IMO 2026 Strategy on Marine Plastic Litter and the Future Pellet Code
Zero plastic discharge from ships into the sea by 2030 is not a slogan: MEPC 84 adopted a strategy with a concrete action plan and decided to develop a mandatory code for the carriage of plastic pellets in freight containers. The code is not yet adopted or in force: in the interim MEPC.1/Circ.909 remains voluntary guidance.
Operational Explanation
MEPC 84 adopted the 2026 Strategy and Action Plan to Address Marine Plastic Litter from Ships, reaffirming the IMO's goal of zero plastic discharge from ships into the sea by 2030. The plan focuses on three directions: reducing shipping's contribution to ocean plastic pollution, improving the effectiveness of port reception facilities and onboard waste management, and strengthening international regulation and compliance.
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.
The interval is not a void: there is an IMO circular
Between today and the future code there is not only voluntary market practice: the recommendations have a number and a date.
They are circular MEPC.1/Circ.909, “Recommendations for the carriage of plastic pellets by sea in freight containers”, of 19 April 2024, approved by MEPC 81. The circular describes itself as “the first step in a two-stage approach aimed at reducing the environmental risks associated with the carriage of plastic pellets in packaged form by sea, pending the Committee's consideration of future mandatory measures”: it is the first movement of the path leading to the code, not a document extraneous to it.
It contains three recommendations. Packaging quality: “Plastic pellets should be packed in good quality packaging which should be strong enough to withstand the shocks and loadings normally encountered during transport”, constructed and closed so as to prevent any loss of contents. Identification in the transport document: “Transport information should clearly identify, as an addition in the cargo information required by SOLAS regulation VI/2, those freight containers containing plastic pellets”. And proper stowage and securing, with a preference for under-deck or sheltered positions.
The practical difference is not formal. “Industry practice” and “recommendatory IMO circular” produce different outcomes in a vetting or in a dispute: the second has a number you can cite, a date, and an explicit addressee — the circular invites Member States to bring it to the attention of “shippers, manufacturers, terminal operators, shipowners, ship operators, charterers, shipmasters and all other parties concerned”. Remaining voluntary does not make it invisible.
Regulatory Reference
2026 IMO Strategy and Action Plan on Marine Plastic Litter from Ships (adopted at MEPC 84, April-May 2026): goal of zero plastic discharge from ships by 2030. Development of a mandatory code for the carriage of plastic pellets in containers under MARPOL Annex III and/or SOLAS, being drafted by the PPR Sub-Committee (PPR 14 session). In the interval, circular MEPC.1/Circ.909 of 19 April 2024, approved by MEPC 81, applies on a voluntary basis; IMO itself describes it as the first step of a two-stage approach towards mandatory measures. Declared limit: we read the circular in the IMO text; the outcome of PPR 13 and MEPC 84 on the legal vehicle for the future code comes instead from the session summaries of four classification societies and flag registries, concurring with one another, not from an IMO document we were able to open.
Scope of Application
Every ship, in relation to general onboard plastic waste management under the 2026 Strategy; ships carrying plastic pellets in containers, ahead of the future mandatory code under development.
Procedure / How to Complete It
- Keep onboard plastic waste management aligned with the 2026 Strategy's goals, in particular correct segregation and recording in the Garbage Record Book.
- For ships carrying plastic pellets in containers, follow developments on the mandatory code being drafted by the PPR Sub-Committee, ahead of its future adoption.
- Train the crew on the specific sensitivity of plastic pellets as a long-lasting marine pollutant, distinct from generic onboard plastic waste.
- For the carriage of plastic pellets apply the three recommendations of circular MEPC.1/Circ.909 of 19 April 2024: good quality packaging able to withstand the shocks and loadings normally encountered in transport and closed so as to prevent loss of contents; identification of containers holding pellets in the transport information, in addition to the cargo information required by SOLAS regulation VI/2; proper stowage and securing, preferably under deck or in sheltered areas.
- Monitor updates from the PPR 14 session and subsequent MEPC sessions on the evolution of the pellet code.
Practical Example
Example: an operator regularly carrying plastic pellets in containers applies circular MEPC.1/Circ.909 as a written procedure — qualified packaging, explicit mention of pellet containers in the transport document alongside the SOLAS VI/2 cargo information, and under-deck stowage where possible — and cites it by number in vetting questionnaires, instead of describing it as internal good practice. When the mandatory code arrives, the procedure will already be written.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| The pellet recommendations treated as industry practice, without knowing they are an IMO circular with a number and a date | In a vetting or a dispute the answer is “internal good practice” instead of a citation of MEPC.1/Circ.909 of 19 April 2024, and the same conduct carries less weight | Adopt the circular as a written procedure and cite it by number: qualified packaging, identification in the transport document, under-deck stowage where possible |
| No monitoring by the Company of developments on the future mandatory pellet code | Unpreparedness for the new requirements once the code is finalised | Monitor updates from the PPR and MEPC sessions on the evolution of the plastic pellet code |
What the PSCO Checks
Operational Tips
- If you carry plastic pellets in containers, do not wait for the mandatory code: circular MEPC.1/Circ.909 of 19 April 2024 already applies today, on a voluntary basis, and should be cited by number.
- Follow updates from the PPR Sub-Committee on the code's evolution: the PPR 14 session is the next key milestone.
- Do not confuse the aspirational 'zero plastic by 2030' goal with an immediate compliance deadline: the action plan unfolds in successive phases.
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.
- Onboard plastic waste management aligned with the 2026 Strategy's goals
- For the carriage of plastic pellets, enhanced packaging/stowage practices applied
- Updates from the PPR Sub-Committee on the future code monitored
- Crew trained on the specific sensitivity of plastic pellets as a long-lasting pollutant
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Last substantive revision of this page: 28 August 2026 · page fingerprint c3c5d50fcc87