Michele Raymond Publisher State Recycling Laws and Recycling Laws International College Park, Md.

A proposal to license the “Green Dot” recycling symbol in Canada has drawn opposition from industry representatives and environmentalists.

The European Green Dot symbol, affixed on packages, denotes that the package's manufacturer has complied with European federal recycling laws by paying collection and recycling costs. Owned jointly by Germany's Duales System Deutschland (DSD), Koln, and Pro Europe, an umbrella organization for industry-run collection organizations based in Brussels, Belgium, the symbol already is licensed in 11 countries and trademarked in approximately 160 countries.

Now, the Toronto-based Corporations Supporting Recycling (CSR) is negotiating with Pro Europe to make Canada the first non-European country to receive the Green Dot license.

But unlike the European countries that use the Green Dot, Canada currently does not require its package manufacturers to pay for recycling. Canada also does not provide national packaging collection. In fact, the only Canadian province that has addressed packaging take-back is Quebec, which last year enacted an authorization bill for “extended producer responsibility (EPR).”

Many in the recycling industry are angry that Pro Europe would consider licensing the Green Dot in a country where take-back laws are not yet in place.

“Pro Europe risks hurting its credibility with this [move],” says one Canadian recycling consultant. “It's like dumbing down the Green Dot.”

But a Pro Europe lawyer says there is no need for Canada to have a take-back law in place before using the Green Dot symbol. If CSR can ensure the Green Dot “guarantee” by proving its capacity to collect all Green Dot packaging, then the symbol's reputation will not be compromised, he says.

Canadian industry representatives oppose the Green Dot because they say it represents a German concept of producer responsibility — a concept they believe is unfair. German manufacturers pay DSD approximately $2 billion per year to collect packaging from consumers. Companies that do not pay are subject to non-compliance lawsuits. And, critics say that while per-capita packaging in Germany has declined, consumers' garbage fees have not.

“The perception of the Green Dot is very negative with my members,” says Larry Dvorkin, a lobbyist for the Packaging Association of Canada (PAC). “We are collecting more than they are in Germany. It's all market-driven here. The cost differential [between Germany's system and Canada's] is enormous.”

Grocery and beverage producers who support Canada's Green Dot licensing say they do not intend to implement a German-style system in Ontario — they merely want to use the symbol to persuade all companies to pay into the system.

But while Dvorkin agrees that CSR's Green Dot proposal has merit, he says that implementing the program without national standards in place is problematic. For example, each province could decide that it wants its own recycling symbol, thereby glutting Canada's market with a confusing array of symbols and package manufacturing requirements, he says.

Additionally, recycled products resulting from closed-loop recycling systems not using the Green Dot symbol could suffer from negative public opinion. The licensing fees that CSR will have to pay Pro Europe likely will be added to industry fees, he continues.

Dvorkin questions whether the organization licensing the Green Dot will have a monopoly.

But the most vehement opposition to the symbol comes from the Canadian Federation of Independent Business (CFIB), Toronto, Ontario, Canada, which represents 100,000 small- to medium-sized businesses.

CFIB's Judith Andrews says she has serious concerns about the government's giving levy-setting power to a private business organization “comprised exclusively of big business.”

Echoing Andrews' concerns about businesses backing CSR, Toronto recycling consultant Clarissa Morawski says she fears that the Green Dot license idea is yet another scheme by beverage interests to discourage container deposits and product stewardship programs.

Environmentalists have voiced similar concerns.

But so far, these and other questions about CSR's plans for the Green Dot symbol remain unanswered. CSR applied for the license in secret and has not yet publicized any details. And, a CSR spokeswoman refused to comment on the application, saying negotiations have not been finalized.

Pro Europe officials say they expect to finalize license negotiations early this year.

Meanwhile, Ontario's Environment Minister Dan Newman has said he intends to introduce legislation this year that would force Canadian industry to pay 50 percent of the province's “Blue Box” recycling system.