Losses during transport have significant environmental impacts.
Packaging, terminal handling, stowage and reporting pathways.
Lost pellets are extremely difficult to recover.
Review where pellets are handled in the supply chain.
Plastic pellets (also called nurdles) are granules of 2-5 mm used as raw material for plastics manufacturing. Over 400 million tonnes are produced globally each year, with a significant proportion transported by sea. Pellets are transported in containers (in big bags or sacks), as bulk cargo in bulk carriers or in flexi-tanks. Each transport mode has specific loss risks.
Container transport: The main risk lies in damaged packaging. Big bags (FIBCs) can tear through improper handling during loading or through movement during the voyage. Pellets then enter the container and from there reach harbour waters via condensation drains or during discharge. In the event of containers lost at sea – on average 1,500-3,000 containers go overboard annually – millions of pellets can be released.
Bulk transport: Pellets as bulk cargo are subject to the same risks as other dry bulk: dust generation during loading and discharge, residues in cargo holds, losses through incomplete discharge. Due to their small size, however, pellets are harder to recover than other bulk cargoes. They reach the sea via bilges, wash water and cleaning discharges.
Terminal handling: Terminals where pellets are handled are critical loss points. Spillages during crane transfers, truck handling and in storage areas are common. Without capture systems (drain filters, containment trays, enclosed conveyor systems), pellets enter harbour waters with every rainfall and from there the open sea.
The ecological consequences are significant: pellets are ingested by marine organisms, transport pollutants (POPs, PAHs) as carrier media and accumulate in coastal ecosystems. On some beaches worldwide, pellets already account for over 70 % of microplastic finds.
The regulatory development affects not only shipowners but the entire supply chain. The EU Pellets Regulation (in preparation) envisages obligations for manufacturers, logistics providers, terminal operators and carriers. For maritime companies, concrete action areas arise.
For shipowners and charterers: checking cargo descriptions for pellet content. Ensuring that containers with pellet cargo are specially secured (stowage securing, integrity checks). Reporting obligations for container losses that may contain pellets. Reviewing bilge water disposal for pellet contamination on vessels that have carried pellets as bulk cargo.
For terminal operators: installation of capture systems at handling areas and drainage points. Training of personnel in pellet handling. Documentation of spillages and clean-up measures. Regular audits of handling processes.
For ship crews: awareness that pellet losses are becoming reportable. Checking container integrity where visible damage exists. Documentation of pellet residues in cargo holds after discharge.
Regulation of pellet transport is developing on several levels in parallel. The IMO addresses the topic through the Plastic Litter Action Plan and via amendments to MARPOL Annex V. The EU is pursuing an independent, stricter approach with the Pellets Regulation. Individual countries go further still: France already passed a law against pellet losses in 2021 (Loi AGEC), which mandates certification obligations for the entire supply chain.
For operators trading internationally, a regulatory mosaic emerges: IMO standards as the minimum, EU standards for European ports, national standards for certain flag states or ports of call. Those who align their processes to the strictest standard are compliant everywhere – those who only meet the minimum risk problems at every port change.
The timeline points towards tightening in the next 2-3 years. The EU Pellets Regulation is expected to enter into force in 2026-2027. IMO amendments to MARPOL Annex V could take effect by 2028. Operators who adjust their processes now have a lead time of 1-2 years.
A structured risk assessment for pellet transport comprises four steps: (1) Determine exposure – Does the vessel or terminal regularly transport pellets or plastic raw materials? What proportion of total cargo volume? (2) Identify loss points – Where in the own process chain can pellets be lost? Loading, stowage, transport, discharge, hold cleaning? (3) Assign measures – For each loss point: what prevention measure is available and proportionate? (4) Build documentation – Implement demonstrable processes that withstand regulatory scrutiny.
For companies with low pellet exposure, an update to the Garbage Management Plan and crew awareness raising is often sufficient. For companies with high exposure (regular pellet transport), a systematic process review with capital measures is required.
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