Marine plastic litter: why it matters to vessel operators

Recent discussions under the MEPC and PPR have proposed enhancements, including a potential new chapter in Marpol Annex III to regulate plastic pellets.

Voluntary measures, such as MEPC.1/Circ.909, provide guidance on the safe transport and packaging of plastic pellets, setting the stage for potential mandatory provisions. To comply with these measures, shipowners and operators must adopt robust waste management plans and adhere to guidelines for fishing gear marking and retrieval.

Transporting plastic pellets requires adherence to packaging and stowage recommendations, with carriers ensuring secure arrangements and documentation. 

Compliance is critical not only for environmental protection but also for mitigating liability. Penalties for non-compliance are jurisdiction-specific, ranging from fines to liability for cleanup costs. For example, improper handling of plastic pellet transport or failure to report lost gear could result in severe financial repercussions, particularly under stricter enforcement of Marpol provisions.

However, challenges remain – data gaps and inconsistencies across national reporting frameworks hinder the uniform implementation of IMO measures.

As Australia noted in its correspondence to IMO, “A lack of harmonisation in data collection undermines the ability to assess and address marine plastic litter comprehensively” (PPR 12/11).

Efforts to unify reporting standards under IMO frameworks are ongoing but face resistance due to resource constraints and varied national capabilities.

Another critical debate centres on mandatory versus voluntary measures. While voluntary instruments like MEPC.1/Circ.909 have demonstrated early success, the transition to mandatory regulations requires industry consensus. As China highlighted, “Sufficient time must be provided for experience-building and industry adaptation before moving to mandatory instruments” (PPR 12/11-4).

The balance between stringent requirements and operational adaptability is crucial, particularly for emerging issues such as microplastics from anti-fouling paints.

Global engagement remains a cornerstone of IMO efforts

Encouraging broader adoption of voluntary measures and fostering international co-operation are essential to building consensus for future regulatory steps.

Friends of the Earth International, a consistent advocate for mandatory measures, noted the importance of “implementing real-time reporting systems and expanding the scope of Marpol provisions to address plastic pellet spills effectively” (PPR 11/13-12).

IMO will continue its work on marine plastic litter at the next session of the Marine Environment Protection Committee (MEPC 83), scheduled from 7 to 11 April 2025, at the IMO headquarters in London. The agenda includes follow up work emanating from the Action Plan to Address Marine Plastic Litter from Ships.

With items such as the energy efficiency of ships, reduction of greenhouse gas emissions and pollution prevention also on the docket, marine plastic litter will remain a critical focus amid broader environmental discussions.

The path forward will require collaboration across governments, industry stakeholders and non-governmental organisations.

IMO’s evolving action plan seeks to strike a delicate balance between environmental stewardship and the practicalities of maritime operations.

Shipowners and operators must remain proactive, not only in compliance but also in contributing to the broader dialogue shaping the future of marine plastic litter regulations.

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