REACH: ECHA Updates Fees and Introduces New SME Verification Procedure under Regulation 2025/2067

Commission Implementing Regulation (EU) 2025/2067, published in the Official Journal of the European Union on 16 October 2025, amends Regulation (EC) No 340/2008 on the fees and charges payable to the European Chemicals Agency (ECHA) pursuant to Regulation (EC) No 1907/2006 (REACH).

The main updates include:

• Adjustment of fees based on the average inflation rate for 2021–2023, equal to 19.5%. This increase applies to standard fees but not to SMEs, in order to preserve their competitiveness.
• Introduction of an ex-ante verification of SME status: companies must submit a recognition request at least two months before applying for any procedure entitling them to a reduced fee. ECHA must issue a decision within two months of receiving complete documentation.
• Three-year validity of SME recognition, applicable to all subsequent applications submitted to the Agency under REACH or other EU legislation during that period. If company size remains unchanged, recognition may be renewed by submitting a self-declaration two months before the expiry date.
• Possibility for ECHA to introduce an administrative charge for SME verification, which will not apply if the recognition is confirmed.
• Overall update of Annexes I–VIII, redefining the fees for registrations, updates, authorisations, PPORD notifications, appeals and other procedures regulated under REACH.

The fee adjustment will enter into force on 5 November 2025, i.e. 20 days after publication, while the new provisions on SME verification and fee reductions will apply from 5 February 2027 - 15 months after entry into force.

The Regulation will not apply to ongoing valid applications at the time it enters into force.

ECHA has announced that additional information and guidance documents will be made available to support companies in preparing their SME verification requests. Further updates are therefore expected.