Plastic Pellets (Nurdles): India Moves Ahead with Targeted Controls
Plastic pellet pollution remains a concern in shipping due to incidents of nurdle spillage. India has now taken action with DGS Circular No. 19 of 2026, introducing specific requirements for the carriage of plastic pellets (nurdles) in freight containers. Nurdles are increasingly recognised as an environmental risk that warrants targeted control.
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.
If Members are trading to India or transiting their waters and are carrying plastic pellets, they 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
DGS Circular No.19 represents a targeted and proportionate response to a recognised environmental risk.
For Members, 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 Members for further developments in what is likely to remain an active area of regulatory focus.
Members requiring further information should contact the Club’s Loss Prevention department.