Tackling sea-based sources of plastic pollution at the International Maritime Organisation

EIA is currently participating in a meeting of the International Maritime Organisation (IMO) which is seeking to push ahead with actions to tackle two major sources of marine plastic pollution.

The eleventh session of IMO’s Pollution Prevention and Response Sub-Committee (PPR-11) is running from February 19-23 in London.

Its primary focus is to advance regulatory measures to address pollution of the natural environment by plastic pellets and fishing gear.


Plastic pellets

Plastic pellets, flakes and powders – aka nurdles or resin – can resemble tiny bead-like particles and are a crucial material for manufacturing almost all plastic products. However, the exponential growth in plastic production has led to a surge in pellet transportation, resulting in spills and lost containers at sea.


These spills pose severe threats to marine ecosystems, with pellets being mistaken for food by marine life, leading to digestive issues, reduced feeding efficiency and even mortality. Additionally, plastic pellets act as carriers for toxic chemicals, contributing to the accumulation of pollutants in marine organisms.

To address these challenges, members of the IMO have committed to a two-step process. First, the creation of voluntary guidance emphasises the use of proper packaging, notification of pellets on board, appropriate stowage on or under deck and the implementation of pollution preparedness and response measures to reduce harm from maritime pellet losses. The second step involves amending international law to establish global mandatory measures in these four areas.

Fish found choked with nurdles following the X-Press Pearl plastic pellet spill off Sri Lanka, 2021

PPR-11 is pivotal for finalising voluntary guidance, including determining a suitable plastic pellet definition. EIA is advocating for a clear and harmonised definition, urging members to adopt the definition of the Convention for the Protection of the Marine Environment of the North-East Atlantic (OSPAR) and the International Organisation for Standardisation (ISO), which avoids size limitations and ensures clarity, consistency, relevance and objectivity.

This comprehensive definition, encompassing various materials and packaging criteria, is essential for mitigating chronic and acute leakage, forming a robust foundation for effective environmental safeguards against plastic pellet pollution.

After finalising the circular, discussions among members will focus on determining the most appropriate instrument for mandatory measures. However, submissions from industry groups indicate a desire to delay mandatory obligations, raising concerns about potential conflicts of interest hindering progress.

EIA stresses the urgency of pursuing amendments to the International Convention for the Prevention of Pollution from Ships (MARPOL) Annex III and a UN Class number, emphasising their role in facilitating the mandatory implementation of objectives aimed at reducing environmental harm caused by plastic pellet losses.


Fishing gear

In the expansive realm of maritime challenges, addressing the profound impact of abandoned, lost or otherwise discarded fishing gear (ALDFG), aka ‘ghost gear’, is also of critical importance. The PPR-11 spotlight extends beyond plastic pellets to encompass the alarming consequences of ghost gear in our oceans.

Crab entangled in plastic ghost gear (c) NOAA


This pollution, often comprising derelict nets, lines and traps, wreaks havoc on marine ecosystems, posing a persistent threat to underwater life. The damage inflicted by these ghostly remnants is far-reaching, entangling and ensnaring marine creatures, contributing to habitat degradation and undermining the sustainability of global fisheries.

To adequately address ghost gear, EIA urges the IMO to expand comprehensive measures on fishing gear to include mandatory reporting, gear marking and fishing gear plans. If IMO members choose ambitious overarching measures to address these three issues, they can make a huge impact on safeguarding our marine environments, coastal communities and the fishing industry.

EIA strongly advocates for real-time, mandatory reporting of lost fishing gear, expressing concern over proposed annual aggregated reporting. Emphasising the need for a dynamic system, we are calling for seamless integration with existing regional efforts, providing real-time, low-burden data without compromising sensitive information. Coastal states’ access to the IMO database, periodic expert analysis and science-based reporting thresholds are crucial for effective intervention.

Beyond reporting, EIA underscores the importance of an holistic approach, addressing port measures, waste management, awareness and training in alignment with the IMO’s Action Plan to reduce marine plastic litter. We call on members to advance work on the marking of fishing gear and creating fishing gear management plans.


Global governance

EIA also actively participates in the international legally binding instrument on plastic pollution, advocating for comprehensive regulations along the entire supply chain of plastic pellets and the lifecycle of plastic fishing gear.

Plastic tap art outside the UN by artist Von Wong (c) EIA

Amid differing opinions on the regulatory framework, EIA calls for legal clarity within the process of the United Nations Intergovernmental Negotiating Committee (INC) on Plastic Pollution, currently working towards a Global Plastics Treaty, and for thoughtful consideration of practical and timely measures.

To this end, we’re urging the Sub-Committee to request that the IMO Secretariat presents a document at the fourth session of the negotiations (INC-4) in April to outline competencies, progress and timelines on plastic pellets and fishing gear.

As we engage in these critical discussions, EIA remains resolute in its mission to drive meaningful change by campaigning for a cleaner and safer maritime environment, with strong international measures that protect our oceans, marine life and the communities that rely on them.