Under the new Implementing Regulation (EU) 2025/2067, starting 5 February 2027, companies wishing to benefit from reduced ECHA fees must obtain official recognition of their SME status before submitting any fee-based dossier.
The new regulation introduces a prior verification process that eliminates the option of self-certification at the time of dossier submission. Key points to note include:
- The request for SME status recognition must be submitted to ECHA at least two months before the planned dossier submission.
- ECHA will review the documentation and issue an official decision within two months of receiving the request.
- Reduced SME fees cannot be applied under any circumstances without prior formal recognition of the status.
- Once SME status has been recognized by ECHA, the recognition decision remains valid for three years.
ECHA has announced that further operational details and guidelines regarding the practical implementation of this new verification procedure will be published in the coming months.
