MARPOL Annex V for Superyachts: Garbage Management Plan and Discharge Rules Explained

A captain we spoke with described the moment precisely: a PSC officer in a Spanish port asked to see the Garbage Record Book, flipped past three months of clean entries, and stopped on a gap — a discharge the crew remembered doing but nobody had logged. No damage, no spill, no fine that day. Just a deficiency notation, and a longer morning than anyone had planned for.

MARPOL Annex V is the part of MARPOL that governs what leaves the vessel as waste, not what leaves the exhaust — and for yachts operating in the Mediterranean, it has applied longer and more strictly than most captains assume. This guide covers what Annex V actually requires: the Garbage Management Plan, the Garbage Record Book and its 2024 threshold change, the discharge rules by category, and where PSC inspections tend to find the gaps.

What MARPOL Annex V Actually Regulates

MARPOL has six annexes, and it's easy to conflate them once you're deep in compliance paperwork. Annex VI governs air emissions — sulphur, NOx, carbon intensity — everything that comes out of the exhaust stack. Annex V is a different regulatory track entirely: it governs garbage, meaning everything from food waste and plastics to cargo residues and incinerator ash, and what a vessel is permitted to discharge into the sea rather than deliver to a shore facility.

The general rule under Annex V is the inverse of what many crew assume by default: discharge of garbage into the sea is prohibited, with narrow, specific exceptions written into the regulation for a handful of categories under defined conditions. Nothing goes over the side because "it's biodegradable" or "it's what we've always done." Either a specific regulation permits the discharge at a specific distance, or it doesn't happen at sea at all.

The Garbage Management Plan: Who Needs One and What It Covers

Regulation 10 of Annex V requires a written Garbage Management Plan aboard every ship of 100 gross tonnage and above, every ship certified to carry 15 or more persons regardless of tonnage, and every fixed or floating platform. For yachts, the certified-persons threshold catches vessels that might otherwise assume they're too small to bother — a day-charter boat well under 100 GT but certified for 20 guests needs a GMP just as much as a much larger private yacht.

The plan itself has to be more than a boilerplate document pulled from a template. It needs written procedures covering:

• Collection, storage, processing, and disposal of garbage, broken out by category (plastics, food waste, cooking oil, cargo residues, incinerator ash, fishing gear, e-waste)
• Equipment aboard for handling garbage — compactors, incinerators, segregation bins — and how they're actually used
• The designated person responsible for implementing the plan day to day, named by role or position
• Placards posted for crew and, where applicable, passengers, notifying them of the discharge requirements — this is a specific Regulation 10 requirement, not an optional nicety

A GMP that was accurate when the vessel was delivered but hasn't been updated since — no reference to newer amendments, no reflection of how the crew actually segregates waste today — is a common enough gap that it's worth treating as a season-opening review item rather than a one-time document.

The Garbage Record Book — and the 2024 Threshold Change

Vessels meeting the size and capacity thresholds must also maintain a Garbage Record Book (GRB), recording every discharge or accidental loss of garbage: date, time, position (latitude and longitude), category and estimated quantity of garbage, and the reason for the discharge or loss. Records must be retained for two years.

Vessels under 100 GT aren't exempt from record-keeping altogether — they log discharge and accidental loss events in the ship's official logbook instead of a dedicated Garbage Record Book. The obligation to record doesn't disappear below the tonnage line; only the format changes.

What Can and Cannot Go Over the Side

This is where Annex V gets specific, and where crew training tends to be strongest on the headline rule (no plastic) and weakest on everything with a distance attached to it.

Plastic — never, anywhere. All forms of plastic, including synthetic ropes, fishing gear, garbage bags, and plastic packaging, are prohibited from discharge into the sea in every ocean area, at any distance from land, inside or outside a Special Area. There is no comminution exception the way there is for food waste. This is the simplest rule in the Annex and the one with zero tolerance.

Food waste — distance and comminution dependent. Outside a Special Area, food waste ground or comminuted to pass through a screen with openings no larger than 25 mm may be discharged at least 3 nautical miles from the nearest land, while non-comminuted food waste requires at least 12 nautical miles. Inside a Special Area, the rules tighten: only comminuted food waste may be discharged, and only at 12 nautical miles or more — non-comminuted food waste discharge is prohibited entirely once you're inside a Special Area boundary.

Everything else — check the category before assuming. Cargo residues, cleaning agents, cooking oil, and other categories each carry their own conditions under Regulations 4 through 6 of the Annex. The safe operating assumption for crew is not "biodegradable items are probably fine" — it's checking the vessel's own Garbage Management Plan, which should already translate these categories into concrete deck procedures.

Special Areas — The Mediterranean Has Been One Since 1983

Annex V designates eight Special Areas where discharge rules are stricter than the global default: the Mediterranean Sea, Baltic Sea, Black Sea, Red Sea, the Gulfs area, North Sea, Wider Caribbean Region, and the Antarctic area.

For a yacht based in or chartering through the Mediterranean, this means the stricter Special Area discharge rules — no non-comminuted food waste, comminuted food waste only beyond 12 nm — aren't a new consideration to plan around. They're the baseline that's applied to every mile sailed for as long as most active captains have held a ticket.

Where PSC Finds the Gaps

Garbage management deficiencies are the second most common MARPOL-related finding in Port State Control inspections, behind Annex I oil pollution items — a meaningful share of the total deficiency picture, not a minor footnote. The specific issues that surface most often aren't dramatic discharge violations; they're paperwork and procedure gaps:

• Incomplete or inconsistent GRB entries — missing position data, undated entries, gaps between when a discharge happened and when it was logged
• A Garbage Management Plan that hasn't been updated to reflect the current regulation, including the 100 GT GRB threshold change
• Crew who can't explain the vessel's own segregation system when a PSC officer asks a watchkeeper directly, rather than the captain
• Mixed bins — plastics in food waste containers, labeling that doesn't match the actual color-coded segregation the plan describes

None of these individually sinks an inspection. The pattern that does is the same one that shows up across every MARPOL Annex: a plan that exists on paper but doesn't match what the crew actually does, discovered by an officer who asks a specific enough question. See our Port State Control guide for how these inspections unfold end to end, and how garbage findings tend to sit relative to other deficiency categories.

Garbage Management in Practice

For most crews, staying ahead of Annex V comes down to a short set of habits rather than memorizing regulation text:

• Confirm your vessel's actual gross tonnage against the 100 GT threshold, not its length overall — GT is a volume measurement, and it's easy to assume a smaller-looking yacht sits below a threshold it's actually above.
• Log every discharge and accidental loss the same day it happens, not at the end of the week from memory — the GRB gaps PSC officers find are almost always timing gaps, not fabrication.
• Review the Garbage Management Plan at the start of each season, alongside other statutory documentation, and update it if segregation equipment or procedures have changed since it was written. Yachts already running an ISM Code Safety Management System should treat the GMP as part of that same documentation review cycle rather than a separate, forgotten binder.
• Brief new crew on the segregation system specifically, not just "don't throw plastic overboard" — a watchkeeper who can walk a PSC officer through the bin color-coding and the reasoning behind it reads very differently from one who can't.
• Treat the plastic rule as absolute in crew training — there's no distance exception to teach, which makes it the easiest rule to enforce consistently if it's framed that way from day one.

Frequently Asked Questions

Keeping Annex V Manageable

MARPOL Annex V isn't conceptually difficult — don't discharge plastic, respect the distance rules for everything else, and keep the paperwork that proves it. What makes it slip is the same thing that makes every compliance track slip on a working yacht: it's one plan among many, competing for attention with maintenance schedules, crew certificates, and a Mediterranean season that doesn't pause for documentation review.

Keeping the Garbage Record Book, the Garbage Management Plan's review date, and the rest of the vessel's compliance calendar in one system — rather than a logbook, a binder, and a captain's memory of when things were last checked — is what turns a routine PSC call into a routine PSC call, instead of the morning that gets talked about for the rest of the season.

Source: IMO — Prevention of Pollution by Garbage from Ships