European Commission, Brussels
Study of the largest loopholes within the flow of packaging material
REFERENCE: ENV.D.2/ETU/2011/0043
Annex 8 to the Final Report:
Specific information on EPS fish boxes
15 January 2013
BiPRO Beratungsgesellschaft für integrierte Problemlösungen
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European Commission Annex to the Final Report: Specific information on EPS fish boxes Study of the largest loopholes within the flow of packaging material
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CLIENT European Commission Directorate-General Environment Unit D2 – Marine Environment and Water Industry Avenue de Beaulieu 29, BU29 - 02/78 1049 Brussels Belgium
PROJECT Study of the largest loopholes within the flow of packaging material ENV.D.2/ETU/2011/0043
CONSULTANT BiPRO GmbH Grauertstrasse 12 81545 Munich Germany
CONTACT BiPRO GmbH
Telephone +49-89-18979050
Telefax +49-89-18979052
E-mail [email protected]
Website http://www.bipro.de
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Content
1 Introduction ..................................................................................................................................... 4
2 The EPS fish box cycles ..................................................................................................................... 5
2.1 Production ............................................................................................................................................... 5
2.2 Use and service life ................................................................................................................................. 5
2.3 Waste management ............................................................................................................................... 7
3 Weaknesses and loopholes and possible measures to improve the situation ................................. 12
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1 Introduction
The analyses of the occurrence of marine litter (see chapter 4 of the final report) and the analysis of
plastic cycles and loopholes demonstrates that most relevant plastic present in marine litter originating
from plastic packaging are bags and bottles (see chapter 4 of the final report). Specific contribution to
marine litter is related to the use of EPS fish boxes. However, their quantitative contribution is limited.
EPS fish boxes are considered relevant in the context of the present project due to the following reasons:
The 3R-Fish Project has identified EPS fish boxes as one of the three major waste types generated
during fishing and port operations (see [3RFish 2011b]).
The preliminary results of one of the Marine litter projects indicate that EPS fish boxes form a
relevant input to marine litter.
Litter from EPS fish boxes is found in marine litter, particularly in port waters. For example during
cleaning operations in December 2011 in the Port of Barcelona EPS fish boxes were collected
from port waters (total litter: 295kg, weight of EPS material: 4kg, identified number of EPS boxes:
3, weight of wooden boxes: 19,9kg, identified number of wooden boxes: 19; personal
communication, port authority of Barcelona, 2011).
EPS, as other plastics, does not readily biodegrade or disintegrate. Mechanical friction and impacts cause
the material to fall apart into smaller and smaller fractions, making it difficult to remove the material
from marine waters and related to possible adverse impacts. EPS pieces can be mistaken for food by the
marine fauna. The 3R-Fish project states e.g. findings of a study where tortoises lost their ability to dive
after having swallowed those pieces, eventually starving to death. EPS can also be a carrier for invasive
species (see [3RFish 2009].
The plastic packaging cycles for bags and bottles are analysed and documented within the country
specific investigations (see Annex “Country Summaries).
The present document has the purpose to provide relevant information on the cycles of EPS fish boxes.
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2 The EPS fish box cycles
2.1 Production
According to [Plastics 2011] the demand for EPS in the PPP amounted to 0.35 Mt. This equals to
approximately 1.9 % of total plastic demand of plastic for PPP (18.1 Mt).
EPS used for fish boxes is only one out of several uses within plastic packaging. Within the sector of
plastic packaging EPS is used for several different uses (typical uses from [EUMEPS 2009]) such as
industrial protective packaging (consumer electronics, appliances)
food packaging (fish, meat, vegetables, meals)
insulated food containers (cups, trays)
Hence significant quantities of EPS are used for other packaging purposes than for EPS fish boxes and it
can be concluded that the quantity of EPS used for fish boxes is only a certain share of 0.35 Mt/year.
Information on the specific exact share of EPS used for fish boxes has not been obtained.
To conclude, the demand for EPS for the production on fish boxes is significantly below 0.35 Mt/year or in
other words significantly below 1.9 % of the total plastic demand for plastic packaging products.
It should be noted that EPS in marine litter originates not only from packaging (EU demand in 2009: ~
0.32 Mt) but also from construction (EU demand in 2009 ~ 1.2 Mt). Particularly the use of EPS in
construction is expected to increase significantly due to higher requirements for thermal insulation in
construction and it should therefore be considered to take appropriate measures to prevent EPS
construction waste from entering the marine environment (e.g. deconstruction management plans for
buildings at the end of their lifetime; implementation primarily for buildings close to the coast).
2.2 Use and service life
EPS has several properties which make it a useful raw material in a number of packaging functions.
Among other its main applications for packaging are (see http://www.eumeps-packaging.eu/):
Transportation and cooling of temperature sensible food products like: fish products, vegetables
and fruits
Packaging of temperature and shock sensible medication in uncontrolled cooling chains
Packaging of shock and vibration sensitive electronic devices
Packaging of heavy packaged goods
Relevant physical properties of EPS making it appropriate for the use as fish boxes are the following (see
[3RFish 2009]):
High shock absorption, therefore highly demanded in transport and logistics
EPS is light weighted, therefore saves fuel and cheapens transportation
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Thermal insulation qualities, as EPS consists to 98% of air, which is enclosed in the material and 2
% polystyrene
Chemically inert (does not react with leaches, salt solutions/salt water, diluted acids)
Biologically inert, as EPS has no nutritive value for microorganisms. Although it can be a carrier of
microorganisms in case of pollution with organic material which hinders possible re-use.
Several contacts with experts (from the 3R-Fish Project, fish processing and whole sale associations, the
port of Barcelona, and fishery and aquaculture companies) confirm that EPS fish boxes are rarely handled
in direct connection with fishery on vessels, trawlers etc. In deep see fishery they are not used at all.
Other fishing vessels usually use HDPE boxes or similar containers. According to personal communication
with the Port of Barcelona and the German Association of the Fishing Industry and Whole Sale, fishing
vessels usually use wooden or hard plastic boxes (PP, HDPE etc.). It might be that EPS boxes are still used,
where smaller boats or vessels are involved. Generally, waste EPS fish boxes from fishing vessels can
therefore be considered of comparatively low relevance.
This is in line with the general finding that “...only an estimated 12% of the waste generated in ports
originates in fishing activities, with the remaining 88% generated by land based inputs (handling activities,
commercialisation processes, transportation, etc)” [3RFish 2011].
Consequently waste EPS fish boxes arise particularly at input and output stations of fish distribution,
processing, commercialisation and consumption activities (e.g. landing of fish, preparing for processing,
whole sale, retail and fish markets, consumption at home or in restaurants).
In distribution and processing of fish, EPS fish boxes are particularly used for transportation of fresh fish
or processed fresh fish parts (e.g. fish filet) in uncontrolled cooling chains, where the high insulative
properties are needed (see [Anyadiegwu 2002]). Transportation includes airfreight and private transport
from consumers.
Due to hygienic reasons EPS fish boxes are non-reusable thus their service life tends to be very short.
Therefore, wherever fish is transported/stored in fish boxes and is afterwards unpacked, processed
and/or distributed, waste EPS fish boxes are generated.
Accordingly, waste EPS boxes can arise after landing of the fish and during the following transport,
handling and/or fish processing activities. Such activities (e.g. handling, preparing for processing,
preparing for transport, sale at local markets) are carried out at ports or close to the coast and resulting
and not properly managed waste has a high potential to become marine litter. Accordingly, significant
quantities of EPS arise at ports (see e.g. [3RFish 2009] and [3RFish 2011]).
A key to preventing EPS waste from fish boxes entering the marine environment is therefore to achieve a
high collection rate particularly at ports, local fish markets and from wholesale/retail and to ensure
proper management of the collected EPS waste (recycling, energy recovery or, as least favourable option,
appropriate landfilling).
At locations where significant quantities of waste EPS boxes arise they could easily enter a recovery and
recycling scheme. Such locations are e.g. fishing ports and markets. As soon as the fish boxes enter
smaller schemes like small scale retail, gastronomy or private consumption, the boxes are most likely to
end up in municipal solid waste.
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Figure 1 gives an overview on the most relevant pathways during the service life of EPS fish boxes. It is
expected that most relevant quantities of waste EPS boxes arise at ports, local markets and
wholesale/retail.
Figure 1: Overview on the most relevant pathways during the service life of EPS fish boxes
2.3 Waste management
Due to hygienic reasons EPS fish boxes are non-reusable. They are one-way products. According to the
waste hierarchy they should be managed with the following priority:
1. prevention (particularly use of alternatives)
2. recycling (as re-use is not possible)
3. incineration with energy recovery
4. disposal (least preferred option)
(a) incineration without energy recovery (preferable from a marine litter perspective), or
(b) landfilling (in line with the technical requirements of the landfill directive)
Because of hygienic reasons the boxes are non-reusable and their service life is short. Therefore,
wherever fish is unpacked, processed and/or distributed EPS waste is generated. EPS fish boxes are
sometimes transported down to the private consumer. Hence several stakeholders (ports, markets,
wholesale/retail, consumers) are involved at the end of life of EPS fish boxes.
Figure 2 illustrates the pathways and quantities of EPS used for packaging and the corresponding waste
treatment (based on data from the PS foam industry; reference year 2009; note: the data concern all
types of EPS packaging. Specific figures for EPS fish boxes are not available).
Aquaculture/ Fishing Operations
Local markets
Consumption (private, gastronomy)
Wholesale/Retail
Imp
ort
/ Ex
po
rt
Fish Processing Industry
Was
te S
tre
am Port operations
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Figure 2: EPS Material Flow for Packaging – Virgin Resin to End of Life for the year 2009 for EU 27+Norway and Switzerland (based on data from PS Foam industry; personal communication with PS Foam Industry)
Prevention
Prevention of EPS waste from fish boxes could be achieved by using alternatives to EPS boxes for the
transport/storage of fish. Common alternatives are boxes made from wood, cardboard or other plastics.
Seafish (the Sea Fish Industry Authority, UK) has tested several non-reusable fish boxes, including double
walled fibreboard boxes and single walled fibreboard boxes from CRT Packaging and a CP fish box model
by Tri-pack Plastics. The study focused on the thermal performance of these boxes and has consequently
stated that while EPS has always performed best in all testing conditions, all types of boxes “performed
satisfactorily in holding low fish temperature close to 0°C.”. The conclusion drawn states that depending
whether the distributors deal with controlled or uncontrolled cooling chains it might be feasible to use
alternatives (controlled) or EPS boxes (uncontrolled). (see [Anyadiegwu 2002]).
Though EPS has relevant alternatives in regard to thermal performance, several Life Cycle Assessments
have shown that EPS achieves better results than other plastic or cardboard alternatives regarding
environmental impacts such as primary energy and water consumption, emissions to air, ozone layer
depletion, transport, water eutrophication and waste production by weight (see [Anyadiegwu 2002],
[EUMEPS 2002], [EUMEPS 2012]. It should be noted that LCAs usually don’t particularly consider the
aspect of marine plastic litter.
According to the Packaging Directive the EPS packaging industry is already obliged to prevent packaging
during manufacturing (particularly according to Annex II (1) of Directive 94/62/EC related to
Requirements specific to the manufacturing and composition of packaging: “Packaging shall be so
manufactured that the packaging volume and weight be limited to the minimum adequate amount to
maintain the necessary level of safety, hygiene and acceptance for the packed product and for the
consumer...”).
Recycling
According to the polystyrene industry, EPS is easily recycled and is one of the most recycled plastics. Since
EPS does not degrade or deteriorate, it can be readily recycled in several ways at the end of its lifetime. It
can be added back into new polystyrene foam insulation boards or moulded into new applications such
as plant pots, coat hangers, park benches or fence posts. Since EPS and XPS are made from oil, the stored
energy can be recovered in modern incinerators and then used for local heating and for generation of
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electricity. Some EPS can be recycled and used for the manufacture of bricks where the polystyrene is
gasified and leaves a cavity in the centre of the brick. It can also be remelted to new granulate to reduce
the volumes of raw material, which would be beneficial for new EPS production of end products [CPAN
2010].
Specific information on the recycling of EPS fish boxes is available from the 3R-Fish project: Although EPS
has not been traditionally seen as a high-target recycling material, innovative solutions are currently
being implemented, with the sector growing fast in terms of capacity and technological innovation
[3RFish 2011]. Within a white book on new opportunities for fishing and port-generated waste 3 types of
recycling for EPS fish boxes are identified (for details see [3RFish 2011]):
Processing of waste expanded polystyrene (EPS) floats into polystyrene ingots
Processing of waste expanded polystyrene (EPS) products into polystyrene pellets using limonene
(monomerisation)
Reuse of EPS through material recycling and chemical recycling 1
However, the recycling of EPS and particularly of EPS from fish boxes is related to specific limitations.
Odour (limited material recycling; if material is recycled it is usually used in the construction
sector)
High volume (difficulties in storing and transport)
Fish boxes come in contact with organic material. Recycling is therefore restricted due to the smell of its
organic residues after use as fish box. As a consequence material recycling of EPS waste from fish boxes is
usually only for construction materials (e.g. EPS insulation boards). The bulk of EPS waste from fish boxes
is landfilled or incinerated. However, specific quantitative data only for fish boxes are not available.
A general limitation for the handling of EPS waste is due to its low density and its related high volume.
These properties make the waste handling and transport inefficient (large storage containers required;
high transport costs). The density and volume of EPS waste can be improved by compaction in order to
save costs and energy. Compaction processes can be performed by using heating systems (i.e. thermal
densification) or non-heat based methods (i.e. cold compaction) (for details see [3RFish 2011] and
[Seafish 2006]). Compaction rates are up to 95% volume reduction by thermal densification and about
40% by cold compaction (see [Seafish 2006]).
EPS Fish boxes have a long “recycling” tradition. In Europe there are several companies dedicated to the
specific tasks of EPS Fish Boxes management and recycling. Some companies perform all the tasks related
to the recycling chain, from the collection, cleaning, compaction, recycling and valorization (see [3RFish
2011] and [Seafish 2006]). In some countries there may be a lack of recycling facilities. Corresponding
infrastructure could be established or collected EPS waste could be exported for recycling or it could be
incinerated (all options are in line with the objective to avoid marine litter).
1 The white book list here also „thermal recycling“. Thermal recycling is not “material recycling” and considered below as
“incineration with energy recovery”.
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However, expanded polystyrene collected at the ports usually end up on landfills or are incinerated. Only
those ports featuring nearby EPS packaging factories had established collection schemes, since this
material’s low density accounts for very high transportation costs. [3RFish 2011b]).
In the 3R-Fish project a management scheme for EPS was put in practice in 4 Spanish and 2 Portuguese
ports. Collection schemes were put in practice, according to the conditions of each port, adapted to the
operations and the companies in charge (for details see [3RFish 2011b]).
Polystyrene was usually collected in containers or cages, set near fish markets and retailing companies, so
the waste generators had an easy access to these points. In certain cases, the packaging was previously
cleaned (eliminating all labels, fish rests and other dirt) to be then compacted in bales or blocks. The
bales were easy to stack and they enhanced significantly the transport efficiency. [3RFish 2011b]
Polystyrene recovered as part of this pilot action was used to produce several materials for the
construction industry and civil works, by different recycling companies. EPS (compacted or not) was
ground on arriving to the plant, and later used to produce such materials. Recycling is technically viable,
but not common, as the features of EPS collected at ports (its odour and the possible presence of fish
rests) restrict the possible end uses. When recycled, it is ground and then stored on silos. From the silos,
it is taken to feed extrusion systems, without being previously washed. After being extruded, the
resulting polystyrene is cut and sifted to produce chippings. [3RFish 2011b]
Within the 3R-Fish project, the recycling process was validated and it was concluded that it is possible to
recycle compacted or ground EPS from fish boxes to polystyrene (to make new products or materials) and
to produce construction materials (see [3RFish 2011b]).
Limitations are e.g. the following (see [3RFish 2011b]):
low waste volumes according to geographic circumstances
mixing of different waste materials
need for resources to implement the recycling scheme (areas to collect, separate, clean waste;
infrastructure for compaction, human resources)
low margin of profit
too few EPS managing companies
additional handling costs
On the other hand the following advantage is stated: “...no large investments are required to obtain
benefits, both economical and environmental. It’s interesting, as on the one hand, waste will not be
destined to the landfill but recovered; and on the other hand, waste management operational costs
would sink.”
EPS Packaging Material
Grinding
Compacting
Pre-cleaning Transport
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It is considered that the management model for recycling EPS fish boxes proposed in the 3R-Fish project
is transferable to other ports. The following is stated: Prior to transferring the management model to
other ports, the situation must be assessed, to identify possible associations and cooperation that may be
established with nearby ports, concessionaires or waste managers. The larger the waste volume is
guaranteed and the more stable the links among all the parties are (ports, concessionaires, transport
companies and end users), the more viable the management model will be. Awareness-raising actions
need to be taken in order to achieve the goals set by the models’ implementation. (see [3RFish 2011b]).
Incineration
According to the waste hierarchy incineration of EPS fish boxes is less favourable than recycling. From a
marine litter perspective incineration is equally favourable. Incinerated fish boxes cannot enter the
marine environment and the EPS is thermally recycled (incineration with energy recovery).
Incineration of EPS according to the requirements of Directive 2000/76/EC on the incineration of waste is
not related to relevant releases of pollutants.
Disposal
It is considered that incineration without energy recovery is not occurring for relevant quantities.
According to the waste hierarchy landfilling is considered the least favourable option for EPS fish boxes.
In several countries it is prohibited to landfill combustible waste such as EPS due to its calorific value. Also
from a marine litter perspective, landfilling is the least favourable waste management option because
landfilling is related to the risk that the EPS will escape from landfill during transport and/or landfilling
activities or in the future.
If EPS is landfilled it is essential, that the requirements of the landfill directive are fulfilled.
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3 Weaknesses and loopholes and possible measures to improve the
situation
The largest loopholes in the flow of EPS fish boxes with particularly high risk to contribute to marine litter
are at ports and local fish markets close to the coast. Less relevant are loopholes in the ensuing
distribution and commercialisation chain. Loopholes are particularly related to insufficient awareness
concerning the disposal of EPS fish boxes, insufficient infrastructure for their collection and recycling and
insufficient cooperation between ports and other actors which would enable to establish economically
viable recycling systems.
Insufficient awareness
Investigations and discussions with different fish processing, fishing and aquaculture institutions in DE, GR
and EE have shown that these usually have internal collection, sometimes also recycling systems in place.
In the 3R-Fish project collection and recycling systems have been successfully established in ports and it is
considered that such systems are transferable to other ports.
However, often direct handlers of EPS fish boxes in ports, on local fish markets and in the gastronomy
sector are insufficiently aware of how to dispose the boxes or the infrastructure for intermediate storage
and recovery is not available. EPS is a high volume material, which requires up a lot of space. E.g.
restaurants or small retailers situated in the vicinity of ports or close to the coast might not have enough
space for temporary waste storage. The boxes are stored outside and can from there directly or indirectly
reach marine waters. The same can apply for local fish markets and may also be relevant for small fish
vessels where EPS fish boxes may still be used due to insufficient cooling conditions.
Reasons for the low awareness are particularly
Specific infrastructure for EPS fish boxes does not exist and there is consequently no information
available on how to deal with EPS waste.
Lack of information activities by ports, market administration, municipalities. People handling
EPS boxes are often not aware that EPS is a valuable material
Possible measures:
Deposit refund systems (in order to allocate a value on waste; would also reach fishermen from
small vessels and small scale consumers such as restaurants and households)
Awareness raising measures by ports, market administration, municipalities (clearly visible
information, brochures, leaflets, ...)
Promote the use of alternative, re-usable boxes where appropriate
Measures should particularly focus on locations close to the coast in order to achieve a high impact on
marine litter.
Insufficient infrastructure for collection and recycling
Currently, expanded polystyrene collected at the ports usually end up on landfills or are incinerated. Only
those ports featuring nearby EPS packaging factories had established collection schemes, since this
material’s low density accounts for very high transportation costs [3RFish 2011b]).
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EPS recycling requires infrastructure in the form of collection points, space for cleaning and intermediate
storage, compaction equipment, transport and companies which recycle EPS.
The first infrastructure requirement is to establish collection points and facilities for storage and cleaning.
This requires particularly space (and human resources).
Additional useful infrastructure is compaction equipment. For a quantity of 25 tonnes of EPS per year, the
payback period for a compacting machine costing around €25,000 can be as short as two years, if the
compacted EPS is sold to a recycling company for about €62 per tonne and the costs of disposal to landfill
are saved (according to [Seafish 2006]). The quantities of EPS annually collected in 16 Galician ports is
documented in [3RFish 2009]. In 50% of the ports the quantities range between 40 and 4,271
tonnes/year and it can be assumed that the payback period for a compacting machine would usually be
below 2 years in these ports.
The price that recyclers paid in 2006 in the UK ranged from around €62 to 99€ per tonne but is very much
market dependent as it is linked to world oil prices. It also varies according to location, cleanliness, level
of compaction and current market situation. Contaminants such as seafood waste, oils, excess moisture,
ice, malodours and the presence of paper labels can create problems for recycling and reduce the prices
paid (see [Seafish 2006]). Cleaning requires infrastructure and human resources, however it can improve
the overall rentability of a recycling scheme (higher process for EPS waste; less waste to be landfilled)
Compacting equipment can also be rented from recycling companies.
An appropriate EPS recycling management model requires no large investments to obtain benefits, both
economical and environmental, as on the one hand, waste will not be destined to landfill (or the marine
environment) but recovered; and on the other hand, waste management operational costs would sink
(see 3RFish 2011b]).
The compacted EPS needs to be transported to a recycling plant. There are several EPS recycling plants
established, however, sometimes the transport distance to such a plant is rather long and can
significantly reduce the margin of profit.
One initiative to increase the infrastructure for the recycling of EPS fish boxes is STYREF which is the short
term for “Styropor-Recycling Europäischer Fischkisten” (EPS recycling of European fish boxes). STYREF
was founded in 1993 by a part of European Fish box producers and aims to close the cycle of EPS boxes.
For this purpose boxes produced by the members of STYREF® are labelled. Fish wholesalers using STYREF
boxes can obtain an EPS compacting machine (type SVM-150 enabling 90% volume reduction; in Germany
there are currently about 90 machines of this type in operation) and can give EPS back for free to the
producer. Thus labelled boxes are collected separately, compacted and are re-delivered to the
manufacturer for recycling. STYREF Members are located in Germany, Denmark the Netherlands and
Norway. The system is financed by the membership fees. The fee depends from the quantity of EPS boxes
a member places on the market.
Reasons for the lack of infrastructure are particularly
Insufficient cooperation between ports, fish markets, wholesale, retail, municipalities and
recycling companies to channel the EPS waste flow place (without cooperation EPS waste
quantities are too little to justify the establishment of infrastructure)
Insufficient awareness of the problem and EPS recycling possibilities
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Lacking obligation to consider EPS waste management in existing planning instruments (port or
municipal waste management plans)
Possible Measures:
Support the establishment of appropriate infrastructure (specific bins at vessels, collection and
storage places at ports/markets, compaction equipment) via awareness raising (e.g. by means of
information, events, dissemination of relevant information such as on disposal possibilities of
polystyrene boxes (example: [Seafish 2006]) and increasing cooperation between involved actors
and obliging ports and municipalities to consider waste EPS fish boxes in their waste management
procedures (e.g. via waste management plans for ports2 and municipalities).
Measures should particularly focus on locations where large quantities of EPS boxes arise close to the
coast: ports and integrated or close by fish markets (in order to cover the low hanging fruits: large
quantities of EPS enable profitable EPS recycling schemes).
Insufficient cooperation between actors
EPS recycling has a low margin of profit. There are only a few companies managing EPS waste [3RFish
2011b]. Profitable recycling of EPS boxes requires a long term stable availability of sufficient quantities of
EPS waste. In order to ensure such availability, ports, fish markets but also other companies where EPS
waste arises and municipalities and recycling companies could co-operate in order to establish a
sustainable EPS recycling or disposal schemes covering the whole value chain from collection, cleaning
activities, intermediate storage, compaction, transport, (material or thermal) recycling or appropriate
disposal.
The quantities of EPS annually collected in 16 Galician ports is documented in [3RFish 2009]. In 50% of the
ports the quantities range between 40 and 4,271 tonnes/year. In 50% of the ports, the quantities range
between <1 and 24 tonnes per year. These small ports would certainly benefit from participating in a
coordinated EPS recycling scheme.
Cooperation between ports, markets and other relevant actors could ensure long term stable supply of
waste EPS fish boxes to enable profitable recycling. However, currently such cooperation is limited to
some extraordinary examples (see e.g. [3RFish 2011]). This is probably due to the low awareness
regarding on the one hand the problem of marine litter and on the other hand the possibility to establish
economically sustainable EPS fish box recycling schemes (such as proposed and demonstrated viable and
transferable in the 3R-Fish project [3RFish 2011b]).
Possible measures:
Promote the cooperation for EPS waste management between actors and the identification of
synergies between them (e.g. by means of information, events, dissemination of relevant
information such as the results of the 3R Fish Project). Possible synergies are particularly relevant
with respect to compaction equipment, transport logistics, contracts with recycling companies,
etc.
2 Port facilities are obliged to establish a management plan written in accordance with the guidelines set in the international and
national legislation. These management plans that already include procedures for collecting, storing, processing and disposing waste and specific regulations on the use of equipment on board could be updated with specific provision for the management of EPS packaging (see [3RFish 2011]).
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Oblige ports and municipalities to consider cooperation for EPS waste management within their
region (e.g. in port or municipal waste management plans or in port operation permits)