OCS Europe

Status & developments

• The OCS Europe Scheme was initiated jointly by PlasticsEurope and EuPC, in consultation with industry, NGOs and politicians.  
• Stakeholders were involved in a public consultation in May 2022.  
• The legal significance of the OCS scheme depends heavily on whether it becomes mandatory through EU regulation. So far, OCS is a voluntary standard or certification offer.  
• Under the planned EU regulation on pellet losses, independent certification will become mandatory above a certain quantity (e.g. > 1,000 tonnes of pellet handling per year).  
• For smaller companies, however, only self-declarations are planned.  
• There are also reports that certain players are already required to report pellet losses and carry out audits, such as EPS (expanded polystyrene) manufacturers.  

Challenges & uncertainties

• The OCS standard still needs to be translated into specific legal requirements for certification obligations to apply.
• It remains unclear how strict audits and sanctions will be interpreted.
• For actors involved in the supply chain (e.g. transporters, cleaning companies), this will result in an expansion of their responsibilities.  
• Implementation at national level (EU Member States) is likely to vary.

Microplastics (EU regulation, EP & Council)

Previous regulation – intentionally added microplastic particles

• On 17 October 2023, Regulation (EU) 2023/2055 came into force, which is consistent with REACH and concerns synthetic polymer microparticles (≤ 5 mm, organic, insoluble, non-degradable) when they are intentionally used in products.  
• Some products are already affected (e.g. loose glitter, certain cosmetics).  
• For other products (e.g. detergents, polishes, leave-on cosmetics, etc.), there are staggered transition periods (2027, 2028, 2029, 2031, 2035) for the ban or restriction.  
• The threshold for the ban on microplastics in a mixture is usually 0.01% by weight (i.e. the product must not contain more than 0.01% of such particles).  
• In April 2025, the European Commission published an explanatory implementation guide to support the application of the microplastics regulation.  

New regulation – loss of plastic pellets / unintentional release

Since many microplastic problems are caused not by intentional addition but by loss and abrasion, the EU is currently in the process of introducing supplementary regulations:

• On 8 April 2025, a provisional agreement was reached between the Council and Parliament on a new regulation to prevent pellet loss.  
• Under this regulation, plant operators, transporters and ship operators will have certain obligations (risk management, cleanliness, training, reporting requirements).  
• Above a certain amount of pellet handling (frequently discussed: 5 tonnes or more per year), certification or a declaration of conformity would be required.  
• The regulation would apply to both EU and non-EU transport (with authorised representatives in the EU for non-EU carriers).  
• Following the provisional agreement, the Parliament and the Council must now formally adopt the text, followed by legal and linguistic review and publication in the Official Journal.  
• After publication, the regulation will typically take effect after 20 days.  

Additional initiatives & accompanying measures

• As part of the revision of the Waste Water Directive / municipal waste water, proposals are included to monitor and reduce microplastics in the inflows and outflows of sewage treatment plants.  
• One proposal stipulates that manufacturers of cosmetics and pharmaceuticals should bear 80% of the costs of removing micro- and micropollutants from municipal wastewater (in accordance with the polluter pays principle).  
• The EU Zero Pollution Action Plan sets a target of reducing microplastic emissions by 30% by 2030.  
• Some national implementations of the EU requirements are still in flux, and monitoring and enforcement will be an important issue.

Assessment & looking ahead

• The EU is going well beyond mere product bans and is attempting to address sources of unintentional release (pellet losses, wastewater).
• The new pellet regulation will be essential for institutionalising OCS in the future.
• Companies that handle, process or transport pellets should familiarise themselves with their obligations (risk management, training, audits, reporting requirements) at an early stage.
• For manufacturers of products with possible microplastic content, the switch to alternative ingredients is urgently important – especially in view of the transition periods.
• Practical implementation (monitoring, enforcement, audit quality) will be crucial to achieving a real impact.