By Priyatham Sanjeeva Reddy Ramidi
A container ship casualty can be measured in familiar units: tons of fuel spilled, containers lost, days of salvage, kilometers of shoreline affected, or millions of dollars in claims. Plastic pellets complicate that picture because the unit that matters may be counted in the millions before anyone knows exactly where they went.
India’s new requirements for the carriage of plastic pellets, commonly known as nurdles, therefore deserve attention for more than their environmental purpose. They also expose a difficult maritime investigation and liability problem: how do authorities, shipowners and insurers reconstruct responsibility after countless tiny pieces of cargo leave a container, spread through the sea and wash ashore over a wide area?
The Directorate General of Shipping’s Circular No. 19 of 2026 introduces specific controls for plastic pellets carried in freight containers. Containers carrying pellets must be stowed below deck, rather than on exposed deck positions, and packaging must meet strengthened standards.
The requirements apply to shipments from 15 April 2026 and are subject to Flag State and Port State inspection. The timing is significant. The 2025 sinking of MSC Elsa 3 off Kerala demonstrated how a container casualty can quickly become a prolonged coastal response.
Following the sinking, Indian Coast Guard surveillance and shoreline-cleanup efforts continued as nurdles and other pollutants affected parts of Kerala and Tamil Nadu. The casualty gave India a practical view of a problem that the International Maritime Organization has been discussing for several years.
At IMO level, recommendations adopted in 2024 called for stronger packaging, clear identification of containers carrying plastic pellets and safer stowage, preferably below deck. In April 2026, IMO’s Marine Environment Protection Committee agreed to develop a mandatory international code for the maritime transport of plastic pellets.
India has effectively moved ahead of that future global regime.
The logic behind below-deck stowage is straightforward. A container placed beneath deck is less exposed to the conditions that can result in containers being lost overboard. Stronger packaging creates another layer of defense if a container is damaged. These are sensible loss-prevention measures.But prevention is only one side of the issue.
Once pellets enter the sea, the casualty changes character.
Oil usually creates a visible pollution footprint. Containers can be identified by numbers. Damaged cargo often remains associated with a particular unit. Nurdles behave differently. Individual pellets are tiny, buoyant and mobile. Currents, tides and weather can disperse them over large distances, while repeated beaching and refloating can extend the response long afterthe original casualty.
For investigators, the first question may appear simple: where did the pellets come from?
After a known container casualty involving declared pellet cargo, the answer may seem obvious. Yet major incidents rarely remain simple once claims, enforcement and cost recovery begin. Investigators may need to establish which containers contained pellets, whether packaging failed before or after the containers entered the sea, what quantities were actually released, when the release occurred, and which shorelines can reasonably be connected to the casualty.
That makes documentation unusually important.
Cargo declarations, container numbers, bills of lading, packing records, stowage plans and photographs may become central evidence. So might samples collected from shorelines. Different polymer types, colors, sizes or additives may help distinguish one shipment from background plastic pollution or another release.
The investigation may also need oceanographic evidence. Current modelling, wind, tides and the timing of shoreline discoveries can help establish whether a particular accumulation is consistent with the casualty under investigation.
This is where a small piece of plastic can become a large P&I problem. A shipowner facing a pellet release may encounter costs connected with shoreline cleanup, surveys, monitoring, disposal, third-party property or economic impacts, and potentially wreck or cargo-removal issues depending on the circumstances and applicable law. IMO itself notes that liability for pellet-cleanup costs depends on the specific incident, relevant international conventions and national law.
For a P&I Club, that creates two related challenges. The first is response. Unlike a conventional cargo claim, the priority may quickly become environmental mitigation. Local authorities, cleanup contractors, surveyors, correspondents and scientific specialists may all become involved while pellets continue to move. The second is attribution. Insurers need to distinguish reasonable casualty-related costs from contamination that cannot reliably be connected to the insured event. That is not necessarily an attempt to avoid responsibility. It is a basic requirement of fair claims handling. If a coastline already contains legacy microplastics, every pellet recovered after a casualty cannot automatically be assumed to have come from one ship.
At the same time, uncertainty cuts both ways. A shipowner cannot reasonably argue that dispersed cargo is no longer its problem merely because individual pellets cannot be tracked visually from vessel to beach. The practical solution is early evidence preservation.
If a vessel loses containers carrying plastic pellets, the investigative response should begin almost immediately. Authorities and interested parties should identify the exact pellet cargo, obtain representative samples where possible, preserve packaging and shipping documentation, map confirmed sightings, record the timing of shoreline impact and establish an agreed sampling methodology.
That approach would help both environmental response and later claims handling. India’s new rule also places greater importance on the chain of responsibility before the ship sails. The carrier depends on the shipper to correctly declare the cargo and package it appropriately. The vessel must then incorporate that information into its stowage plan. If the shipment is mis declared, improperly packed, or incorrectly stowed, the later casualty investigation may extend well beyond the actions of the master and crew.
This is an important point because the maritime conversation around nurdles can too easily become focused only on ships. The risk begins before the container reaches the vessel. Manufacturers, packers, shippers, freight forwarders, terminal operators and carriers each occupy a point in the containment chain. India’s approach recognizes that preventing pollution requires the cargo to be identified, contained and positioned appropriately before heavy weather or a casualty tests those defenses.
The wider significance extends beyond India. IMO’s decision to develop a mandatory code suggests that stronger international requirements are coming. India’s 2026 rules may therefore offer an early test of how practical controls work in real-world shipping.
The industry should pay close attention to what follows: inspection findings, compliance difficulties, packaging performance and, unfortunately, any future incidents. Plastic pellets look harmless when contained in a bag. At sea, their scale is deceptive. One lost container can transform a cargo problem into a shoreline problem, an environmental response, an investigation and ultimately an insurance dispute.
India’s new rules are an important preventive step. Their larger lesson, however, is that modern automatically be assumed to have come from one ship. At the same time, uncertainty cuts both ways. A shipowner cannot reasonably argue that dispersed cargo is no longer its problem merely because individual pellets cannot be tracked visually from vessel to beach.
The practical solution is early evidence preservation. If a vessel loses containers carrying plastic pellets, the investigative response should begin almost immediately. Authorities and interested parties should identify the exact pellet cargo, obtain representative samples where possible, preserve packaging and shipping documentation, map confirmed sightings, record the timing of shoreline impact and establish an agreed sampling methodology.
That approach would help both environmental response and later claims handling. India’s new rule also places greater importance on the chain of responsibility before the ship sails. The carrier depends on the shipper to correctly declare the cargo and package it appropriately. The vessel must then incorporate that information into its stowage plan. If the shipment is mis declared, improperly packed, or incorrectly stowed, the later casualty investigation may extend well beyond the actions of the master and crew.
This is an important point because the maritime conversation around nurdles can too easily become focused only on ships. The risk begins before the container reaches the vessel. Manufacturers, packers, shippers, freight forwarders, terminal operators and carriers each occupy a point in the containment chain. India’s approach recognizes that preventing pollution requires the cargo to be identified, contained and positioned appropriately before heavy weather or a casualty tests those defenses.
The wider significance extends beyond India. IMO’s decision to develop a mandatory code suggests that stronger international requirements are coming. India’s 2026 rules may therefore offer an early test of how practical controls work in real-world shipping.
The industry should pay close attention to what follows: inspection findings, compliance difficulties, packaging performance and, unfortunately, any future incidents. Plastic pellets look harmless when contained in a bag. At sea, their scale is deceptive. One lost container can transform a cargo problem into a shoreline problem, an environmental response, an investigation and ultimately an insurance dispute.
India’s new rules are an important preventive step. Their larger lesson, however, is that modern marine pollution is not always measured by the size of what enters the water. Sometimes the smallest cargo creates the most difficult claim.
Author : Priyatham Sanjeeva Reddy Ramidi
Disclaimer: The views expressed by Priyatham Ramidi in this interview are his independent professional opinions and are provided for general informational purposes. They do not constitute legal, insurance, classification, regulatory, security, or vessel-specific advice. Operational decisions are entirely based on the circumstances and of the individual vessels at their own discretion and made in conjunction with the Master’s agreement along with technical
managers, flag administration, classification society, P&I Club or insurers, brokers, and relevant authorities.
