Maritime Transport of Plastic Pellets

Background

In 2023, the International Maritime Organization (IMO) agreed to a two-stage approach to address the environmental risks associated with the carriage of plastic pellets by sea in freight containers. Stage 1 included drafting and finalizing a circular (non-mandatory guidance) that contains recommendations for the maritime transport of plastic pellets. Stage 2 involves the consideration of potential amendments to mandatory instruments to ensure the safe transport of plastic pellets by sea in freight containers.

This effort stems from recent maritime incidents involving the release of plastic pellets into coastal waters, including serious accidents in Sri Lanka, Spain, and the Netherlands. In March 2024, the IMO completed the first stage of its approach by finalizing a circular that contains voluntary recommendations for the carriage of plastic pellets by sea in freight containers. The IMO will now shift its focus to potential amendments to mandatory instruments to ensure safe maritime transport of plastic pellets.

Council Action

Circular (Stage 1)

In February 2024, the World Coatings Council (WCC) attended the IMO’s 11th Session of the Sub-Committee on Pollution Prevention and Response (PPR 11). The sub-committee was tasked with finalizing the text of the draft circular that contains recommendations for the maritime transport of plastic pellets in freight containers. The circular includes a definition for “plastic pellet,” and industry was concerned that powder coatings and any solid polymer raw materials may fall into the scope of the circular.

During PPR 11, WCC intervened in the plenary session and working group meeting with alternative definitions to ensure powder coatings are outside the scope of this effort. Notably, WCC highlighted that, for the purposes of this circular, the definition of “plastic pellet” should only include the appropriate, relevant, and appliable types of plastic pellets that were intended to be captured at the beginning of this process: pellets transported in large volumes as feedstock for the manufacture of plastic articles.

Ultimately, the sub-committee approved the OSPAR/ISO definition of plastic pellet, which is a marked improvement from the original draft definition. The revised circular was sent to the IMO’s 81st Session of the Marine Environment Protection Committee for approval as an urgent matter. MEPC 81 formally approved the circular in March 2024.

The final circular invites member states to use the recommendations and bring them to the attention of shippers, manufacturers, terminal operators, shipowners, ship operators, charterers, shipmasters and all other entities concerned, requesting that additional care and appropriate action be taken during maritime transport of plastic pellets in packaged form. The definition in the final circular reads as follows:

“Plastic pellets means a mass of pre-formed moulding material, having relatively uniform dimensions, used as feedstock in plastic product manufacturing operations. Plastic pellets are transported in various forms, including flakes, granules and powders and can be referred to as resin or nurdles.”

Industry is encouraged to review the new definition of plastic pellet in the circular and reply to ACA with any known concerns.

Potential Amendments to Mandatory Instruments (Stage 2)

With the circular finalized, the IMO will now shift its focus to potential amendments to mandatory instruments to ensure safe maritime transport of plastic pellets. At PPR 11, several member states and NGOs proposed options and measures for amendments to different instruments (e.g., MARPOL Annex III, IMDG Code, UN TDG Model Regulations). The proposals included classifying plastic pellets as dangerous goods (Class 9) or subjecting them to other international maritime transport regulations. However, these discussions on potential amendments to mandatory instruments were deferred to future IMO sessions (MEPC 82 & PPR 12).

ACA/WCC were informed that there may still be some concerns for industry about the definition and scope of “plastic pellet” (e.g., the same HS codes and possible impacts to pellets of resin feedstock from raw material suppliers). As such, ACA/WCC intends to remain actively involved in these plastic pellet discussions moving forward. PPR 12 is scheduled for January 27-31, 2025. Working papers will be due in October/November 2024 (and INF documents due in December). ACA/WCC will remain engaged and update its members with relevant developments.

ACA Staff

Rhett Cash
Counsel, Government Affairs