Q&A info

ECHA does not carry out an economic activity within the meaning of Directive 2006/112/EC on the common system of value added tax. This means that no VAT has to be paid on the fees defined in Regulation (EC) No 340/2008 ('the REACH Fee Regulation'). For the reason above, ECHA has no VAT number and ECHA's invoices are exempt from VAT. ECHA's Finnish Business ID number is 2139942-8 and it is always mentioned on ECHA's invoices. However, this number is not a VAT number.

Thus it is important to note that ECHA is unable to provide registrants a VAT or a withholding tax / tax at source residence certificate. As ECHA has no tax residence in any Member State. In Q&A 739 ECHA has published a financial identification form confirming its Finnish business ID.

For any enquiry, please contact ECHA by using the ECHA Helpdesk contact form.

The registration fee for a substance depends on the tonnage of the registration, size of the company and the type of submission. Additionally:

• Lower fees apply to joint submissions as compared to individual submissions. This does not apply in case you decide to opt-out of the joint submission;
• SMEs benefit from a reduced fee in all categories;
• An additional fee is levied for confidentiality.

No fee is required for the registration of substances if you are entitled to a fee waiver. Further information related to the fee waiver can be found under Q&A 1237.

All these provisions are specified in Articles 12(1)(a) and 74 of REACH, taking into account Recital 34 of the regulation. The fee amounts can be found in the REACH Fee Regulation (No. 340/2008, and subsequent amendments).

Further information can be found under Invoicing and Payments..

Fee amounts are specified in the Commission Implementing Regulation (EU) No 2018/895 of 22 June 2018 amending Regulation (EC) No 340/2008 on the fees and charges payable to the European Chemicals Agency ("the REACH Fee Regulation").

Information related to the chargeable confidentiality claims can be found in the manual “Dissemination and Confidentiality under the REACH Regulation”, chapter 3.5.

ECHA encourages to run the Fee calculator plugin before submitting the IUCLID dossier in REACH-IT. A potential fee mismatch will enable you to identify and correct a mistake in your dossier before the submission.

The timelines for payment of fees levied under the REACH Regulation are specified in the REACH Fee Regulation as subsequently amended by the Commission Implementing Regulation (EC) No 340/2008 and its subsequent amendments (see Q&A 716) and the precise payment due date is set out in ECHA's invoice.

Fees invoiced for initial and update registrations

In the case of fees for registrations submitted, as well as in the case of updates of a registration, the initial payment due date of the fee is set at 14 calendar days from the date on which the invoice was notified to you. 

If the payment has not been made within the prescribed period (by the initial payment due date), ECHA will set a second deadline for payment. This second deadline (extended payment due date) is 60 calendar days from the initial payment due date.

If the payment is not made by the extended payment due date, the registration fails the completeness check and will be rejected.

For updates of a registration unrelated to tonnage band changes, the registrant has the possibility to request a further extension of the second deadline for fee payment before its expiry. In practice, this request for extension of the second deadline for payment applies only to:

• Fees levied for new chargeable confidentiality claims included in updates;
• Fees levied as a consequence of a legal entity change.

The request for extension should be submitted before the expiry of the second deadline via the ECHA Helpdesk using the contact form.

If the payment is not made by the deadline of the extension, the update fails the completeness check and will be rejected.

Fees invoiced (PPORD) exemptions and for requests to extend PPORD exemption.

Fees for notification of PPORD exemptions: the initial payment due date of the fee is 7 calendar days from the date on which the invoice was notified to you. Requests to extend a PPORD exemption: the initial payment due date of the fee is set at 30 calendar days from the date on which the invoice was notified to you.

If the payment has not been made within the prescribed period (by the initial payment due date), ECHA will set a second deadline. This second deadline (extended payment due date) is 60 calendar days from the initial payment due date.

Where the payment is not made by the expiry of the second deadline, the notification or the request for an extension will be rejected.

Fees invoiced for Legal Entity Change (LEC)

Fees for Legal Entity Change: the initial payment due date of the fee is 14 calendar days from the date on which the invoice was notified to you.

If the payment has not been made within the prescribed period (by the initial payment due date), ECHA will set a second deadline. This second deadline (extended payment due date) is 30 calendar days from the initial payment due date.

Where the payment is not made by the expiry of the second deadline, the Legal Entity Change will be rejected.

Fees invoiced for Applications for Authorisation (AfA)

Fees for Application for Authorisation: the initial payment due date of the fee is 14 calendar days from the date on which the invoice was notified to you.

If the payment has not been made within the prescribed period (by the initial payment due date), ECHA will set a second deadline. This second deadline (extended payment due date) is 7 calendar days from the initial payment due date.

Where the payment is not made by the expiry of the second deadline, the Application for Authorisation will be considered as not received by ECHA. In this case the application is not processed further. The only way to proceed is to re-submit the application. 

ECHA does not send confirmations of receipt of payment, but you can check the status of your payment in REACH-IT. Open the submission report and look at the “Submission processing steps” section; the "Financial completeness check" step will be green when your payment has been received and accepted by ECHA.

Please note that it may take several days before ECHA receives the payment depending on the payment method. A SEPA payment is transmitted within three bank business days.

A submission is subject to both a technical and a financial completeness check. Therefore, a fully paid invoice does not necessarily indicate an accepted submission of your REACH dossier.

When an invoice is cancelled (e.g. due to incorrect information on the invoice, such as billing information, company size, etc.), you will receive a credit note for the whole amount and, if needed, a replacement invoice. These electronic documents can be downloaded from your REACH-IT account in PDF format. If you receive two invoices and one credit note, the reference number you should indicate in your bank transfer is the reference number of the latest invoice.

If you pay an invoice for which ECHA later issues a credit note, the paid amount will be credited back to your company by either reallocating the received amount to another open invoice or refunding the amount to you.

Please be informed that ECHA doesn't provide any credit notes in case the invoice was not paid in full and your registration was rejected.

• Company name and address indicated by the registrant (or the billing details, if the tab "Billing company information" was filled in by registrant);
• Customer ID number (= Legal entity UUID);
• DUNS number and VAT number (if provided by the registrant);
• Purchase order number (if provided by the registrant when submitting the dossier or when accepting a legal entity change).

If your invoice has not been paid yet, ECHA will be able to cancel it and create a new one with your updated company information. If the invoice has already been paid, ECHA cannot modify the invoice.

ECHA is unable to update any company information in REACH-IT. It is the responsibility of the REACH-IT account owner within the company to make sure that the information is up-to-date.

To receive an invoice with updated company information update your information in REACH-IT. Go to Menu >> Manage Company >> Company information. Here you can modify and update your information by clicking on "Update" at the top right corner of the page. Always remember to save your changes. Additional information on how to update your company information can be found in the ECHA Accounts Manual for Industry Users.

After the company details have been updated, you need to contact the ECHA Helpdesk by using the contact form available on the ECHA website.

Company size information

If the changes in your company information are related to a change in the company size or to an incorrectly declared company size, please refer to the SMEs section on the ECHA website.

You are entitled to the fee waiver if:

1. Your substance is a phase-in substance and considered to be low risk (i.e. does not meet the Annex III criteria of REACH); and
2. You submit a standard registration dossier for 1-10 tonnes per year voluntarily providing the full set of information listed in Annex VII.

The fee waiver does not apply if:

• Your substance is considered to be low risk (i.e. does not meet the Annex III criteria) and you submit a registration dossier for 1-10 tonnes per year with only physicochemical information (listed in section 7 of Annex VII); or
• Your substance is not considered to be low risk (i.e. meets the Annex III criteria) and therefore, you must provide the full Annex VII information; or
• Your substance is a non-phase-in substance.

The above is based on REACH Regulation Articles 12(1)(a) and 74, taking into account Recital 34.

Important notes

In a joint submission, the tonnage band of the other member registrants does not influence the applicability of the fee waiver for your own dossier.

You need to actively claim the fee waiver in IUCLID to benefit from it – the system does not grant it automatically.

More information on the Annex III criteria and their applicability can be found here.

When submitting a dossier or accepting a legal entity change, you are able to indicate your own internal purchase order number in the third step of your dossier creation wizard (see screenshot). The indicated purchase order will be linked to the invoice issued for the dossier submission or the legal entity change.

For the submission report or an already issued invoice, it is not possible to add any forgotten purchase order number aor modify it afterwards.

As you register online in REACH-IT you should not send any purchase orders by ordinary mail or email to ECHA. Please make sure that your system does not send any purchase orders automatically to ECHA. Your purchase order is only for your internal purposes. ECHA will not confirm your internal purchase order or provide information to or access third party platforms for handling your purchase orders.

Bank transfer is the only accepted payment method. Other types of payment, such as cheque, banker's draft or cash, are not accepted by ECHA.

Payments should be executed in Euros only and it must be ensured that the full amount of the invoice is received by ECHA. Deductions of bank charges, from exchange rate differences or of any other costs will lead to an underpayment of the invoice.

The following bank details are indicated on all invoices issued under the REACH Regulation as from 01.07.2019:

Bank: 		ING Belgium, Avenue Marnix 24, 1000 Brussels, Belgium

IBAN: 		BE93 3631 8789 1767

BIC/SWIFT: 	BBRUBEBB

Please note that separate instructions for the payment of Appeal Fees exist. These are explained in the relevant section of the Board of Appeal on ECHA's webpage.

In the payment instruction, the invoice number should be indicated as the reference number. According to Article 17(1) of the REACH Fee Regulation (EU) No340/2008, in its latest version (see Q&A 716), every payment must indicate the invoice number. Thus, in the free text message/communications or reference field of the payment you should indicate only the payment reference indicated on the invoice. It is comprised of eight digits and you will find it next to ECHA's bank details on the invoice. This is very important, as your payment is automatically processed by REACH-IT. Please instruct your accounts payable/payments department and your bank accordingly.

Where the payment of a fee is not made by the extended payment due date or by the extension of the second deadline, the submission will be rejected or deemed not to be received. In the above mentioned cases, a rejection due to non-payment is not related to the status of the technical completeness check (TCC). Your submission will be rejected regardless of a given prolonged deadline to fulfil information requirements by submitting further information.

Furthermore, if your submission is rejected, the REACH Fee Regulation (EU) No340/2008, in its latest version (see Q&A 716), stipulates that the fees paid in relation to that submission before its rejection shall not be refunded or otherwise credited to you. After you have received the rejection letter, you are able to start your submission process from the beginning.

Since 1 November 2009, a SEPA payment must be transmitted within three banking business days. The bank statement of any given day is available to ECHA only on the next banking business day.

Therefore, it normally takes up to five banking business days before ECHA can handle your payment and confirm the invoice as paid in REACH-IT. Please note that the handling time may be longer if your payment cannot be dealt with automatically. By following ECHA's instructions regarding payments you can significantly reduce ECHA's handling time of your payments (see Q&A 721).

On the basis of the daily electronic bank statement, REACH-IT automatically matches your payment with your open invoice if you have indicated the correct payment reference (invoice) number in your payment message and you have paid the correct amount. An additional condition is that you pay each invoice separately as a single payment. One bank transaction per invoice therefore ensures the fast registration of your payment.

ECHA strongly advises you not to pay two or more invoices in the same transaction ("multiple invoice payment"). If you however include more than one invoice in the payment, please make sure that the invoice references are mentioned in full. Otherwise, the payment has to be manually handled by ECHA's accounting department. This may delay the processing of the payment and thus also the overall completeness check of your registration. If, for some reason, you cannot avoid sending multiple invoice payments and you are unable to indicate the full reference numbers in the payment, please make sure to follow the instructions in Q&A 732, which describes the sending of payment advices.

1. Pay one invoice per transaction (single payment);
2. Indicate the correct reference number (eight digit invoice number);
3. Ensure the invoiced amount is paid in full (no charges or exchange rate differences);
4. Instruct your bank to send a SEPA payment with shared cost.

• Legal entities
• Financial identification

All the information you need for proceeding with the payment is visible in the invoice itself. However, depending on your internal administrative procedures, it is advisable that your accounting/accounts payable department is prepared for the payment of ECHA's invoices.

We therefore recommend that you set up ECHA's bank account information in the accounting system well in advance of the first invoice's due date.

PLEASE NOTE OUR NEW BANK DETAILS SHOWN ON INVOICES AS FROM 01 JULY 2019.

On 01 July 2019 ECHA changed the bank account details shown on its fees and charges invoices. The Agency’s new house bank is ING Belgium NV. ECHA’s new financial identification form (see attachment) covers all the details needed for this new bank account.

If you use an external accounting company, please ensure that all required information about ECHA and REACH is passed on, in order to ensure the smooth handling of ECHA's invoices. It is also advisable that you ensure beforehand that there are no misunderstandings related to ECHA's status as an EU body which is exempt from any national tax or any value added tax. Please refer to Q&A 725 and Q&A 726.

Please make sure that the persons handling the payments of ECHA's invoices are aware that the payment should be made at the full amount so that any possible bank charges are not deducted from the payment.

Please inform your accounting department that if the invoice is paid after the extended due date, the REACH dossier submission will be rejected and the paid fee will not be refunded.

Please ensure that ECHA’s invoice number is stated in the payment instruction (see Q&A 721).

ECHA’s New Financial Identification Form (PDF)