The European Commission has approved changes to the REACH fee regulation that will raise compliance costs for large companies and introduce a new pre-verification process for smaller firms. Adopted on Oct. 15, 2025, the revised regulation increases standard fees and charges for large enterprises by 19.5% and requires micro, small and medium-sized enterprises to validate their company size before filing REACH registration or authorization dossiers.
The update aims to align fees with inflation while clarifying eligibility for reduced SME rates. Industry participants say the changes could influence operating costs and compliance planning across Europe’s chemicals and lubricants value chain.
Under the revised system, SMEs will need to apply for company size validation at least two months before submitting their dossiers. The European Chemicals Agency will have two months to confirm SME status once the documentation is received. Companies that fail to obtain recognition may face an administrative charge set by ECHA’s Management Board.
“Before, there was a system whereby you certify you are an SME and then they maybe check. If they check you, you do the paperwork,” Mattia Adani, president of the Union of the European Lubricants Industry and CEO of Nowl Chimica, told Lube Report. “Now every SME, even before starting registration, has to do the paperwork.”
To maintain continuity, validated SME status will remain valid for three years, with renewal by self-declaration permitted if the company’s size has not changed, according to the EU.
“At this stage, our focus is on ensuring that companies, particularly smaller enterprises, have clarity and sufficient time to adapt to the new process,” an ECHA spokesperson said in a statement. “We will publish detailed guidance to help registrants prepare for the SME validation requirement before the new system takes effect.”
“There’s more bureaucracy for everybody, which I think really misses the point that they need to trust their own people, because there is this element of mistrust.,” Adani said.
The updated fees will take effect on Nov. 5, 2025.