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Start with the places pellets can escape
Plastic pellets, also called nurdles or pre-production plastics, are small granules used as raw material for plastic products. They can be lost during storage, transfers, loading, transport, unloading, or cleanup. Regulation (EU) 2025/2365 puts prevention of spills from primary containment first, followed by containment and cleanup.
Map the handling process before choosing equipment. For installations covered by the regulation, a risk management plan includes information such as site layout, quantities handled, spill and loss locations, relevant operations, estimated losses, supplier and contractor activities under the operator’s control, responsible staff, and equipment and procedures. The required details and applicable measures depend on the actor, activity, installation, and scale.
- Trace pellet movement from receipt and storage through transfers, production, packaging, loading, and dispatch.
- Mark transfer points, open containers, loading areas, floor and external drains, and locations where packaging is inspected or repaired.
- Identify who owns each control, who responds to a spill, and how losses and corrective actions are recorded.
The Council of the European Union estimated in an 8 April 2025 press release that up to 7,300 truckloads of plastic pellets are lost to the environment each year. This is the Council’s estimate, not a measurement independently established here. Council press release.
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Prevent losses during handling and loading
Reduce transfers and protect primary containment
Where process design allows, reduce unnecessary handling and transfer points: each additional movement can create another opportunity for a spill. Use packaging appropriate to the material and transport conditions. Regulation (EU) 2025/2365 specifies sift-proof packaging or suitable liners and secure closure for relevant packaging, so it prevents losses under normal transport vibration or acceleration.
Inspect bags, packages, and containers before use and before dispatch. Do not continue using packaging that leaks or sifts. Prevent punctures during handling, and use suitable protective measures on equipment where appropriate. Loading procedures should control opening, transfer, closure, sealing, and departure; the regulation identifies spill trays under transfer points and during loading or unloading as measures to consider in relevant risk plans.
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Contain spills at the work area
Put catchment equipment where a spill is likely, such as beneath transfer points or in loading areas. Depending on the site, examples include spill trays and in-ground retention tanks with grating. Protect floor and external drains with pellet-retaining drain covers or suitable alternatives. Where appropriate, the regulation specifies a mesh size smaller than the smallest pellets handled at the site.
Choose drain protection for both pellet retention and safe water flow. Check the smallest pellet size, drain dimensions, expected flow, and the risk of water backing up. Consider secondary catchment, stormwater filtration, sewage treatment, or closed containers where appropriate to the installation’s risks and scale. Inspect and maintain covers, filters, catchment devices, and storage facilities rather than treating installation as a one-time task.
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Build spill response into normal operations
Keep appropriate recovery equipment ready
Match equipment to the site’s mapped risks and the material to be recovered. Regulation (EU) 2025/2365 names vacuums with adequate internal and external capacity, brooms, dustpans, brushes, buckets, repair tapes, and disposal bins among examples of equipment for relevant plans. Keep collected material in closed recovery or disposal containers so it does not escape again.
For a drain cover, check site dimensions, pellet size, drainage requirements, and load rating before selecting a product. For a vacuum, tray, container, or reinforced bag, confirm that its specification fits the expected spill, location, and recovery or disposal method. Equipment works as part of a system: assign inspection, training, and response responsibilities.
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Contain, clean, and account for losses
- Stop the release if safe. Close or isolate the source and prevent further pellet movement.
- Contain the spill. Use the site’s trays, drain protection, or other catchment measures to keep pellets in the work area.
- Recover promptly. Clean spills as soon as possible and no later than the end of the operation, as required by the regulation for applicable operators.
- Secure the recovered material. Reuse collected pellets as raw material where possible. Otherwise retrieve and dispose of them in accordance with applicable waste rules.
- Record and investigate. Assign a staff role to record losses, examine causes, and follow up on corrective actions and the effectiveness of controls.
Include carriers and transport in the control plan
Pellet-loss prevention does not end when a shipment leaves the production area. The regulation includes carrier provisions such as checking packaging integrity, preventing leakage in transit, keeping loading compartments and freight containers clean, and carrying hand tools and closed collection containers or reinforced bags. It also addresses notification of relevant authorities after losses.
Coordinate responsibilities among the operator, carrier, and contractors: establish who checks packaging, who verifies that a loading compartment is clean, what happens if a package is damaged, and how a loss is reported and recorded. The exact obligations depend on the actor and activity covered by the regulation.
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Who is covered by the EU rules?
Regulation (EU) 2025/2365 applies to specified economic operators handling at least five tonnes in the previous calendar year; certain installations that clean pellet containers and tanks; EU and non-EU carriers transporting pellets in the Union; and specified actors involved in seagoing transport of pellets in freight containers to or from Member State ports. The five-tonne threshold refers to handling in the previous calendar year for the specified economic operators; it is not a universal threshold for every actor listed.
The regulation entered into force on 16 December 2025, according to the European Commission. Its requirements are proportionate and vary by actor, activity, installation, and scale. Not every item described as a measure to consider applies universally. Check the legal text against the operation’s exact facts before deciding which provisions and plan requirements apply. The Commission said it would develop awareness and training materials and request European standardisation organisations to prepare harmonised standards for estimating pellet losses by 17 December 2026. European Commission overview. Regulation (EU) 2025/2365.
Maritime pellet rules are still being developed
The IMO reports that MEPC 84 agreed in April 2026 to develop a mandatory code for maritime transport of pellets in freight containers under MARPOL Annex III and/or SOLAS. That is a code under development, not a final code already in force. Check the IMO’s status updates for changes to this rulemaking. IMO: Marine plastic pellets.
Use certification as a complement to operational controls
OCS Europe describes a certification scheme for documenting prevention of pellet, powder, and flake losses across the plastics supply chain. Certification may help structure and demonstrate prevention practices, but it does not replace the need to identify site-specific risks, maintain equipment, train staff, and meet applicable legal requirements. OCS Europe.
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