What to do if you incorrectly indicated the SME size category

Follow these instructions if you realise that you have indicated in REACH-IT the incorrect size category of your company (or the company that you represent as an Only Representative) and that you have confirmed that incorrect SME category when submitting registrations, updates or notifications:

Prior the initiation of an SME verification procedure by ECHA

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Inform ECHA about the incorrect indication of the company size category by filling in the 'Helpdesk contact form'. After having entered your contact details, please choose the topic option ‘I have a question related to the dossier submission to ECHA... ', fill the required fields and indicate the correct submission number. Make sure that you now declare the correct company size. If you have several submissions, indicate all those that are affected by this size category update.

ECHA Helpdesk contact form

 
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After you have informed ECHA about the incorrect company size category as specified in point 1 above, you will receive a communication followed by new invoice(s) via your REACH-IT account. You will also receive a credit note which cancels the original invoice sent to your REACH-IT mailbox. Please pay the new invoice(s) corresponding to the revised company size by the due date indicated in the new invoice(s).

 

If you proceed according to the above instructions, you may avoid the levy of an administrative charge. ECHA does not levy an administrative charge where registrants rectify their incorrect size category declarations in writing to the Agency prior to the initiation of the SME verification procedure by ECHA.

Important: Updating the company profile in REACH-IT will not suffice to avoid the administrative charge.

Remember, once ECHA has contacted you to verify the declared SME category, an administrative charge will be levied in addition to the balance of the accurate fee corresponding to the revised company size category for all submission(s) covered by the SME verification procedure, provided that the SME verification results in the finding that the size category of the company is larger than the one indicated at the time of the submission(s).

It is recommended to keep the profile of your company or the company that you represent as an Only Representative updated in REACH-IT at all times in order to avoid an incorrect invoice for future submissions.

After the initiation of an SME verification procedure by ECHA

As soon as ECHA contacted you to verify the declared SME category, an administrative charge will be levied in case that the SME verification results in the finding that the size category of the company is larger than the one indicated at the time of the submission(s). In addition, you will be invoiced the balance to the full fees that correspond to the correct company size category for all submission(s) covered by the SME verification procedure.

However, in accordance with the amendments to ECHA Management Board Decision MB/D/29/2010, on the classification of services for which charges are levied, as introduced by the Management Board Decision MB/21/2012/D, companies which correctly rectify their company size after being first contacted by ECHA can benefit from a 50 per cent reduction of the applicable administrative charge. Thus, in case you receive the letter from ECHA on the initiation of the SME verification procedure and you realise that you declared and confirmed the size of your company incorrectly, please do the following to benefit from the reduction:

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Declare the correct company size by filling in the Declaration of wrong size (enclosed to ECHA's letter initiating the verification of your company's entitlement to SME fee reductions).

 
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Send the duly completed and signed Declaration of wrong size to ECHA within 21 calendar days of the date of the abovementioned letter, either by e-mail to sme-verification (at) echa.europa.eu or by mail or courier to the following address:


ECHA R1-Finance - SME verification,
Annankatu 18,
P.O. Box 400,
FI-00121 Helsinki

 
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In addition, if you update your company size to a non-SME (Large) you do not need to provide ECHA with any additional documents, other than the duly completed Declaration of wrong company size. However, if following this Declaration, the updated company size is still within the SME categories (i.e. update from micro to small, micro to medium, or small to medium size category), you are still required to send documents demonstrating the updated SME status.

 

Please note that if you submit your declaration of a wrong company size after the expiry of the time-limit set by ECHA, you will not be eligible for the 50 per cent administrative charge reduction.

It is recommended to keep the profile of your company or the company that you represent as an Only Representative updated in REACH-IT at all times in order to avoid an incorrect invoice for future submissions.

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