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Charges for companies wrongly registering as SMEs
2010-11-26

As from 1 December 2010, ECHA will collect an administrative charge from registrants who wrongly claimed to be entitled to a fee reduction or a fee waiver. If ECHA concludes that the size of a company is larger than registered under REACH, the company will not only have to pay the difference in registration fee but also an administrative charge as follows:

 

Size of company

 

Administrative charges

Large (non-SME)

20 700

Medium

14 500

Small

8 300

Micro (*)

2 070

(*) Refers to fee waivers only

The administrative charge is levied on the basis of the decision of ECHA's Management Board cited below and it will be applied as of this publication date.

Companies have been reminded that when defining the company size ownership, voting rights and relationships with other companies do matter. Only Representatives must indicate the size of the company they represent and not their own size.

If you have mistakenly identified your company as medium-sized, small or micro and you realise this immediately when submitting your dossier or at the time of receiving the invoice for your submission, please follow the instructions on ECHA's SME web pages on how to correct this and avoid the administrative charge. After having notified ECHA you will be sent a new invoice for each registration you made with the wrong company size. Please note that after you received the registration number an administrative charge cannot be avoided.

From the start of 2011 ECHA will increase the number of verifications of the company size of registrants. On the basis of its own intelligence, ECHA will sample a significant share of the number of SME's that benefited from the fee reduction. Companies will be asked to demonstrate their size by sending documentary evidence corresponding to the definition of SMEs which can be found from ECHA's SME page together with an electronic tool for registrants' convenience. If ECHA identifies a wrong basis for the fee reduction the difference in fee together with the administrative charge corresponding to the correct company size will be levied. If the company cannot prove its size by documentary evidence, it will be considered as a large company having to pay the corresponding fee difference and the maximum administrative charge.

Further Information

Management Board's decision on 12 November 2010

http://echa.europa.eu/doc/about/organisation/mb/mb_29_2010_d_final_decision_on_the_classification_of_services_for_which_charges_are_levied.pdf

SME web pages on ECHA's web

http://www.echa.europa.eu/sme_en.asp

ECHA e-News on 20 October

http://echa.europa.eu/enews/2010_10/20101020.html

News Alert On 29 July 2010: ECHA encourages SME registrants to verify their company size

http://echa.europa.eu/doc/press/na_10_42_sme_verification_20100729.pdf

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