On 25 July, 2025, the European Commission is set to hold a final vote on amendments to the REACH Regulation administrative fees by 30 August 2025. If passed, the revised regulation will take effect 20 days after publication in the EU Official Journal.
Legislative Context
The draft proposal highlights that after the 2018 REACH registration deadline, ECHA’s registration revenue has “plummeted and become unpredictable,” while its scientific evaluation and technical support workload continues to grow. The European Court of Auditors, European Parliament, and Council have all raised concerns about the inefficiency and inaccuracy of the current SME (Small and Medium-sized Enterprise) verification mechanism, describing it as “cumbersome, time-consuming, and prone to unfair competition.”
Key Amendments
1. Across-the-Board Registration Fee Increases
Based on the European Commission’s review, standard fees will be adjusted according to the cumulative 19.5% inflation rate (average annual inflation from 2021–2023 per Eurostat data). To align with the EU’s 2024–2029 Political Agenda and SME Relief Plan, SMEs will be exempt from the inflationary adjustment to maintain competitiveness. Key fee adjustments:
Table 1: Adjusted Registration Fees (19.5% Increase)
Individual Submission |
Joint Submission |
|
1–10 tonnes |
€2,078 |
€1,558 |
10–100 tonnes |
€5,585 |
€4,190 |
100–1,000 tonnes |
€14,939 |
€11,204 |
Over 1,000 tonnes |
€40,270 |
€30,202 |
Table 2: SME Fee Reductions (Unchanged)
Medium (Ind.) |
Medium (Joint) |
Small (Ind.) |
Small (Joint) |
Micro (Ind.) |
Micro (Joint) |
|
1–10 tonnes |
€1,131 |
€848 |
€609 |
€457 |
€87 |
€65 |
10–100 tonnes |
€3,038 |
€2,279 |
€1,636 |
€1,227 |
€234 |
€175 |
100–1,000 tonnes |
€8,126 |
€6,094 |
€4,375 |
€3,282 |
€625 |
€469 |
Over 1,000 tonnes |
€21,904 |
€16,428 |
€11,795 |
€8,846 |
€1,685 |
€1,264 |
2. Pre-Application SME Verification
To streamline SME eligibility checks and ensure fairness, the draft introduces:
- Mandatory pre-application: Companies must request SME status at least two months before submitting registration dossiers.
- Three-year validity: Approved SME status applies to all EU regulatory submissions for three years.
- Review fee refund: ECHA may charge an administrative fee for SME applications but must refund it if status is granted.
- 15-month transition period: The new rules will take effect 15 months post-adoption.
ChemRadar Insights
As early as February this year, CIRS Group successfully predicted a 19.5% increase in EU REACH registration administrative fees based on ECHA's annual report. The proposal has now entered the final voting stage. Considering the recent 19.5% fee adjustment under EU BPR regulations, this voting is highly likely to be approved. If passed, there is expected to be approximately two months' grace period (subject to official EU publication date). Drawing from the latest BPR fee adjustment experience, the earliest possible effective date for the new regulation could be November.
EU REACH registration typically requires about 3 months, with data negotiation with Lead Registrants constituting a significant portion. Recently, CIRS Group has received multiple LR letters while relevant responsible personnel are undertaking intensive leave arrangements, which may delay the acquisition of LoAs (Letter of Access). This will directly extend enterprises' registration timelines. To avoid additional administrative costs under the new fee structure, companies should aim to complete registrations before the regulation takes effect. CIRS experts strongly recommend initiating registration processes immediately. Please feel free to contact us for any further clarification.
Further Information