According to the European Commission’s new REACH Fee Regulation, micro, small, and medium-sized firms (SMEs) seeking lower costs for their REACH applications will soon be forced to go through an ex-ante company size validation process.

This substantial shift requires that SMEs apply for business size validation at least two months before submitting their REACH registration or permission dossiers. This new requirement of SME Validation for REACH becomes effective on February 5, 2027.

ECHA Verification and Timing

• Once the appropriate evidence is obtained, the European Chemicals Agency (ECHA) has two months to validate the SME status. Companies should submit for validation as soon as possible to ensure their status is validated before the submission deadline and to provide time to respond to any requests for further information from ECHA.
• A company’s application may be delayed if it is not submitted on time; if ECHA does not accept the applicant’s SME status, an administrative fee determined by the Management Board of ECHA may be assessed.
• A SME status that has been approved will be valid for three years in order to reduce the administrative burden. A self-declaration may be used for the initial status renewal as long as it is started two months prior to the three-year validity period ending.

Fee Increase for Large Companies

The revised Regulation also includes a 19.5% rise in normal fees and levies for major businesses. This rise takes effect on November 5, 2025, and represents Europe’s average yearly inflation rate from 2021 to 2023. Importantly, this tax increase only applies to large businesses, protecting the competitiveness of SMEs.

Timeline and Guidance of SME Validation for REACH

The new REACH Fee Regulation, adopted by the European Commission on October 15, 2025, takes effect on the twentieth day after its publication in the Official Journal of the European Union.

The new ex-ante verification process for SMEs will commence 15 months after the Regulation goes into effect (February 5, 2027). Until then, the present SME verification process is still in effect.

ECHA has indicated that it would progressively provide further information to help firms prepare their SME Validation for REACH requests.