Effective 5 November 2025, the European Chemicals Agency (ECHA) has increased REACH registration and authorisation fees by 19.5%. This change results from Commission Implementing Regulation (EU) 2025/2067, which updates Regulation (EC) 340/2008 (the “REACH Fee Regulation”) to reflect inflation for 2021–2023 and to streamline how company size (SME status) is verified.
Impact on Businesses
If your company manufactures, imports, or uses substances covered by REACH registration or authorisation requirements you need to:
- Review Commission Implementing Regulation (EU) 2025/2067 to understand the updated fees and new SME verification procedures.
- Prepare for higher ECHA fees from 5 November 2025 if your company is not an SME.
If your company is an SME, ensure you apply for SME recognition well in advance (at least two months before submitting your dossier or application). This ex-ante verification process will apply from 5 February 2027.
Higher REACH Fees
From 5 November 2025, large companies must pay 19.5% higher fees when they:
- Submit or update a REACH registration dossier; and/or
- Submit or review a REACH authorisation application.
Micro, small, and medium-sized enterprises (SMEs) are exempt from this 19.5% increase.
Revised SME Verification Process
From 5 February 2027, SMEs that wish to benefit from reduced REACH fees must:
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- Apply for SME status recognition at least two months before submitting their dossiers or applications to ECHA.
- Provide supporting documentation for ECHA’s verification.
ECHA will have two months to confirm SME status, which will then remain valid for three years. Until that date, SMEs must continue to self-declare their size when submitting REACH dossiers.
SME Definition
Under Commission Recommendation 2003/361/EC, an SME is an enterprise that:
- Employs fewer than 250 people; and
- Has an annual turnover of up to EUR 50 million and/or an annual balance sheet total of up to EUR 43 million.
ECHA provides detailed guidance on how to determine company size.
Additional Resources
