The EU REACH Fee Regulation has been revised and will enter into force on 5 November 2025. It brings two major changes:
1. Increased fees and charges for large companies
Effective immediately, from 5 November 2025, standard fees and charges for large companies will increase by 19.5%, reflecting a cumulative inflation rate in Europe over 2021-2023 (prior to the revision process). The adjustment of fees aims to support the financing model of the European Chemicals Agency (ECHA) in a way that, when combined with other sources revenue, the cost of the services delivered by ECHA are sufficiently covered.
The updated Regulation will not apply to valid submissions that are pending on the date of its
entry into force. Therefore, if your company is in the final steps of submitting a REACH Registration, a legal entity transfer, or another submission subject to a fee – we recommend considering if the
submission can be made before the changes take effect.
2. Ex ante SME verification process: a pre-requisite for claiming reduced fees
Starting from 5 February 2027, micro, small, and medium-sized enterprises (SMEs) will have to
apply for company size verification before submitting their REACH registrations or other
applications to benefit from the reduced fees. The fees for SMEs will not be increased.
Companies claiming to qualify as SMEs will have to apply for company size validation at least two months before submitting their dossiers. ECHA will have two months to verify the SME status and issue a decision – a positive decision will be valid for three years and applicable to all submissions during that time. If the company’s size remains unchanged, the first renewal of the SME status can be done by self-declaration, if it is initiated two months before the validity expires.
If an applicant’s SME status is not supported during the validation, an administrative charge may be imposed. ECHA will publish support material to help SMEs prepare for their company size validation closer to the time.
We advise companies who consider they qualify as SMEs to review the latest guidelines and prepare for the company size verification as early as possible, to allow sufficient time for gathering supporting documents and processing and enable timely submissions with the reduced fees. H2 Compliance’s team will be happy to help you navigate a changing SME process.