SMEs Must Apply for REACH Company Size Validation Before Submitting Dossiers
The European Commission has introduced major changes to the REACH Fee Regulation. Under the new rules, small and medium-sized enterprises (SMEs) must apply for REACH company size validation before submitting their dossiers. This requirement ensures that only verified SMEs can benefit from reduced REACH fees.
From 5 February 2027, all SMEs planning to submit REACH registrations or applications for authorisation will need to obtain company size validation at least two months before submission. The European Chemicals Agency (ECHA) will manage this verification process.
Once a company submits its documentation, ECHA will have two months to confirm the SME status. To avoid delays, companies are advised to apply for REACH company size validation well in advance. This gives them time to respond to possible requests for additional information.
If ECHA does not confirm SME status, the applicant may face an administrative charge. The level of this charge is determined by ECHA’s Management Board.
To simplify future submissions, validated SME status will remain valid for three years. If a company’s size remains unchanged, it may renew its validation through self-declaration. This simplified renewal must be initiated two months before the original validity period expires.
The revised Regulation also increases standard fees and charges by 19.5% for large companies. This adjustment reflects the average European inflation rate between 2021 and 2023. Importantly, the increase will not apply to SMEs, helping to protect their competitiveness in the EU market.
The updated fees will take effect on 5 November 2025. ECHA plans to publish detailed guidance to support companies in preparing their SME validation applications ahead of submission deadlines.
Background
The revised REACH Fee Regulation was adopted by the European Commission on 15 October 2025. It enters into force 20 days after publication in the Official Journal of the European Union. The new ex-ante company size verification will become mandatory 15 months later. Until then, the current SME verification process will continue to apply.
By acting early on REACH company size validation, SMEs can secure reduced fees and avoid costly delays in their compliance journey.
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Source: ECHA
