REACH24H Consulting Group

This confession is to be done via the Helpdesk webform, as described on the SME web pages on ECHA's website. The registrant will then receive the invoice for the difference up to the correct fee level. Please take care that updating the company profile only in REACH-IT will not suffice to avoid the administrative charge.

Background Information

Under both the REACH and CLP Regulations, small and medium-sized companies (SMEs) benefit from fee reductions depending on their size as a medium, small or micro-sized enterprise.

A company's qualification as an SME is determined by the Commission Recommendation 2003/361/EC. The headcount and financial figures of the legal entity as well as those of partner and linked enterprises are determinant in this regard. Only Representatives (ORs) should be aware that the assessment of whether the fee reduction for SMEs applies will not be based on their figures but on the figures of the non-EU enterprise that is represented by that OR, including information of linked and partner enterprises. In REACH Fee Regulation (EC) No 340/2008 specific provisions are formulated to ensure fair competition and the equal treatment of all registrants.

ECHA has started in 2010 to verify the size category of the companies that have claimed to be eligible for SME fee reductions and subsequently have paid reduced fees. However, the results of last year’s verifications show a high proportion of the examined companies did not qualify for the SME. Companies are therefore invited, once again, to check the company size category they have declared when submitting their registration(s). Once a registrant has been contacted by ECHA to verify the declared SME status, it is no longer possible to avoid the administrative charge if they made a mistake in their company size category.

Later this year, ECHA will host a webinar on the definition of SMEs and its implications under REACH and CLP.

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