What is it?
Eco-modulation is the concept of increasing or decreasing producer responsibility organization (PRO) dues / fees to encourage environmentally friendly material use and product design.
Why is it needed?
Even though extended producer responsibility (EPR) regulations and laws have been implemented around the world for decades, the hoped for substantial environmental benefits, increase in the use of sustainable materials, and ecofriendly product design hasn’t happened.
Eco-modulation added to EPR is implemented to incentivize environmental design through pricing.
What is going on in Colorado?
The Colorado Department of Public Health and Environment (CDPHE) in consultation with the Circular Action Alliance (CAA) Colorado’s packaging PRO, and the Producer Responsibility Advisory Board have until 1 January 2026 to develop an eco-modulation driven plan for calculating dues.
The plan must incentivize:
- Reduction in the amount of packaging materials used for products
- High recycling and refill rates of covered materials
- Designs for the reuse and refill of covered materials
- High level use of postconsumer recycled content material
- Innovations and practices to enhance the recyclability or commodity value
The plan must discourage:
- Use of covered materials that are not on the Minimum Recyclable List
- Designs and practices that disrupt the recycling of other materials
- Designs and practices that increase the costs of recycling, reusing, or composting covered materials
Implementation will be a challenge
A balance must be found that won’t penalize producers who have already made great improvements in material use and eco-design, while incentivizing those who still need to make improvements. Additionally: data collection and monitoring need to be improved; ways to quantify innovations and practices must be established; ways found to make sure certain packaging types aren’t unfairly disadvantaged (e.g. weight reduction requirements and glass packaging); and recycling infrastructure may need to be changed to effectively deal with changed products.
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Published August 19, 2024
Image generated with the assistance of Artificial Intelligence.