ECHA Introduces Mandatory SME Verification for Reduced REACH and CLP Fees

The European Chemicals Agency (ECHA) has announced a significant change to the way small and medium-sized enterprises (SMEs) access reduced fees under the REACH and CLP Regulations.

From 5 February 2027, companies wishing to claim SME fee reductions for REACH registrations and authorisation applications will be required to complete a new ex-ante company size verification process before submitting their dossiers. The change is being introduced through amendments to the ECHA fee framework and represents a shift away from the current approach, where company size is verified after submission if required.

What is Changing?

Under the new system, SMEs must first apply to ECHA for confirmation of their company size status before they can benefit from reduced fees.

The application must be submitted at least two months before the intended dossier submission date and must include supporting documentation demonstrating the company’s size classification. ECHA recommends applying as early as possible to allow sufficient time for any requests for additional information.

Documentation is expected to include:

Employee headcount data
Annual turnover information
Balance sheet figures
Details of linked and partner enterprises

This information will be used to determine whether a company qualifies as a micro, small or medium-sized enterprise under the relevant EU criteria.

How Will the Process Work?

Once ECHA has received all required information, the Agency intends to complete the assessment within two months.

Where SME status is confirmed, the decision will remain valid for three years, meaning companies will not need to reapply for each REACH or CLP submission during that period.

Importantly, the change does not alter the SME fee reduction structure itself. Instead, it introduces an additional administrative step that companies will need to factor into regulatory planning and submission timelines.

Why Does This Matter?

For many businesses, particularly SMEs and Only Representatives managing future REACH registrations or authorisation applications, the new process will require greater forward planning.

Organisations that fail to obtain verification in sufficient time may face delays in dossier submissions or risk being unable to claim the reduced fees available to qualifying SMEs.

Businesses planning regulatory activities during 2027 and beyond may therefore wish to start reviewing corporate structure information and gathering supporting financial and organisational documentation well in advance.

ECHA Webinar Scheduled

To support implementation of the new requirements, ECHA will host a webinar on 5 November 2026. The session will explain:

How the new verification process works
The documentation that companies will need to provide
How to use ECHA’s application tools
Common issues that can delay verification
Sources of additional guidance and support

What Should Companies Do Now?

Although the new requirements do not take effect until February 2027, companies expecting to submit REACH registrations or authorisation applications should begin preparing now by: