FAQ - Plastic pellets

This page provides information about the transport of plastic pellets by sea.

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Plastic pellets (also known as nurdles) are small plastic granules that are widely used as a raw material in the creation of plastic products.

When plastic pellets are released into the marine environment, they can cause environmental damage, including impacts on fishing, aquaculture and tourism.

To address this issue from the perspective of maritime transport, IMO is working on provisions on how freight containers used to transport plastic pellets should be declared to ship operators and stowed on ships, and on how plastic pellets should be packaged for maritime transport. Work on developing guidance for responding to marine incidents involving plastic pellets is also underway.

This work is linked to IMO's action plan to address marine plastic litter from ships.

What are plastic pellets/nurdles?

Pellets are defined as a set of "small pre-formed masses of moulding material, having relatively uniform dimensions in a given batch, used as raw material in moulding and extrusion operations" by the ISO (International Organization for Standardization) in ISO 472:2013.

The term "plastic pellets" refers to small granules (also known as nurdles, pre-production plastics) used as the base material to create other plastic products.

Currently, IMO Members States are considering the most appropriate definition for use in IMO instruments, in order to provide clarity as to which products fall within the scope of any IMO provisions.

Relevant discussions will take place during the 11th meeting of IMO's Sub-Committee on Pollution Prevention and Response (PPR 11) in February 2024.

Why are plastic pellets an issue?

If plastic pellets are released and dispersed into the marine environment, they can harm living resources and marine life and can interfere with other legitimate uses of the sea, such as fishing and aquaculture. Additionally, the pellets can be washed up on beaches and coastlines and, as a result, negatively impact tourism and shore-based activities.  

What has IMO done to regulate the transport of plastic pellets?

IMO began addressing the issue of the transport of plastic pellets following the X-Press Pearl incident off the coast of Sri Lanka in February 2021. Following a fire onboard and subsequent sinking of the ship, pellets were released into the marine environment and several tonnes of pellets washed ashore.

In March 2024, the Marine Environment Protection Committee (MEPC 81) approved MEPC.1/Circ.909 Recommendations for the carriage of plastic pellets by sea in freight containers.

The recommendations include the following actions: 

  • Plastic pellets should be packed in good quality packaging which should be strong enough to withstand the shocks and loadings normally encountered during transport. Packaging should be constructed and closed to prevent any loss of contents which may be caused under normal conditions of transport, by vibration or acceleration forces.  

  • Transport information should clearly identify those freight containers containing plastic pellets. The shipper should supplement the cargo information with a special stowage request for proper stowage. 

  • Freight containers containing plastic pellets should be properly stowed and secured to minimize the hazards to the marine environment without impairing the safety of the ship and persons on board. Specifically, they should be stowed under deck wherever reasonably practicable, or inboard in sheltered areas of exposed decks. 

How should plastic pellets be cleaned-up after a spill?

IMO Members States are currently working on draft Guidelines on the clean-up of plastic pellets from ship-source spills.

The draft guidelines on clean-up of plastic pellets from ship-source spills provide practical guidance for government authorities to ensure clean up actions are appropriate and effective. The guidelines cover contingency planning, response, post-spill monitoring and analysis, and intervention and cost recovery. 

The draft guidelines were discussed during 11th session of PPR (PPR 11) in February 2024 and will be submitted to the 82nd session of MEPC (MEPC 82) in October 2024 following an editorial review by the Secretariat. In the meantime, Member States were invited to apply the guidelines early, if needed.

Read the draft Guidelines here. (This is a working document and not a final text)

Who is liable for clean-up costs if pellets are washed ashore?

The liability for the clean-up costs in the event of a release of plastic pellets into the marine environment and/or are washed ashore depends on the incident and on any relevant treaty to which the coastal State and/or flag State is party, in addition to any applicable national law.

There are several IMO treaties relevant to this, including:

The Convention defines "Wreck", following upon a maritime casualty, as:

(a) a sunken or stranded ship; or

(b) any part of a sunken or stranded ship, including any object that is or has been on board such a ship; or

(c) any object that is lost at sea from a ship and that is stranded, sunken or adrift at sea; or

(d) a ship that is about, or may reasonably be expected, to sink or to strand, where effective measures to assist the ship or any property in danger are not already being taken.

The articles of the WRC cover liability of the owner for the costs of locating, marking and removing hazardous ships and wrecks - the registered shipowner is required to maintain compulsory insurance or other financial security to cover liability under the convention (not exceeding an amount calculated in accordance with article 6(1)(b) of the Convention on Limitation of Liability for Maritime Claims, 1976, as amended – refer hereunder).

Limits of liability are specified for many  types of claims – such as claims for loss of life or personal injury, property claims (such as damage to other ships, property or harbour works), claims in respect of the raising, removal, destruction or the rendering harmless of a ship which is sunk, wrecked, stranded or abandoned, including anything that is or has been on board such ship, and claims in respect of the removal, destruction or the rendering harmless of the cargo of the ship.

Ship insurance

Generally speaking, ships must carry insurance under the Nairobi International Convention on the Removal of Wrecks (WRC), 2007, usually through a P&I Club.

The International Group of Protection and Indemnity Associations (P & I Clubs) has consultative status with IMO.

What is IMO doing to tackle container losses?

IMO has long been working to ensure the safe transport of containers, including through guidelines on container stowage; mandatory SOLAS requirements to provide the verified gross mass of a container before it can be loaded on a ship; and mandatory reporting of loss of any containers, i.e. not only containers used to transport dangerous goods (amendments to SOLAS and MARPOL Conventions to be adopted in 2024).

The work will continue through a new output on the "Development of measures to prevent the loss of containers at seaʺ, which was approved by MSC 107 and is being coordinated by the CCC Sub-Committee. It is anticipated that all matters relating to loss of containers will be discussed under that output in a holistic manner, with a view to developing further relevant provisions.

Please find more information about safe transport of containers here.

Container loss statistics

The World Shipping Council (WSC) estimates that in 2022, 661 containers were lost at sea, out of 250 million transported.

What is IMO doing to tackle plastic pollution from sea-based sources?

IMO's long history of responding to pollution of the marine environment from ships spans more than five decades, through the development of guidance and regulations.

The International Convention for the Prevention of Pollution from Ships (MARPOL) is the main international convention covering prevention of pollution of the marine environment by ships from operational or accidental causes. The Convention includes several annexes which cover regulations for the prevention of pollution by oil; noxious liquid substances in bulk; harmful substances carried by sea in packaged form; sewage from ships; garbage from ships (including marine litter); and air pollution from ships.

IMO's work on marine plastic litter

The regulations in MARPOL Annex V and the London Convention/Protocol prohibit the discharge and dumping of plastics from ships, respectively.

Notwithstanding the above, the MEPC adopted an Action Plan to Address Marine Plastic Litter from Ships (resolution MEPC.310(73)) in 2018 to contribute to the global solution for preventing marine plastic litter from entering the oceans through ship-based activities.

This was followed by the adoption in 2021 of the Strategy to address marine plastic litter from ships (resolution MEPC.341(77)), which includes, inter alia, a prioritization of the actions in the Action Plan into short-term, mid-term and long-term measures, as well as an associated timeline.

Since the adoption of the Action Plan, several work streams have been initiated and are ongoing (or have been completed).

These include for example: the development of draft amendments to MARPOL Annex V to enhance the reporting of lost fishing gear and to make the marking of fishing gear mandatory (in cooperation with FAO); consideration of how the risk of containers packed with plastic pellets being lost overboard can be reduced; the development of draft amendments to SOLAS to improve the reporting of incidents involving containers lost overboard, the development of amendments to STCW and STCW-F to improve environmental awareness of crews; and the establishment of the GloLitter Partnerships project.

Please find more information on marine plastic litter here.