REACH 2027: Why SMEs need to anticipate the validation of their company size
From February 5, 2027, companies wishing to benefit from the reduced fees applicable to SMEs for REACH registration of their substances will need to have their size category validated by ECHA before submitting their registration dossier. This change necessitates anticipating the verification of company size and preparing supporting documents well in advance of the registration dossier.
Key points to remember
- February 5, 2027 : entry into force of the new SME verification procedure
- Minimum 2 months : the waiting period to be observed before submitting the application for validation
- 2 months : the timeframe ECHA has to make a decision once all the documents have been received.
- 3 years : validity period of SME status recognition
- Documents to prepare : staff numbers, turnover, balance sheet and information relating to partner and related companies
The aim of this reform is to further secure the application of fee reductions granted to micro-enterprises, small and medium-sized enterprises. But for registrants, it primarily introduces a new planning constraint .
Until now, verification has been primarily done after the reach registration submission
When a company submits a REACH registration, its size category directly influences the calculation of the fees to be paid.
SMEs benefit from reduced fees. They must therefore correctly declare their category in REACH-IT and be able to justify it.
Until now, ECHA could verify this declaration after the registration dossier had been submitted. The Agency already conducts checks on companies that have declared micro-enterprise, small, or medium-sized company status.
In the event of an incorrect declaration, the company must pay the difference between the fees corresponding to the actually applicable category and the fees initially paid. Administrative fees will be applied.
From February 5, 2027, the principle changes: the SME will have to obtain validation of its status before being able to benefit from reduced fees.
1. Prior validation before submission
The regulation amending the REACH registration fees scheme introduces an ex ante verification procedure .
A micro-company, small enterprise or medium-sized company wishing to benefit from reduced fees must ask ECHA to validate its size before submitting its application .
The application must be submitted at least two months before the relevant submission date. ECHA will make a decision within two months of receiving all the relevant documents.
This timeline is crucial. A company preparing for registration can no longer wait for its IUCLID file to be finalized before starting to consider its size category.
Example
A company plans to submit a REACH registration on June 15, 2027 and wishes to benefit from the SME reduced fees.
The company must have submitted its size validation request no later than two months before this submission. In practice, it will be preferable to start the process much earlier , especially if the group's structure is complex or if certain supporting documents need to be obtained from other companies.
ECHA recommends anticipating the request in order to have sufficient time to respond to any requests for additional documents.
2. The size of a company is not simply determined by its number of employees
This is probably one of the main points of focus for companies.
To determine whether a company is a micro-company, a small or a medium-sized company as defined by European law, it is not enough to look at its workforce.
ECHA reiterates that the applicable definition is that of European Commission Recommendation 2003/361/EC. The analysis must, in particular, take into account any potential relationships with partner or related companies.
This can significantly alter the data to be considered. A company that appears to be an SME when considered in isolation may, depending on its capital structure, need to incorporate certain data from other companies when determining its category.
3. Information to prepare
The validation request requires information relating to:
- to the workforce;
- to turnover;
- total balance sheet;
- to the ownership structure;
- to partner and related companies;
- to the relevant data from these companies when they need to be taken into account.
For an Only Representative (OR) , the analysis must be carried out on the basis of the data of the non-European company represented, also taking into account relevant partner and related companies.
Determining size therefore becomes a genuine regulatory and financial analysis, and not simply administrative information to be entered in REACH-IT.
4. A status recognized for three years
When ECHA has recognised the company size category, this recognition will remain valid for three years from the date of the Agency's decision.
The company will therefore not have to repeat the procedure before each new registration or each new submission during this period.
The scheme also provides for a simplified renewal option under certain conditions when the size of the company has not changed.
5. What are the risks for a company that misdeclares the category?
The issue is financial.
If ECHA does not recognize the requested SME status, the company will not be able to benefit from the corresponding reduction. An administrative fee may also be applied.
The current system already illustrates the importance of this verification: ECHA indicates that an incorrect declaration can lead to the payment of the difference in fees as well as an administrative charge of up to 19,900 euros under current checks.
It is therefore preferable to secure the company's qualification before submitting , rather than having to correct its declaration afterwards.
6. What businesses need to do right now
The reform directly affects companies that are planning to make deposits from February 5, 2027.
It is therefore relevant not to wait until 2027 to prepare for the transition.
a. Identify the relevant future submissions
This first step helps to identify the deadlines that will need to be included in the new procedure.
b. Check the size category
The SME category must be determined according to applicable European criteria and not according to an internal definition of the company.
Particular attention should be paid to groups, investments and relationships with other companies.
c. Map partner and related companies
This is often where the main difficulty lies.
The companies whose data should be included in the calculation must be identified and the determination of the financial and social information will need to be retrieved.
d. Supporting documents
It is recommended to prepare in advance the documents necessary to demonstrate:
- the group structure;
- capital links;
- the workforce;
- turnover;
- the balance sheet;
- relevant data from partner and related companies.
e. Integrate SME validation into the REACH planning
Size verification should now be seen as a step in the regulatory project , on the same footing as preparing the IUCLID dossier, verifying compliance, or submitting to REACH-IT.
7. A checklist for future registrants
Before submitting a REACH registration dossier from February 5, 2027:
- The company size category is determined according to the European definition of SMEs.
- The company's capital structure has been analyzed.
- Partner and related companies have been identified.
- The necessary financial and social data have been collected.
- Supporting documents are available.
- The application for validation with ECHA was submitted at least two months in advance.
- The time required for any additional requests from ECHA has been integrated into the schedule.
- Recognition of SME status was obtained before filing.
2026: The right time to review your REACH procedures
The new procedure does not change the criteria for determining whether a company is an SME under European law. It primarily modifies the point at which this classification must be secured.
The shift from a control logic potentially carried out after filing to prior validation requires companies to review their organization.
For companies belonging to a group, manufacturers or importers making multiple registrations, as well as exclusive representatives, this anticipation can be particularly important.
REACH 2027: Conclusion and support from EcoMundo for your REACH registrations
From February 5, 2027, the question "Are we an SME within the meaning of REACH?" will have to be addressed well in advance of the submission of the registration dossier.
For the companies concerned, the challenge is therefore to anticipate: identify the applicable category, document its analysis and obtain validation early enough not to delay the submission of the REACH registration dossier.
Good preparation in 2026 will make it possible to transform this new requirement into a controlled step in the registration process. EcoMundo offers support with your REACH registrations and all the associated processes. Contact our experts to discuss your requirements.
From February 5, 2027, companies wishing to benefit from the reduced fees applicable to SMEs for REACH registration of their substances will need to have their size category validated by ECHA before submitting their registration dossier. This change necessitates anticipating the verification of company size and preparing supporting documents well in advance of the registration dossier.
Key points to remember
- February 5, 2027 : entry into force of the new SME verification procedure
- Minimum 2 months : the waiting period to be observed before submitting the application for validation
- 2 months : the timeframe ECHA has to make a decision once all the documents have been received.
- 3 years : validity period of SME status recognition
- Documents to prepare : staff numbers, turnover, balance sheet and information relating to partner and related companies
The aim of this reform is to further secure the application of fee reductions granted to micro-enterprises, small and medium-sized enterprises. But for registrants, it primarily introduces a new planning constraint .
Until now, verification has been primarily done after the reach registration submission
When a company submits a REACH registration, its size category directly influences the calculation of the fees to be paid.
SMEs benefit from reduced fees. They must therefore correctly declare their category in REACH-IT and be able to justify it.
Until now, ECHA could verify this declaration after the registration dossier had been submitted. The Agency already conducts checks on companies that have declared micro-enterprise, small, or medium-sized company status.
In the event of an incorrect declaration, the company must pay the difference between the fees corresponding to the actually applicable category and the fees initially paid. Administrative fees will be applied.
From February 5, 2027, the principle changes: the SME will have to obtain validation of its status before being able to benefit from reduced fees.
1. Prior validation before submission
The regulation amending the REACH registration fees scheme introduces an ex ante verification procedure .
A micro-company, small enterprise or medium-sized company wishing to benefit from reduced fees must ask ECHA to validate its size before submitting its application .
The application must be submitted at least two months before the relevant submission date. ECHA will make a decision within two months of receiving all the relevant documents.
This timeline is crucial. A company preparing for registration can no longer wait for its IUCLID file to be finalized before starting to consider its size category.
Example
A company plans to submit a REACH registration on June 15, 2027 and wishes to benefit from the SME reduced fees.
The company must have submitted its size validation request no later than two months before this submission. In practice, it will be preferable to start the process much earlier , especially if the group's structure is complex or if certain supporting documents need to be obtained from other companies.
ECHA recommends anticipating the request in order to have sufficient time to respond to any requests for additional documents.
2. The size of a company is not simply determined by its number of employees
This is probably one of the main points of focus for companies.
To determine whether a company is a micro-company, a small or a medium-sized company as defined by European law, it is not enough to look at its workforce.
ECHA reiterates that the applicable definition is that of European Commission Recommendation 2003/361/EC. The analysis must, in particular, take into account any potential relationships with partner or related companies.
This can significantly alter the data to be considered. A company that appears to be an SME when considered in isolation may, depending on its capital structure, need to incorporate certain data from other companies when determining its category.
3. Information to prepare
The validation request requires information relating to:
- to the workforce;
- to turnover;
- total balance sheet;
- to the ownership structure;
- to partner and related companies;
- to the relevant data from these companies when they need to be taken into account.
For an Only Representative (OR) , the analysis must be carried out on the basis of the data of the non-European company represented, also taking into account relevant partner and related companies.
Determining size therefore becomes a genuine regulatory and financial analysis, and not simply administrative information to be entered in REACH-IT.
4. A status recognized for three years
When ECHA has recognised the company size category, this recognition will remain valid for three years from the date of the Agency's decision.
The company will therefore not have to repeat the procedure before each new registration or each new submission during this period.
The scheme also provides for a simplified renewal option under certain conditions when the size of the company has not changed.
5. What are the risks for a company that misdeclares the category?
The issue is financial.
If ECHA does not recognize the requested SME status, the company will not be able to benefit from the corresponding reduction. An administrative fee may also be applied.
The current system already illustrates the importance of this verification: ECHA indicates that an incorrect declaration can lead to the payment of the difference in fees as well as an administrative charge of up to 19,900 euros under current checks.
It is therefore preferable to secure the company's qualification before submitting , rather than having to correct its declaration afterwards.
6. What businesses need to do right now
The reform directly affects companies that are planning to make deposits from February 5, 2027.
It is therefore relevant not to wait until 2027 to prepare for the transition.
a. Identify the relevant future submissions
This first step helps to identify the deadlines that will need to be included in the new procedure.
b. Check the size category
The SME category must be determined according to applicable European criteria and not according to an internal definition of the company.
Particular attention should be paid to groups, investments and relationships with other companies.
c. Map partner and related companies
This is often where the main difficulty lies.
The companies whose data should be included in the calculation must be identified and the determination of the financial and social information will need to be retrieved.
d. Supporting documents
It is recommended to prepare in advance the documents necessary to demonstrate:
- the group structure;
- capital links;
- the workforce;
- turnover;
- the balance sheet;
- relevant data from partner and related companies.
e. Integrate SME validation into the REACH planning
Size verification should now be seen as a step in the regulatory project , on the same footing as preparing the IUCLID dossier, verifying compliance, or submitting to REACH-IT.
7. A checklist for future registrants
Before submitting a REACH registration dossier from February 5, 2027:
- The company size category is determined according to the European definition of SMEs.
- The company's capital structure has been analyzed.
- Partner and related companies have been identified.
- The necessary financial and social data have been collected.
- Supporting documents are available.
- The application for validation with ECHA was submitted at least two months in advance.
- The time required for any additional requests from ECHA has been integrated into the schedule.
- Recognition of SME status was obtained before filing.
2026: The right time to review your REACH procedures
The new procedure does not change the criteria for determining whether a company is an SME under European law. It primarily modifies the point at which this classification must be secured.
The shift from a control logic potentially carried out after filing to prior validation requires companies to review their organization.
For companies belonging to a group, manufacturers or importers making multiple registrations, as well as exclusive representatives, this anticipation can be particularly important.
REACH 2027: Conclusion and support from EcoMundo for your REACH registrations
From February 5, 2027, the question "Are we an SME within the meaning of REACH?" will have to be addressed well in advance of the submission of the registration dossier.
For the companies concerned, the challenge is therefore to anticipate: identify the applicable category, document its analysis and obtain validation early enough not to delay the submission of the REACH registration dossier.
Good preparation in 2026 will make it possible to transform this new requirement into a controlled step in the registration process. EcoMundo offers support with your REACH registrations and all the associated processes. Contact our experts to discuss your requirements.
