Plastic pellet pollution remains a concern in shipping due to incidents of nurdle spillage. West P&I Club has highlighted a circular from India’s DGS, Circular No. 19 of 2026, which introduces specific requirements for transporting plastic pellets (nurdles) in freight containers. Nurdles are increasingly recognised as an environmental risk that warrants targeted control.
In the circular, DGS said recent incidents along the Indian coastline have highlighted serious concerns regarding marine pollution caused by the loss of freight containers carrying plastic pellets at sea. It added recovery of these pellets has proved extremely difficult and requires extensive manual clean-up operations. There is also the further issue of plastic pellets fragmenting into microplastics, raising another concern of the long-term impact on marine biodiversity, coastal ecosystems and fisheries-dependent livelihoods.
Specifically, West P&I Club said incidents such as MSC ELSA 3, which occurred in May 2025 and affected the Indian coastline, have illustrated the scale of the issue. At the international level, the IMO has already issued recommendations on the carriage of plastic pellets, with further discussions ongoing regarding potential mandatory measures.
The circular introduces two requirements regarding stowage and packaging.
Stowage:
- Containers carrying plastic pellets must be stowed under deck only.
- Carriage on deck is prohibited.
From a loss prevention perspective, this directly addresses a recognised exposure, as container losses are more likely to occur in high-deck stow, particularly in adverse weather when automatic and semi-automatic twist locks are used.
Packaging:
- It needs to meet secure standards not less than those prescribed under the IMDG Code for dangerous goods.
This strengthens cargo containment and reduces the risk of leakage at sea and during handling.
Compliance will be checked through Port State and Flag State inspections. The requirements apply to shipments from 15 April 2026 onwards.
Vessels calling at Indian ports or transiting their waters and are carrying plastic pellets, must consider the following:
- Ensure the crew check the packaging standards during cargo acceptance
- Ensure stowage planning reflects the under-deck requirement
- Advise the crew prior to trading to or through Indian waters
The club said the key takeaway is that expectations around the carriage of plastic pellets are evolving. Early alignment with these requirements will support compliance within the Indian context and help position the maritime industry for further developments in what is likely to remain an active area of regulatory focus.
