financial assessments. The trade group’s primary concern stems from an overlapping system where regulated members may be obliged to remit fees and submit to auditing by two distinct Producer Responsibility Organisations (PROs)—Circular Action Alliance and Interchange 360.
As extended producer responsibility legislation expands globally, the administrative design of compliance systems increasingly determines their economic feasibility for regulated businesses. The challenge in Colorado illustrates a critical vulnerability in circular economy frameworks: regulatory fragmentation. When multiple PROs operate within the same jurisdiction without distinct boundary lines, obligated producers face duplicative compliance costs, conflicting reporting metrics, and redundant operational friction. This administrative complexity threatens to divert funding away from infrastructure investment and into compliance management.
For UK packaging converters, waste management operators, and Turkish exporters, the dispute in Colorado serves as a case study in compliance risk management. While the UK’s phased packaging EPR (pEPR) rollout utilizes a scheme administrator model designed to limit multi-PRO friction, exporters targeting international markets face a patchy mosaic of regional compliance bodies. Turkish converters supplying packaging products into North America or European jurisdictions with decentralized systems must rigorously verify local PRO mandates. Overlapping reporting regimes can rapidly escalate compliance overheads, inflate cost structures, and complicate material traceability across export supply chains.
Practical Takeaway: Businesses trading packaging or packaged goods internationally should conduct an immediate audit of their target market PRO registrations. Establishing a centralized reporting system to map packaging volumes against specific state or national compliance bodies is essential to prevent duplicate fee payments and ensure audit readiness across fragmented regulatory landscapes.
