Please excuse my ignorance, but shouldn't EU OPS 1.375 (3) override company documents, no matter where?
- excused! You claim to be an 'ATPL in Germany' so I assume you know that Company Ops Manuals in EU land are REQUIRED to be written in accordance with EUOPS 1.375, and most companies will normally 'amplify' the guidance to para b) 3) as per slasher post #8, although NB there is no OFFICIAL system/procedure for the last scenario in that post? If yours is not, you need to get that changed PDQ before you lose your AOC.
If this helps you, it is really very simple and has been posted here an
amazing number of times:
You KNOW you will be landing below Final reserve - Mayday
You THINK you will be landing below Final reserve under the existing circumstances - Pan
You are getting anxious about your position in the queue and tell ATC you are beginning to worry - they will probably ask "Are you declaring an emergency"? - at which point YOU make the decision.