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Q What documents are needed in REACH-IT for SME fee reductions under REACH?

Under REACH, registrants and applicants can benefit from reduced fees established for micro, small and medium enterprises (SMEs).

Companies declare their SME size at the time of dossier submission, based on which ECHA issues an invoice. At a later stage, ECHA carries out an ex-post assessment, to verify the correctness of the company size. The SME verification process is important to ensure that only genuine SMEs benefit from the reduced fees and that correct fees are collected.

Before declaring the SME status in REACH-IT, companies should be familiar with the rules set by the Commission Recommendation 2003/361/EC on SME definition.

Companies should upload documentary evidence to their REACH-IT account to support SME status claims. This is only required for those submissions, which are related to SME fee reductions.

The documentary evidence should include:

  • Information about the ownership structure (upstream, downstream) at the time of the submission.
  • The financial statements (consolidated, if available) together with accompanying notes for the two latest accounting periods before the time of the submission.
  • Official certificate/information confirming the average number of employees for each of the two latest accounting periods before the time of submission.

The documents listed above shall be provided for all partner and linked enterprises, as defined by Article 3 of the aforementioned Commission Recommendation.

In case of Only Representatives, the assessment on whether the SME reduction applies is done by reference to the headcount, turnover and balance sheet information of the non-EU company represented and its linked and partner enterprises.

All documents uploaded to REACH-IT are treated confidentially by ECHA and used exclusively for size verification purposes. For transparency and traceability reasons, documents cannot be deleted. It is, however, possible to add supplementary documentation to your REACH-IT account at a later stage. The documentation is not assessed immediately, but only once the size verification process has been initiated.

The list of documentary evidence accepted by ECHA can be found in SME verification -page.

Instructions on how to upload documents and other useful information about REACH-IT can be found at Discover REACH-IT -guide.

More information on company’s size assessment and links to the relevant legislation can be found at SME fees under REACH and CLP -page

Data modyfikacji: 17/06/2019
Scope: Legal entity
Chapter: B. SME Verification
ID: 1225
Wersja: 1.2

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