The new Commission Implementing Regulation (EU) 2025/2067 has been published, in which the amendment to REACH Fee Regulation (EC) No 340/2008 was outlined. This update introduces two major changes that will affect businesses differently depending on their size and registration status.
The most immediate impact is a 19.5% increase in standard REACH registration fees for companies without verified SME status, effective from 5th November 2025, as below:
| Tonnage Band | Current joint submission fee (EU) | Updated joint submission fee (EU) | Current individual submission fee (EU) | Updated individual submission fee (EU) |
| 1-10 tonnes/year | 1,304 | 1,558 | 1,739 | 2,078 |
| 10-100 tonnes/year | 3,506 | 4,190 | 4,674 | 5,585 |
| 100-1000 tonnes/year | 9,376 | 11,204 | 12,501 | 14,939 |
| 1000+ tonnes/year | 25,274 | 30,202 | 33,699 | 40,270 |
A second important change is that SMEs (Small to Medium Enterprises) need to verify their status with ECHA before a registration dossier is submitted. This change will come into effect on 5 February 2027, allowing a transition period for businesses to adapt.
After granting, SME status is valid for 3 years. If SME status is denied, an administrative fee will apply. Applications for SME status must be submitted to ECHA at least 2 months before any dossier submission. If eligible, if is advised to gather the documentation early on.
The new fees regulation can be found at EUR-Lex:https://eur-lex.europa.eu/eli/reg_impl/2025/2067/oj/eng
Linmark Consulting provides services in EU Reach registration and Only Representative. Through its UK company, Linmark Consulting assists with UK-REACH strategy and submission of DUINs (Downstream User Import Notifications).