Polymer Comply Europe
The only training course covering both the REACH Restriction EU 2023/2055 and the new Pellet Loss Regulation EU 2025/2365 — with practical, operational guidance for every company handling plastic pellets, flakes, or powders.
REACH labelling is already live — your first annual emissions report to ECHA is due May 2026, covering 2025 losses.
What's At Stake
Under Article 20 of Regulation 2025/2365, the maximum administrative penalty must be at least 3% of annual EU turnover in the preceding year — set by each Member State to be effective, proportionate, and dissuasive.
Additionally, competent authorities can suspend operations or immobilise vehicles where an infringement poses an immediate risk to human health or the environment.
Course Curriculum
Scope and definitions of Entry 78 of Annex XVII to REACH. The industrial site derogation — why pellets used as feedstock are not banned, and what conditions apply. Labelling obligations for compounders and masterbatchers: instructions for use and disposal, SPM identity, quantity, and the mandatory REACH statement. Exceptions for technically contained, permanently modified, or permanently incorporated SPMs.
Full overview of the standalone regulation: scope, what are plastic pellets, and which operators are covered. Key obligations: RMP, certification/EMAS notification, record keeping and labelling.
Practical implementation of Annex I measures, covering Prevention, Containment and Clean-up measures.
How can OCS Europe certification help you meet the Pellet Loss Regulation? What are the benefits of certification, and how can it help you comply with the regulation?
How can you meet and comply with the REACH reporting requirements? What you need: ECHA account, IUCLID template, information on use, and an emissions estimate submitted via REACH-IT.
A complete, practical guide to quantifying and documenting your pellet losses. Map all emission sources on your site plan. Apply the simplified EuPC Bow-Tie methodology. Measure and estimate losses at each mitigating barrier. Calculate on-site routine losses, incident losses, and transport losses separately. Complete the IUCLID reporting template.
Who Is This For
Responsible for implementing Risk Management Plans, practical measures and day-to-day pellet loss prevention on site.
Ensuring REACH labelling is correct, ECHA reporting is submitted on time, and certification deadlines are met for your company size.
Carriers and logistics managers responsible for transport obligations, SQAS compliance, incident reporting, and Incoterms responsibilities.
Understanding the full exposure — penalties up to 3% of EU turnover, certification timelines, and the strategic compliance roadmap.
Access
Questions
My company handles less than 1,500 t/yr. Do I still need to comply?
Yes. The scope threshold under EU 2025/2365 is just 5 t/yr. Operators below 1,500 t/yr are exempt from third-party certification but must still implement Annex I measures, establish a Risk Management Plan, and provide a self-declaration to competent authorities every 5 years.
What is the difference between EU 2023/2055 and EU 2025/2365?
EU 2023/2055 is a REACH restriction driving labelling and ECHA reporting obligations. EU 2025/2365 is a standalone pellet loss regulation covering operational prevention, Risk Management Plans, certification, and transport requirements. Most companies in the plastics value chain are subject to both, and this course covers them together.
I haven't measured my losses yet. Can I still report by May 2026?
Yes. The provided guidance allows extrapolating from a monthly measurement window. Module 6 walks you through this step by step — including how to select a representative measurement period, document your methodology, and submit an estimate to ECHA.
Are flakes and powders in scope, or just pellets?
Both regulations cover pellets, flakes, and powders. Under EU 2025/2365, the definition of "plastic pellets" explicitly includes all shapes: nurdles, granules, flakes, resins, cylinders, beads, powders, micro-powder, microspheres, and agglomerates — from both primary and secondary (recycled) origin.