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Home › MARPOL Operations › IMO 2026 Strategy on Marine Plastic Litter and the Future Pellet Code
Regulatory update

IMO 2026 Strategy on Marine Plastic Litter and the Future Pellet Code

The MARPOL plastic-discharge prohibition is already in force. The 2030 strategy, voluntary pellet guidance and future code remain distinct.

marine plastic litterMEPC 84plastic pelletsMARPOL Annex III

Operational Explanation

The prohibition on discharging plastics at sea is already in force under Annex V/3.2, subject only to the limited regulation 7 exceptions. The IMO 2030 objective does not postpone this obligation. Distinguish ship-generated plastic waste, pellet cargo, incident reporting and the future code.

MEPC.417(84) adopts the 2026 strategy and action plan, updating and superseding the 2021 strategy and 2025 plan. They cover port reception facilities, training, implementation and cooperation. Development of the mandatory pellet code is a future step: the code is not yet adopted or in force.

The most concrete measure, and the most immediately relevant for the cargo trade, is the decision to develop a mandatory code for the maritime carriage of plastic pellets in containers, under MARPOL Annex III and/or the SOLAS Convention: the PPR (Pollution Prevention and Response) Sub-Committee has been tasked with drafting the code at its PPR 14 session, before reporting back to the MEPC. Plastic pellets lost at sea, often following container losses, are a recognized long-lasting marine pollution problem.

Recommendations for pellet carriage

Cargo-specific guidance sits alongside already mandatory prohibitions and reporting; it does not replace them.

The recommendations are set out in MEPC.1/Circ.909, dated 19 April 2024 and approved by MEPC 81. They provide an initial voluntary measure pending development of mandatory measures.

MEPC.1/Circ.909 recommends strong, good-quality packaging closed against leakage; shipper information identifying pellet containers and including a special stowage request, in addition to SOLAS VI/2 information; proper stowage/securing, below deck where practicable or inboard in sheltered areas of exposed decks, without compromising ship or personnel safety.

Since 1 January 2026, when containers are lost from the ship, the master reports without delay to nearby ships, the nearest coastal State and the flag State; the flag State informs IMO. SOLAS V/31–32 requires identity, date/time, position, known or estimated number, any dangerous goods and updates after verification. A ship sighting drifting containers reports to nearby ships and the nearest coastal State using the required sighting information; it is not treated as the ship that lost them. Follow shipboard procedures and V/32; a GRB entry alone does not replace reporting.

Regulatory Reference

Current obligations: Annex V/3.2, 7 and 10 (MEPC.201(62), updated thresholds in MEPC.360(79)); SOLAS V/31–32, MSC.550(108), and MARPOL Protocol I article V.3, MEPC.384(81). Strategy: MEPC.417(84). Guidance: MEPC.1/Circ.909, linked above.

Regulation (EU) 2025/2365, articles 1.2(d), 12 and 26, already sets 17 December 2028 for application of its containerized sea-transport branch in relation to EU ports. Do not confuse this date with the Regulation’s entry into force or the future IMO code. EU Regulation.

Preparation for 17 December 2028: article 12.2 requires the operator and master, and the agent where relevant, to hold a list, manifest or appropriate loading plan consistent with the shipper’s information. Article 1.2(d) covers vessels leaving or calling at a Member State port. Source: Regulation (EU) 2025/2365, articles 1, 12, 26.

Scope of Application

Annex V: waste management and the plastics prohibition within its scope; plan and GRB have their own thresholds. Pellet cargo does not automatically become garbage. Circ.909 concerns pellet carriage in containers; lost-container reporting already applies even when the pellets are not dangerous goods.

Procedure / How to Complete It

  1. The prohibition on discharging plastics at sea is already in force under Annex V/3.2, subject only to the limited regulation 7 exceptions. The IMO 2030 objective does not postpone this obligation. Distinguish ship-generated plastic waste, pellet cargo, incident reporting and the future code.
  2. Check plan, segregation and GRB where required. Document losses and exceptions with circumstances and precautions without treating them as operational options.
  3. MEPC.1/Circ.909 recommends strong, good-quality packaging closed against leakage; shipper information identifying pellet containers and including a special stowage request, in addition to SOLAS VI/2 information; proper stowage/securing, below deck where practicable or inboard in sheltered areas of exposed decks, without compromising ship or personnel safety.
  4. Since 1 January 2026, when containers are lost from the ship, the master reports without delay to nearby ships, the nearest coastal State and the flag State; the flag State informs IMO. SOLAS V/31–32 requires identity, date/time, position, known or estimated number, any dangerous goods and updates after verification. A ship sighting drifting containers reports to nearby ships and the nearest coastal State using the required sighting information; it is not treated as the ship that lost them. Follow shipboard procedures and V/32; a GRB entry alone does not replace reporting.
  5. Regulation (EU) 2025/2365, articles 1.2(d), 12 and 26, already sets 17 December 2028 for application of its containerized sea-transport branch in relation to EU ports. Do not confuse this date with the Regulation’s entry into force or the future IMO code.

Practical Example

Scenario: a container of non-dangerous pellets is lost in September 2026. The master immediately activates V/31–32 reporting and updates verified information; the ship does not wait for the pellet code or consider a garbage entry sufficient. Prevention also follows Circ.909 packaging, special stowage request and location recommendations.

What Typically Goes Wrong

The decision to develop a dedicated mandatory code for plastic pellets stems from growing evidence of the long-lasting environmental impact of these materials when lost at sea following a container loss: unlike other plastic waste, pellets disperse in enormous quantities from a single lost container and are difficult to recover, making prevention at source the most effective measure.

Common Mistakes Mistake Library

Avoid waiting until 2030 for the plastics prohibition, using the GRB as the only loss notification, always requiring below-deck stowage without the safe guidance alternative, or presenting the future code as in force or bringing the EU maritime branch forward to 2027.

What the PSCO Checks

Checks concern already applicable obligations, documents and actual management. The strategy, voluntary guidance and future code are not the same legal basis. Absence of the new code does not remove Annex V prohibitions or SOLAS reporting.

Operational Tips

Preparation checklist

Educational checklist. This summary supports learning and preparation only. It does not replace the vessel’s approved procedures, manuals, statutory documents, company SMS, or applicable official requirements. Completing it demonstrates neither compliance nor readiness for an inspection: it shows that a list has been read, not that the ship is in order. Always verify the current documents carried on board.

FAQ

Does the prohibition start in 2030?
The prohibition on discharging plastics at sea is already in force under Annex V/3.2, subject only to the limited regulation 7 exceptions. The IMO 2030 objective does not postpone this obligation. Distinguish ship-generated plastic waste, pellet cargo, incident reporting and the future code.
Is a GRB entry enough for a lost container?
Since 1 January 2026, when containers are lost from the ship, the master reports without delay to nearby ships, the nearest coastal State and the flag State; the flag State informs IMO. SOLAS V/31–32 requires identity, date/time, position, known or estimated number, any dangerous goods and updates after verification. A ship sighting drifting containers reports to nearby ships and the nearest coastal State using the required sighting information; it is not treated as the ship that lost them. Follow shipboard procedures and V/32; a GRB entry alone does not replace reporting.
Is the pellet code already in force?
No. Strategy and guidance do not amount to an adopted code. Regulation (EU) 2025/2365, articles 1.2(d), 12 and 26, already sets 17 December 2028 for application of its containerized sea-transport branch in relation to EU ports. Do not confuse this date with the Regulation’s entry into force or the future IMO code.

Related Topics

Garbage Record BookAnnex III: harmful substances in packages, separate scopeLost-container reporting

Last substantive revision of this page: 15 September 2026 · page fingerprint 06c7f3a646ba