IMDG Code identifies a substance, material or article as MARINE POLLUTANT with the criteria based on those developed by the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS), as amended. This criteria is listed in Appendix to Annex III of MARPOL.

Marine pollutants are identified with letter “P” in column 4 of dangerous goods list in chapter 3.2

MARPOL Annex III deals with ‘Regulations for the Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form’. This regulation deals with Application, Packing, Marking and labelling, Documentation, Stowage, Quantity limitations, Exceptions & Port State control on operational requirements. In this article we will look at Annex III requirement for, Marking and labelling and Documentation; regulations 3 & 4 respectively.

Marking and labelling

Every package containing marine pollutant shall be marked with correct technical name and marine pollutant mark. These marks and label shall be so durable that information will still be identifiable on packages surviving at least three months’ immersion in the sea.

Symbol (fish and tree): black on white or suitable contrasting background

Dimensions at least 100 mm × 100 mm

Exception: for packages, single packagings and inner packagings of combination packagings containing

– a net quantity of 5 l or less for liquids; or a net mass of 5 kg or less for solids.


If the cargo is a marine pollutant Dangerous Goods Declaration must indicate this with words ““MARINE POLLUTANT”. Also if the cargo is under a generic or N.O.S. entry then proper shipping name shall be supplemented with technical name.

Examples for technical name supplementing proper shipping name for N.O.S. and Generic entries:-

“UN 1993, FLAMMABLE LIQUID, N.O.S. (propyl acetate, di-n-butyltin-di-2-ethylhexanoate), class 3 PG III (50 °C c.c.) MARINE POLLUTANT”

“UN 1263, PAINT (triethylbenzene), class 3 PG III (27 °C c.c.) MARINE POLLUTANT”

Globally Harmonized System of Classification a...
Globally Harmonized System of Classification and Labelling of Chemicals (GHS) pictogram for environmentally hazardous substances (Photo credit: Wikipedia)

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