Occupational Hygiene Posts

Is your company size declared correctly?



ECHA will soon verify the size of micro, small and medium-sized companies (SMEs) that have registered substances between 2016 and 2019 under REACH and benefitted from reduced fees. Check that you declared your enterprise’s size correctly and have uploaded the documents in REACH-IT.


Helsinki, 31 January 2020 – If you are an SME registrant, you should check that the enterprise size you claimed when registering or updating your registration is correct and that you uploaded the required support documents in REACH-IT.


If the enterprise size you claimed turns out to be incorrect, you should inform ECHA by sending an email to: sme-verification@echa.europa.eu by 11 February 2020 and update your information in REACH-IT.


By declaring and rectifying your size before ECHA begins the verification check, you will benefit from a full administrative charge waiver and only have to pay the difference to the applicable registration fee.


If later, during the verification process, ECHA identifies that you have claimed an incorrect size, you will have to pay the balance of the accurate fee and an administrative charge of up to EUR 19 900.


A stepwise approach on how to determine and declare the correct size of your enterprise is available on ECHA’s website.


It is also important to regularly check your REACH-IT accounts for any messages and tasks from ECHA, keep your contact details up to date and react to ECHA’s requests.


Small and Medium-sized Enterprises (SMEs)


Companies of all sizes are responsible for the safety of chemicals that they place on the EU market. There is a lot of material and many tools available to help you. Thousands of companies, including many SMEs, have already registered their chemicals with ECHA.


If you are new to REACH, CLP, PIC and the Biocidal Products Regulations, the first step is to find out about your rights and responsibilities. These depend on your role in the supply chain, the specific substance you import, manufacture, store or use and how hazardous it is.


Reduced fees for SMEs


Small and Medium-sized Enterprises can benefit from reduced fees under the REACH, CLP and Biocidal Products Regulations. The reductions depend on the company size as defined by the Commission Recommendation 2003/361/EC and can be up to 95% from the standard fee for a REACH registration.

SME fees under REACH and CLP


Before you declare your company as an SME, make yourself familiar with the relevant EU definition. The Commission Recommendation 2003/361/EC is the sole authentic basis for determining the conditions regarding qualification as micro, small or medium-sized enterprise.


For Only Representatives (ORs), the pertinent assessment of whether the fee reduction for SMEs applies shall be determined by the relevant data of the enterprise that is represented by that OR, including relevant information from linked and partner companies of that enterprise, in accordance with the Commission Recommendation.


It is important to get this right. If you wrongly declare your company size, you will have to pay an administrative charge and the balance to the correct fee. Remember that it is you, the registrant, that is entirely responsible for the correctness and authenticity of the information provided in the process of the dossier submission in REACH-IT.


The Agency does not assume any responsibility for the accuracy of the advice given by third parties to determine your company size or the size of the company you represent as an Only Representative.


How to determine the company size category?


https://echa.europa.eu/support/small-and-medium-sized-enterprises-smes/sme-fees-under-reach-and-clp

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