SME registrants: Be ready to prove your company size

ECHA/NA/17/22

Small and medium-sized companies (SMEs) registering their substances under REACH benefit from a reduced registration fee. However, they have to be able to prove their SME size upon ECHA’s request.

Helsinki, 25 September 2017 – Under the REACH and CLP regulations, SMEs benefit from notable fee reductions, even up to 95 %. They need to claim this fee reduction when they submit a dossier through REACH-IT, and will consequently be invoiced the reduced fee for their SME size category.

To ensure equal and fair treatment for all registrants, ECHA needs to verify the eligibility to such fee reductions (SME verification). Currently, ECHA is checking the size of SME registrants who submitted their dossiers in 2013-2015.

For the verification concerning the paid fees, ECHA requests documentary evidence from the companies proving their declared SME size. ECHA sends these requests only through the dossier submission and communication tool REACH-IT and gives a deadline by which the documents must be delivered. It is important that companies regularly check their REACH-IT accounts for any messages and tasks from ECHA, keep their contact details up-to-date and react to ECHA’s requests.

If the registrant does not provide the requested documents by the deadline set by ECHA, it is considered non-eligible for the fee reduction. ECHA then invoices the difference between the SME fee already paid and the fee for a large enterprise to the company. In addition, the company has to pay an administrative charge.

Registrants can themselves proactively correct their size category after submission by declaring the correct size to ECHA’s Helpdesk and by updating their REACH-IT accounts accordingly. Companies are advised to assess their company size covering all relevant linked and partner enterprises. If they correct their size category before ECHA starts its verification procedure, the company does not have to pay any administrative charge, but only the difference up to the correct fee level. If they admit their mistake by the given deadline, they only have to pay half of the administrative charge.

Finally, as of June 2016, SME registrants have to upload documentary evidence supporting their entitlement to the fee reductions in REACH-IT before submitting their registrations. For earlier SME registrants, the evidence is requested by ECHA at the time of the verification.

Background: results of previous verifications

The past years’ verifications show that a high proportion of companies did not in reality qualify for the SME fee reductions. Until 2013, 32 % of dossiers had claims for SME fee reductions. However, after ECHA’s verification, only 18 % actually were entitled to these reductions. See graphs below.

Proportion of SMEs and large enterprises, as claimed by registrants, until 2013 (left). Actual proportion of SMEs after ECHA’s verification (right).