The European Parliament has adopted a resolution on the impact on fisheries of marine litter
(2019/2160(INI)), which had been prepared by the Fisheries Committee.
We fully share the concern about the environment that has motivated it. However, we regret that it “urges
the Commission […] to consider phasing out expanded polystyrene containers and packaging from fishery
products in line with the ambition of replacing single-use plastics with durable alternatives for the environment
and fishers” (para. 25).
- We call expanded polystyrene (EPS) ‘engineered air’, as it is a rigid foam plastic produced from (solid)
polystyrene (PS) and 98% air, creating a different material, which is resource efficient by design.
EPS is the common packaging material of choice for landed fish. It is essential to fishery, due to its unique
qualities. For example, the excellent insulation properties of EPS keep fish fresh and avoid food waste.
Unlike some cellulose-based materials, EPS supports hygiene, because it resists humidity, preventing the
spread of bacteria, mould and fungi, thus keeping the food safe.
Its light weight, combined with its superior thermal insulation properties, reduces the need for cooling, e.g.
with heavy ice, which saves energy during transport and storage across the whole logistics chain.
- Furthermore, EPS is 100% recyclable. Already in 2017, recycling rates for EPS post-consumer
packaging waste exceeded 52% in Belgium and Norway, 47% in the Netherlands, 46% in Germany, and 38%
in Italy, showing that EPS recycling is economical. Specifically, in countries like Norway, Denmark, and the
Netherlands, at least 80% of EPS fish boxes are recycled. Moreover, the EPS industry has been working
towards further increasing EPS recycling by investing in new technologies to exceed the EU’s goals.
EUMEPS was one of the first to submit a recycling pledge to the European Commission and now actively
contributes to the Circular Plastics Alliance (CPA) to collectively achieve the goal that 10 million tonnes of
recycled plastics are used in European products by 2025.
- There are no more sustainable alternatives to EPS with the same essential functionality available.
For example, in a peer-reviewed comparative life cycle analysis (LCA), PwC concluded that for two scenarios
in Spain and France, EPS fish boxes performed similar or better than Polypropylene (PP) and cardboard
alternatives on all environmental indicators except one (the formation of photochemical oxidants).
- Unjustified claims about the prevalence of EPS in the marine environment have been based on beach
litter item counts. However, beach litter does not accurately reflect overall marine pollution. According to the
European Environmental Agency (EEA) and United Nations Environment Programme (UNEP), only 15% of
marine debris floats on the sea surface; another 15% remains in the water column, and 70% rests on the seabed.
Due its 98% air content, EPS floats. Thus, it does not contribute to the majority of the marine debris in the
water column and on the seabed. Furthermore, item counts do not reflect the mass of any pollutant in the
The EU-wide beach litter data that the EU Institutions have relied upon (European Commission, Impact
assessment for the ‘Single-use Plastics Directive’, SWD(2018) 254 final, part 2, pp. 31 et seq.) does not smartpackagingeurope.eu | eumeps.org | plasticseurope.org | plasticsconverters.eu 2
specifically identify EPS. Relevant categories used in said beach litter counts mix (solid and foamed) PS with
(all sorts of) other plastics. In fact, less than 1% of all litter items found on EU beaches have been clearly
identified as PS (Impact Assessment, op cit., categories ranking 28 and 53). The preceding 2017 JRC report
on Top Marine Beach Litter Items in Europe identified EPS fish boxes - but only as 0.02% of all litter (p. 40).
Having said that, the EPS industry shares your concerns about the marine environment. We are fully
committed to protecting the environment in general from any negative impacts. To this end, the industry
has been engaged in many initiatives, e.g.:
• EUMEPS’ packaging division Power Parts is a partner of Operation Clean Sweep (OCS). OCS works
on preventing the leakage of plastic pellets during production, handling, transportation, conversion, and
recycling across Europe.
• Smart Packaging Europe’s supporters Storopack and BASF broke new ground in 2019 by using material
from an innovative recycling process to produce EPS fish boxes and other insulative food packaging.
Complementing other, well-established recycling options for EPS, the process allows for the recycling
of mixed plastic waste.
• BEWI, another Smart Packaging Europe supporter and EUMEPS member, is quickly expanding its
collaboration with Doca Pesca (a state-owned company under the Ministry of Agriculture) to collect
EPS fish boxes for recycling in fishing ports across Portugal.
• In Spain, Italy, Portugal, Greece, and beyond, the LIFE-funded project, EPS-SURE has demonstrated
that it is technically, environmentally, and economically viable to collect, store, pre-treat (compaction,
briquetting, washing), and recycle waste EPS fish boxes into new PS food contact packaging. Thus, it
has closed the loop and overcome challenges that any comparable material used for fish boxes faces.
Whilst the final results have not yet been published, the expected outcome is the reduction of the
landfilling of waste EPS fish boxes by 80% in some European countries (70% in Spain and 50% in
Italy and Greece).
• In Spain and Portugal, as documented by the European Commission in 2018, the LIFE project 3-R Fish
has contributed to lessening the impact of fishing industry waste. It developed new systems for
collecting, processing, and reusing the fishing industry’s main solid wastes at ports in Galicia
(Spain) and north-west Portugal. These wastes included (plastic) fishing nets and EPS packaging,
which are used at fish auctions.
• AIPE, EUMEPS’ national association in Italy, has initiated a cooperation with Federpesca, the Italian
fishery federation, on a whole series of projects with SMEs for a circular economy. They will build on
AIPE’s already successful projects on the collection of EPS fish boxes, e.g. from retailers. AIPE has
also been collaborating with Corepla, the national consortium for the collection, recycling and recovery
of plastic packaging, to promote the collection and recycling of all EPS packaging.
• In Greece, EUMEPS’ national association EPS Hellas is supporting an initiative led by the non-profit
organisation Archipelagos Institute of Marine Conservation to put in place an experimental net for the
cleaning of surface waters from plastic waste.
For these reasons, we call on the European Commission to refrain from any restrictions on EPS containers
and packaging. Any such restriction would be not only unjustified and disproportionate, but even
counterproductive, given the already excellent and further improving environmental performance of EPS
packaging, including fish boxes. Rather, we ask the Commission to support the non-discriminatory separate
collection of EPS for recycling.smartpackagingeurope.eu | eumeps.org | plasticseurope.org | plasticsconverters.eu 3
• Smart Packaging Europe is an alliance of companies big and small that reflects the diversity of the
European Expanded Polystyrene (EPS) industry.
Transparency register no.: 665271342003-79
• EUMEPS is the association and voice of European Manufacturers of Expanded Polystyrene. Our members
cover the entire EPS value chain from raw material suppliers to EPS converters and recyclers as well as
supporting industries including machinery and additive suppliers. Members include individual companies
as well as 22 European national EPS associations. This unique representation of the entire value chain
ensures that EUMEPS represents both large companies and small- and medium-sized converters and
recyclers. Altogether our membership represents more than 1,000 companies, most of them small- and
medium-sized enterprises (SMEs), and employs more than 80,000 people.
Transparency register no.: 02100645398-66
• PlasticsEurope is the pan-European association of plastics manufacturers with offices across Europe. For
over 100 years, science and innovation has been the DNA that cuts across our industry. With close to 100
members producing over 90% of all polymers across Europe, we are the catalyst for the industry with a
responsibility to openly engage with stakeholders and deliver solutions which are safe, circular and
sustainable. We are committed to implementing long-lasting positive change.
Transparency Register no: 454264611835-56
• European Plastics Converters (EuPC) is the leading EU-level trade association, based in Brussels,
representing European plastics converting companies. Plastics converters use plastics raw materials and
recycled polymers to manufacture new products. EuPC totals about 45 national as well as European
plastics converting industry associations and represents more than 50,000 companies, producing over 50
million tons of plastic products every year. The European plastics industry makes a significant contribution
to the welfare in Europe by enabling innovation, creating quality of life to citizens and facilitating resource
efficiency and climate protection. More than 1.6 million people are working in EU converting companies
(mainly SMEs) to create a turnover in excess of € 260 billion per year.
Transparency Register no: 93255296152-29
• Sven Heppes, Spokesman, Smart Packaging Europe - firstname.lastname@example.org
• Flavia Ferri, Operations Coordinator, EUMEPS - email@example.com
• Christian Block, Director Styrenics, PlasticsEurope - firstname.lastname@example.org
• Felix Miessen, Communication Manager, EuPC - email@example.com