EU Adopts New Regulation Revising REACH Fees and SME Verification

On 15 October 2025, the European Commission adopted Implementing Regulation (EU) 2025/2067, amending Regulation (EC) No 340/2008 on the fees and charges payable to the European Chemicals Agency (ECHA) under REACH. The regulation was published in the Official Journal of the European Union the following day. It introduces two major reforms: an inflation-based adjustment to standard REACH fees and a new system for verifying Small and Medium-sized Enterprise (SME) status.

Fee Adjustments

The amendment introduces a 19.5 % increase in standard REACH fees, reflecting the cumulative inflation recorded since 2021. This update ensures that the fees paid to ECHA continue to cover the costs of registration, evaluation, and other administrative processes under REACH.
However, in line with the European Commission’s SME Relief Package and the 2024–2029 Political Guidelines, small and medium-sized enterprises (SMEs) are excluded from this adjustment. The exemption is intended to maintain a fair balance between administrative sustainability and the financial capacity of smaller companies.

The exact fee amounts for each registration type and company size can be found in Implementing Regulation (EU) 2025/2067 which is available here.

New Approach to SME Status Verification

The amendment introduces a change to how ECHA verifies SME eligibility. Rather than reviewing SME claims after submission (the current ex post approach), ECHA will now verify SME status in advance (ex ante).

Under the revised system, companies wishing to benefit from reduced fees must obtain SME recognition before submitting their dossiers. This request must be submitted no later than two months before the intended submission date. Once granted, SME status will remain valid for three years and will cover all applications made during that period.
ECHA may charge an administrative fee to process SME recognition requests, but this fee will be waived if the company’s SME status is confirmed.

Implementation and Transition Period

The revised fee structure and the new verification system will both take effect from 5 February 2027, giving companies a 15-month transition period to align their internal procedures. These changes aim to enhance predictability, ensure the fair application of SME reductions, and reduce the administrative burden on registrants and ECHA alike.