Key takeaway
What This Development Means
The EU’s Implementing Regulation (EU) 2025/2067 raises REACH fees by 19.5% from November 2025 and introduces pre-submission SME verification from February 2027. SMEs are exempt from the increase but must apply for recognition in advance. Companies should review costs, timelines, and verification readiness.
When does Implementing Regulation (EU) 2025/2067 take effect?
The Regulation enters into force on **5 November 2025**. However, the new ex ante SME verification system will apply from **5 February 2027**, allowing a 15-month preparation period for companies and industry associations to adjust to the new process.
How does the new SME verification affect REACH compliance?
SMEs must apply for recognition two months before any REACH submission to qualify for reduced fees. ECHA’s decision will remain valid for three years and can be reused. Firms failing to secure recognition in time will need to pay the full standard fee.
Source basis: https://eur-lex.europa.eu/eli/reg_impl/2025/2067/oj
The European Commission has adopted Implementing Regulation (EU) 2025/2067, updating the fees and charges payable to ECHA under REACH. The Regulation, which enters into force on 5 November 2025, introduces a 19.5% fee increase for standard registrants, while small and medium-sized enterprises (SMEs) remain exempt. It also replaces ECHA’s ex post SME verification with a mandatory pre-submission (ex ante) system starting 5 February 2027.
REACH Fee Increase And Financial Sustainability
The European Commission said the change aims to improve ECHA’s long-term financial sustainability after declining fee income since the final registration deadline in 2018. Standard REACH fees are now adjusted in line with cumulative inflation rates for 2021–2023. For example, the base fee for an individual registration in the 1–10 tonne range is set at EUR 2,078, while fees for authorisation applications start at EUR 64,650.
SMEs remain protected from the inflation-based adjustment. Reduced fees for medium, small, and micro enterprises continue to apply under Commission Recommendation 2003/361/EC.
From Ex Post To Ex Ante SME Verification
ECHA’s SME verification process will move from retrospective checks to advance validation. Companies claiming SME reductions must apply for official recognition at least two months before submission. ECHA will decide within two months of receiving complete documentation, and its decision will remain valid for three years.
An administrative charge may be introduced to cover verification costs but will be waived when SME status is confirmed. Temporary fee reductions may be granted if a decision is pending, though full fees will be recovered if the SME claim is later rejected.
Transition Timeline And Next Steps
The Regulation takes effect on 5 November 2025, but the new SME verification provisions will only apply from 5 February 2027, providing a 15-month transition period. Pending submissions made before entry into force are unaffected.
The Commission advises companies to prepare early by aligning internal processes with the new timeline, budgeting for higher registration and authorisation costs, and planning SME recognition applications well ahead of 2027 submissions.
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