Auto Care Association seeks to join suit against Colorado packaging EPR law
The Auto Care Association filed a motion on 15 October 2026 to join as plaintiff in National Association of Wholesaler-Distributors v. Ryan, the federal suit challenging Colorado's packaging extended producer responsibility law. The association objects to automotive and petroleum producers having to report and pay fees to both Circular Action Alliance and the Lubricants Packaging Management Association (LPMA) for the same products. Member AutoZone has paid more than USD 575,000 to the two organisations, and LPMA plans to move to a materials-based fee schedule on 1 January 2027 that the complaint says could raise some rates by over 300%.
Why this mattersA second producer-responsibility organisation operating alongside Circular Action Alliance raises compliance cost and complexity that other states weighing EPR design may need to address.
- Auto Care Association filed its motion on 15 October 2026 in the US District Court for the District of Colorado.
- CDPHE approved LPMA's individual program plan, operating as Interchange 360, on 9 September 2025.
- O'Reilly has been invoiced more than USD 350,000 by CAA and expects LPMA fees above USD 500,000.
- AutoZone has paid more than USD 575,000 across both organisations, including over USD 415,000 to LPMA, plus about USD 390,000 in consultant and software costs.
- LPMA currently charges a flat 56 cents per gallon and plans a materials-based schedule from 84 cents to USD 1.88 per gallon starting 1 January 2027.
- The Independent Lubricant Manufacturers Association separately sued over the LPMA plan in Colorado state court in March 2026.