October 16, 2019

Charles Herlinger
Chief Financial Officer
Orion Engineered Carbons S.A.
4501 Manolia Cove Drive, Suite 106
Houston, TX 77345

       Re: Orion Engineered Carbons S.A.
           Form 20-F for the year ended December 31, 2018
           Filed March 8, 2019
           File No. 001-36563

Dear Mr. Herlinger:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 20-F for the year ended December 31, 2018

Item 5. Operating and Financial Review and Prospects
A. Operating Results , page 47

1.    We note that you recognized material restructuring charges during the
last three fiscal
      years. Please expand your discussion and analysis to include the amount
of the anticipated
      future cost savings at the consolidated and reportable segment levels for
these activities,
      and whether the actual results were in line with the anticipated cost
savings. If the
      anticipated cost savings were not achieved as expected or will be
achieved in periods
      other than as expected, please disclose the reasons for the differences,
and the likely
      effects on future operating results and liquidity. Please refer to SAB
Topic 5:P.4 for
      guidance.
Consolidated Statements of Cash Flows of Orion Engineered Carbons S.A, page F-5

2.    We note your presentation in your statements of cash flows related to
"other assets and
 Charles Herlinger
Orion Engineered Carbons S.A.
October 16, 2019
Page 2
         liabilities that cannot be allocated to investing or financing
activities" which resulted in a
         net cash used from operating cash flows in 2018 of $48.7 million
compared to a net cash
         provided from operating cash flows of $26.7 million in 2017. The
impact on reported
         2018 operating cash flows approximates 40%. Please quantify for us the
changes in your
         balance sheet line items that are reflected in this line item. In this
regard, we note that the
         changes in your prepaid expenses and other current assets, Other
assets and Other current
         liabilities accounts did not materially change from the prior year
while your Other
         liabilities balance increased by approximately $26.5 million from the
prior year.
Note R. Financial Information by Segment and Geographic Area, page F-38

3.       We note from reading your Business Overview in Item 4 that you offer a
variety of
         products with different end user applications within your reportable
segments. Please
         explain what consideration you gave to disclosing revenues for each
product or each
         group of similar products. See ASC 280-10-50-40.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

      You may contact Ameen Hamady at 202-551-3891, or in his absence Al Pavot
at 202-
551-3738 if you have any questions.



FirstName LastNameCharles Herlinger                              Sincerely,
Comapany NameOrion Engineered Carbons S.A.
                                                                 Division of
Corporation Finance
October 16, 2019 Page 2                                          Office of Life
Sciences
FirstName LastName