What URCO Composting Exemptions and Waivers Exist in Denver?

URCO provides limited exemption paths. The main one is de minimis volume: a premises generating less than 64 gallons of trash per month, or less than 48 gallons of organic materials per month, may qualify. Other paths involve inadequate hauling availability and approved on-site processing. Most covered properties do not qualify.

If you are here hoping to find a way out, read the de minimis numbers carefully first. This post covers every exemption path, how to document one, and the option that usually works better than chasing an exemption at all.

De minimis volume, hauling availability, and on-site processing, plus why most properties do not qualify.

What is the de minimis exemption?

The volume-based exemption applies to premises generating very small quantities of waste.

The organics threshold is less than 48 gallons of organic materials per month. There is also a trash threshold of less than 64 gallons per month, and a separate recyclables threshold for the recycling requirement.

To put 48 gallons per month in perspective: that is roughly one 13-gallon kitchen bag of food waste per week. A single-person household clears that. A restaurant clears it in a day.

Realistically, this exemption exists for edge cases such as a tiny retail operation with a coffee station, not for functioning kitchens or residential buildings with 8 or more occupied units.

What if no hauler will serve my property?

There is an exemption pathway tied to inadequate availability of hauling service.

This is narrower than it sounds. It is not "the quotes were expensive" or "my current hauler does not offer organics." It contemplates a genuine absence of available compliant service.

Denver has an active licensed hauler market with multiple providers offering organics collection. Before assuming service is unavailable, get real quotes from multiple licensed haulers. Most properties that believe they cannot get service have talked to one company.

Does on-site composting count?

Approved on-site processing can serve as a diversion pathway.

This is relevant for properties running in-vessel systems, community garden composting programs, or similar arrangements. The bar is that the material is genuinely processed and diverted, and that you can document it.

For most multifamily and food service operations, on-site processing is not practical at the volumes involved. Where it works, it works well and should be documented in your Waste Diversion Plan.

Does food donation reduce my obligation?

Donating edible surplus food to food banks and shelters is a recognized diversion pathway and belongs in your program.

It does not eliminate the composting requirement, because donation handles edible surplus while composting handles inedible scraps. Prep trim, bones, peels, and plate waste are not donatable. Run both.

Are townhomes and rowhomes exempt?

Some are, and this is a coverage question rather than an exemption.

Townhomes and rowhomes that hold their own account with Denver Solid Waste Management are outside the multifamily requirement, because the city already services them as residential customers.

The test is who provides service, not building style.

How do you document an exemption?

Assume you will have to prove it.

Measure and record actual volume over a representative period, including peak weeks. Retain the records. Note the basis for the exemption in your Waste Diversion Plan.

An undocumented exemption is functionally identical to non-compliance when an inspector arrives, and the fine ladder under Denver Municipal Code §48-47 starts at $150 and escalates to $500 and then $999, with each continuing day a separate offense.

What about shared service instead of an exemption?

Frequently the better answer for small properties.

Shared waste diversion arrangements between adjacent or related properties let small generators reach compliant service economically without chasing an exemption they probably do not qualify for. The arrangement needs to be documented.

If your property is small enough that you are researching exemptions, price shared service first.

Frequently asked questions

Is there a small business exemption? Not by business size as such. The relevant threshold is volume generated, not headcount or revenue.

Do I have to apply for an exemption? Document your basis and retain records. Requirements for notifying the city should be confirmed against the current adopted rules.

Does a seasonal business get an exemption? Seasonality does not create an exemption on its own. Capacity should be sized to peak operating periods.

Our building is under renovation and vacant. Does URCO apply? Coverage tracks the premises and its generation. Document the vacancy period.

Find out where you actually stand

Melly's Recycling is a Denver URCO compliance company, not a hauler. We determine coverage, measure volume in gallons, document exemption eligibility where it genuinely applies, and build the compliance program where it does not. That includes Waste Diversion Plans, bilingual signage, education, annual reporting, and documentation, plus coordination of licensed Denver haulers through a sealed-bid process.

You finish what you started.

Request your free URCO compliance audit.