On 22 February 2026, during Fish International in Bremen, a dedicated session examined the impact of new EU legislation on the seafood sector. The discussion focused in particular on the Packaging and Packaging Waste Regulation (PPWR) and its practical implications for operators across the value chain.
Lea Salihovic, EU Policy Manager at EUMEPS, participated in the panel discussion, contributing the perspective of the EPS industry on recyclability requirements, reuse systems and implementation challenges.
Recyclability Under the PPWR: Current Performance and Ongoing Action
During the exchange, Lea Salihovic underlined that the EPS industry supports the objectives of the PPWR, particularly the ambition to improve recyclability and strengthen circular economy performance.
She highlighted that EPS transport packaging, including fish boxes, is already recycled at scale in several Member States. On average, around 40% of European post-consumer EPS packaging is recycled. In structured collection systems, recycling rates exceed 50%, and in Norway they approach 80%. EPS transport packaging has also been recognised by the United Nations Environment Programme as recycled “in practice and at scale”.
Lea explained that performance depends largely on the existence of structured collection systems. Where such systems are in place, EPS demonstrates efficient and resource-efficient circularity. The common challenge is to scale these systems consistently across all Member States.
She also outlined ongoing industry initiatives, including:
- Expansion of industrial recycling capacity
- Installation of compaction units in ports and fish markets to improve collection efficiency
- CEN standardisation work aligned with PPWR recyclability criteria
- Cooperation with recyclers to strengthen traceability and quality of secondary raw materials
The objective, she stressed, is to move from theoretical recyclability to verifiable and documented circular performance.
Reuse of Fresh Fish Boxes: A System-Level Consideration
A key part of the discussion addressed the feasibility of reuse systems for fresh fish transport packaging.
The feasibility of reuse is not an EPS-specific problem — it is a systemic challenge. Fresh fish supply chains are among the most demanding logistics systems in Europe. EPS manufacturers can technically produce stronger boxes. Structural reinforcement is not the limiting factor. The difficulty lies in food safety and hygiene compliance. EPS fish boxes are not simple transport packaging. Their primary function is insulation — maintaining freshness, temperature stability and compliance with strict hygiene rules for highly perishable goods.
Lea emphasised that EUMEPS supports reuse where it demonstrably delivers environmental benefits. However, in the case of fresh fish logistics, the feasibility question is not material-specific. It concerns the complexity of the entire system.
Fresh fish supply chains are among the most demanding logistics systems in Europe. EPS fish boxes provide insulation that ensures temperature stability, freshness and compliance with strict hygiene rules for highly perishable goods.
She recalled that under Regulation (EC) No 852/2004 and Regulation (EC) No 1935/2004, operators must guarantee validated cleaning procedures, full traceability, uniform hygiene standards and clear liability allocation.
In cross-border supply chains with multiple handling points, unpredictable return flows and exposure to organic contamination, ensuring absolute reliability after repeated reuse cycles can be particularly challenging.
EPS has become the standard solution for perishable fish packaging because it consistently meets functional, hygiene and energy-saving requirements.
Lea concluded this part of the discussion with a balanced message: where reuse systems can function safely and efficiently, they should be encouraged. Where structural constraints limit feasibility, high-performance recyclable systems must remain a proportionate and sustainable option. Food safety, food waste prevention and circularity should be pursued together.
Ensuring Proportionate and Effective Implementation
Throughout the discussion, Lea stressed the importance of clarity and proportionality in implementing the PPWR.
She noted that the sector is investing in recycling infrastructure, increased integration of recycled content, improved collection logistics and standardised documentation to demonstrate recyclability and circular performance.
To ensure effective implementation, she called for:
- Clear definitions
- Proportionate timelines
- Recognition of application-specific realities
- Performance-based assessment rather than assumptions based solely on material
Conclusion
The session at Fish International reflected the strong interest of the seafood sector in understanding and preparing for the PPWR.
EUMEPS’ contribution underlined a shared objective: reducing environmental impact while safeguarding food safety, economic resilience and efficient logistics.
As implementation of the PPWR progresses, continued dialogue between policymakers and industry will remain essential to ensure that circular economy objectives are achieved in a way that is sustainable, practical and aligned with the realities of perishable food supply chains.