It elevates the topic to a systematic international level.
Preventive and systemic: better data, reduction and port reception support.
Waste management and cargo handling under environmental considerations.
Read it as a signal: where does early prevention pay off.
The IMO Action Plan to Address Marine Plastic Litter from Ships was first adopted in 2018 and updated in a revised version in 2025. It is not a binding instrument in the traditional sense but a strategic framework that sets the direction for future mandatory regulations. The structure is based on six action areas that collectively address the problem from source to disposal.
Action area 1: Reduction of ship-generated marine litter. This covers improved MARPOL Annex V provisions on disposal of plastic waste, including extension of the prohibition on discharge of plastics to microplastics and cargo residues. The practical consequence: Garbage Management Plans must become more detailed, particularly regarding separation and documentation of plastic fractions.
Action area 2: Improvement of port reception facilities. Many ports – particularly in developing countries – have inadequate disposal infrastructure. The Action Plan pushes for implementation of London Convention/Protocol requirements and for financial mechanisms supporting port states in their development. For operators, this means better disposal options in the medium term but continued gaps in certain trading areas in the short term.
Action area 3: Data collection and reporting. The IMO is working on a standardised reporting system for plastic litter from shipping – including lost cargo, fishing gear and operational waste. This is expected to result in an extension of the IMO Data Collection System (DCS). Operators should prepare to systematically record and report plastic waste quantities in future.
Action area 4: Pellet losses. A dedicated focus area addresses the prevention of pellet losses during sea transport – driven by incidents such as the X-Press Pearl disaster in 2021 off Sri Lanka, when billions of plastic pellets entered the sea. Improved packaging, stowage and reporting standards are being developed.
For technical operations, three concrete changes arise. First: Garbage Management Plans must be updated. Previous plans focus on MARPOL Annex V categories (plastics, food waste, domestic waste etc.), but the new requirements differentiate more within the plastics fraction – particularly microplastics from operational processes (cleaning agents, packaging material, cargo residues).
Second: documentation of disposal events becomes stricter. Port State Control is beginning to examine Garbage Record Books more systematically. Discrepancies between on-board inventory, disposal receipts and estimated waste generation are noticed. Vessels that have not disposed of waste for weeks but have had a full crew on board will have to answer questions.
Third: for vessels transporting plastic pellets, granules or raw materials, specific cargo securing requirements are being tightened. Containers must be checked for integrity before loading. Lost cargo must be reported immediately – not only at the next port. For bulk carriers transporting pellets as bulk cargo, additional covering and handling regulations apply.
The Action Plan does not exist in a vacuum. It is the IMO’s response to a global regulatory trend driven by spectacular incidents and growing public awareness. The X-Press Pearl disaster in May 2021 – when a container vessel caught fire off Sri Lanka and released tonnes of pellets and chemicals – massively accelerated the political momentum.
The EU has taken its own regulatory path with the planned Pellets Regulation (EU Pellets Regulation), which goes beyond the IMO’s ambitions. The regulation envisages binding handling standards for the entire supply chain – including sea transport. Operators calling at European ports and transporting pellets will need to comply with these standards.
For operators this means: the Action Plan is a harbinger of binding regulations. Those who bring their waste management processes up to standard now will avoid expensive retrofits and compliance problems later. Those who wait until regulation becomes binding are acting reactively – with all the associated disadvantages.
The decision whether to act proactively now or wait for binding regulation can be made on the basis of three factors: (1) Exposure – Does the vessel transport plastics or pellets? Does it call at ports with strict waste controls? The higher the exposure, the sooner proactive action pays off. (2) Investment effort – Most measures (updating the Garbage Management Plan, training crew, improving documentation) are low-cost. The ROI is fast because PSC problems are avoided. (3) Market positioning – Charterers and shippers increasingly ask about environmental standards. Early compliance is a differentiator.
For the vast majority of operators, the answer is clear: the costs of early action are low, the risks of waiting are rising. The Action Plan sets the direction – prudent operators follow it before it becomes obligatory.
Much of the operational burden from the Action Plan will land on how crews are trained to handle waste, not on new equipment. Officers responsible for the Garbage Record Book need to understand the finer distinctions the plan pushes toward – separating microplastic-generating waste streams such as synthetic packaging and cleaning residues from general plastics, rather than lumping everything into a single category as many crews have done for years. This is a habit change more than a technical one, and it typically requires refreshed onboard training and clearer waste segregation signage in galley and engine spaces.
Recordkeeping also needs to withstand closer scrutiny. Port State Control inspectors comparing the Garbage Record Book against actual disposal receipts and estimated generation rates will notice a vessel that has not landed waste for an extended period despite a full crew complement, and officers should be prepared to explain any such gap with supporting documentation. Vessels carrying plastic pellets or granular cargo should add a specific pre-loading container integrity check to standard procedures, along with an immediate-reporting instruction for any suspected loss at sea rather than waiting until the next scheduled port call to log it.
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