FAQ

The company which signs an agreement with a PRO Europe member is relieved of its individual obligation to take back and/or to recycle used sales packaging through the operation of a scheme which fulfils these obligations on a nation-wide basis on its behalf. The company has the guarantee that its recycling obligations are fulfilled in that country in an economically efficient and ecologically sound manner. In addition, the company may also receive the right to place the ‘Green Dot’ logo on its packaging (see next question for the meaning of the Green Dot).

No, the company in question has to sign, via its local importer, an agreement with the respective Green Dot system in each country

PRO Europe provides further information on the following countries:

• Denmark
• Finland
• Iceland
• Italy
• Japan
• Russia
• Switzerland
• Ukraine

Do we need to register in the EU since “Green Dot North America” only applies to products, which are sold and distributed in North America?

Should there be subsidiaries or entities of your group in this country, to which you would like to export, you have not to request membership in a national Recovery Organisation. In this case, it is the European subsidiary or entity that must become a member of the national Recovery Organisation. Should there be no subsidiary or entity you have to register in the EU.

If you wish to use the Green Dot trademark for North America after December 31, 2024, you must have a valid trademark agreement with at least one PRO Europe member country. The licensee may then enter into a Royalty Free License Agreement (RFLA) with Der Grüne Punkt/PRO Europe and continue to use the trademark on packaging in the NAFTA region.

There are several factors affecting fee levels which should be taken into account when comparing the relative costs of compliance across various European schemes.

Major factors influencing relative compliance costs include the following:

• Existing collection and recovery infrastructure in the waste management sector
• The source of packaging waste used to meet national recycling quotas (household only or all packaging) - household packaging waste is usually more expensive to collect and recover than packaging waste arising in the commercial sector
• The proportionate share of costs which industry bears - some schemes meet 100% cost of collection and recovery, while others can rely on other sources of income.
• National recycling quotas and the effect of derogations
• The collection system used - "bring" systems are in general less expensive than kerbside collection.
• Geographic location and population density - remote and sparsely populated regions will generally be more difficult and expensive to cover.
• Enforcement regimes influence costs - the more companies who participate in the scheme, the greater the spread of the cost base.
• Country specific labour costs and general overheads.

If the company decides to use another authorized recycling solution but signs a separate contract for the use of the Green Dot with the local ‘Green Dot’ organisation, the fee to be paid will only concern the licence of the trademark.

Have a look at the list of license fees per organisation/country: https://www.pro-e.org/the-green-dot-trademark/licence-fees

No, according to current information available to us, the application of the Green Dot is no longer obligatory in Spain as of  2023. This means that the use of Green Dot has become voluntary throughout the EU. Nevertheless, there is a benefit  to concluding a trademark use contract for the Green Dot: this financing symbol is internationally known and stands for the participation of "your packaging" in a nationally approved take-back system, plus it signals to consumers that you are taking on "producer responsibility" for your packaging and that you are supporting packaging recycling.

If a company is using the Green Dot on its packaging and is fulfilling its recycling obligation in a certain country by using another authorised recycling solution, it may use the Green Dot on the packaging but should sign a separate contract for the use of the trademark with the national ‘Green Dot’ organisation or licence holder.

No, the company in question has to sign, via its local importer, an agreement with the respective Green Dot system in each country.

Among the EU countries, Italy, Denmark, and Finland are not using the Green Dot as a financing symbol.

In the UK and the Netherlands, the symbol does not demonstrate a financial contribution to the recovery of packaging in these respective countries but is used under licence by companies placing packed products on the respective market in addition to other European markets, such as the Republic of Ireland. It is recognised that although the symbol does not bear the usual meaning in the UK, it is often more environmentally friendly for companies to be able to use uniformly designed packaging in multiple markets rather than having to design and manage separate packaging designs for different countries.

Different systems exist in some countries in which PRO Europe does not have member organisations. Denmark is in the process of establishing EPR, and Switzerland has special systems for each material.

The use of the Green Dot financing symbol is still possible in France. The French government had drafted legislation which in effect discriminated against the Green Dot – companies who used it would have been required to pay a 100 % “malus” on top of the EPR fee. Because this legislation was discriminatory, and a violation of the principles of the internal market, the French Supreme Administrative Court, the Conseil d'État, decided to suspend this “penalty payment”. A final court decision on this was passed in July 2023: The French Supreme Administrative Court nullified the “malus” for use of the Green Dot financing symbol on packaging in France. With this, the discrimination against the Green Dot financing symbol associated with the French labelling ordinance is ended for good.

Questions about the French TRIMAN signet reach us regularly. Please note that PRO Europe has nothing to do with this topic – it is a decision of the French government. Despite the success that has now been achieved with regard to the Green Dot financing symbol, we see no signs of a release from the currently valid regulations: Since 1.1.2022, it has been mandatory for market participants in France to affix the French TRIMAN signet in conjunction with information on waste separation on all household packaging (both standardised). The participating take-back systems, including CITEO as PRO Europe scheme, will provide their customers with guides on the correct markings. A transition period ended 9 September 2022. It granted to make the adjustments. By 9 March 2023 at the latest, packaging imported or manufactured before 9 September 2022 must also bear the appropriate markings. Special instructions have been developed for international shipping (pictograms with country code "FR" ). As a concerned company, you should stay in contact with your take-back system or your Chamber of Commerce abroad for France.

The Green Dot is the financing symbol for the organisation of recovery, sorting and recycling of sales packaging. When you see the ‘Green Dot’ on packaging it means that for such packaging, a financial contribution has been paid to a qualified national packaging recovery organisation, set up in accordance with the principles defined in EU Directive 94/62 on packaging and packaging waste and the respective national laws.

‘Green Dot’ systems have become internationally recognized models that contribute to the efficient fulfilment of the EU Directive on packaging and packaging waste, and the successful implementation of producer responsibility by the companies involved.

However, in some countries where a ‘Green Dot’ system is not operating, and as the symbol as such does not mean that the relevant companies in this country have contributed to the recycling of packaging, the symbol is still a registered trademark and a licence fee should be paid for its use to the relevant organisation.

Today, the Green Dot is the most widely used trademark in the world. More than 150,000 companies are licensees of the Green Dot trademark, while over 400 billion packaging items have been labelled with the symbol.

In general, for packed products which are filled in the country of distribution, the filling company is the one obliged by the respective national packaging legislation and the one that signs up with the respective packaging recovery organisation.

For packaged products imported into a certain country, it is the importer which generally signs the agreement with the recovery organisations. For example, it is usual that the national legislation on packaging places the responsibility for collection and recycling of packaging, at least on the first distributor of the packaged product in the respective market, i.e. the first importer, meaning the company with the first legal seat in a country.

However, as each system varies, it is recommended to check directly with the PRO Europe member organisation operating in the countries in which you market your packaged products for more detailed guidance. In some countries, such as the UK, the obligation can fall on more than one party.

As explained above, in many cases where a non-European company exports packaged products to European countries, it is the responsibility of its local importer to fulfil the recycling obligations and it can do this by joining the respective system in this country. If the importer joins a ‘Green Dot’ scheme, it will receive a licence for use of the Green Dot for all packaged products intended for this respective country. It can then inform the producer to label all packaging for this country with the Green Dot symbol.

You have to conclude separate trademark contracts with the national Green Dot organisations in the respective country you sell your packed products to. Therefore, you have to apply directly to Green Dot organisation.

For getting contact details, please click here.

The Royalty Free Licensing Agreement (RFLA) is an agreement for using “The Green Dot” in countries without a ‘Green Dot’ scheme or cooperation, mainly outside Europe. It safeguards both the use of the Green Dot and the Green Dot trademark rights. One precondition for concluding an RFLA is a separate trademark contract with at least one ‘Green Dot’ scheme which grants the right to use the trademark the Green Dot.

Please note: The agreement does not cover legal use of the Green Dot trademark in countries with a national Green Dot system – rather, you are obliged to conclude separate trademark contracts with the organisations in countries in which your product is sold. The agreement becomes invalid once all agreements with national ‘Green Dot’ systems have ended.

Click here to see the full list of ‘Green Dot’ member schemes.

One of the central objectives of PRO Europe is to ensure barrier-free movement of goods in the European Union and beyond. This means that companies who chose to use the Green Dot on their packaging should be able to do so in Europe and globally. This requires, however, that companies ensure legal use of the registered trademark by concluding contracts with national Green Dot systems.

Europe: View the list of national ‘Green Dot’ organizations   to conclude a bilateral contract for use of the trademark.

Other Countries: To further enable safe use of the trademark also outside of Europe, PRO Europe offers a Royalty Free Licensing Agreement. It covers nearly all countries outside Europe and NAFTA.

There is not such a general obligation. In all ‘Green Dot’ countries, you have to ensure a contract with the relevant organisations if you want to use the Green Dot.

Please note: You are obliged to fulfil the national legislations in each ‘Green Dot’ country you sell your packed products to.  For further information, see section “Members”.   

Would you like to use a globally unique design of packaging? Click here for more information.

PRO Europe, founded in 1995, is the umbrella organisation for European packaging and packaging waste recovery and recycling schemes which mainly use the Green Dot trademark as a financing symbol. In its primary role, PRO Europe is the general licensor of the Green Dot trademark.

The main task of PRO Europe’s members is to organize the efficient implementation of adequate national collection and recovery systems, mostly for sales and household packaging. In this way, industrial companies and commercial enterprises are relieved of their individual obligation to take back used sales packaging. The aim is to ensure the recovery and recycling of packaging waste in the most economically efficient and ecologically sound manner.

PRO Europe’s members span 31 countries: Austria, Belgium, Bosnia-Herzegovina, Bulgaria, Croatia, Cyprus, Czech Republic, Estonia, France, Germany, Greece, Hungary, Ireland, Israel, Latvia, Lithuania, Luxembourg, Malta, North Macedonia, Netherlands, Norway, Poland, Portugal, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden Turkey, and UK.

PRO Europe’s members in Europe were established as a direct response to the EU’s 1994 Directive on packaging and packaging waste.

In the majority of these countries, the Directive has been implemented through ‘producer responsibility’ systems set up to assume packaging waste collection and recovery responsibilities on behalf of the industry.  

Further information on non-member countries can be found here.

PRO Europe s.r.l. (Packaging Recovery Organisation Europe), founded in 1995, is the European umbrella organisation for the packaging and packaging waste recovery systems which mainly use the Green Dot trademark at a national level.