ECHA to Introduce SME Verification for REACH: What Small Businesses Need to Know

As part of the changes being made to the REACH Fee regulation EC 1907/2008 small and medium-sized enterprises (SMEs) registering substances under the REACH regulations will need to verify their SME status before submission.
This change, introduced by the European Chemicals Agency (ECHA), aims to make fee reductions fairer and improve transparency — but it also introduces new administrative steps for companies.

 

What Is SME Verification Under REACH?

Under current REACH rules, SMEs can receive registration fee reductions of up to 95%, depending on company size. Until now, companies could self declare their size, paya reduced fee and ECHA would confirm the classification retrospectively.

The upcoming regulation changes this process. SMEs will now be required to verify their status at least two months before submitting a REACH application. This proactive verification ensures that companies know their applicable registration fee before proceeding.

SME Classification Criteria

A company’s size is determined by its headcount and financial thresholds under EU definitions:

SME verification process

How the New Verification Process Works

Under the new system, companies will submit a verification application to ECHA at least two months before a REACH registration. An administrative fee may apply, but it will be waived if SME status is confirmed. If verification is rejected, the applicant must pay both the verification fee and the full regulatory fee.

Verification results will be valid for three years, and the same confirmation can be used as proof of SME status under other regulations, such as the Biocidal Products Regulation (BPR).

Advantages and Challenges for SMEs

Key Benefits

  • Financial certainty –  application fees known before registration.
  • Cross-regulatory recognition – verified SME status valid for BPR submissions too.

Key Challenges

  • Additional administration – SMEs must prepare and submit verification forms early.
  • Potential delays – while verification should take up to two months, it’s unclear whether ECHA will consistently meet this timeframe.
  • Extra costs – if status is denied, both verification and full regulatory fees apply.

Overall, these changes are designed to reduce false declarations and lower the enforcement workload for ECHA, while giving companies more clarity over their regulatory costs.

Timeline for Implementation

The verification rules will apply 15 months after the updated fee regulation enters into force, giving businesses time to prepare. There is currently no information on when the fee regulation will be approved but it is expected to coincide with the updates to the main REACH Regulation. However, SMEs planning new REACH registrations should start assessing their eligibility now to avoid future delays.

How to Prepare for SME Verification

To stay ahead of the new process:

  1. Review your company size and financials against SME criteria.
  2. Gather supporting documentation early (e.g., accounts, employee numbers, ownership structure).
  3. Plan your REACH submissions to include at least a two month buffer for verification.
  4. Consult regulatory experts to confirm your classification and avoid unexpected fees.

Need support with SME verification or REACH registration?

👉 Contact our regulatory experts today to ensure full compliance and secure your fee reductions with confidence.