May 6, 2025 by Sylwia Kosmala-Grzechnik
The UK government made significant changes to the fees under the UK REACH regulation, which came into force on 1 April 2025. These changes are outlined in the recently published Statutory Instrument 2025 No. 299. Therefore, if your company is operating in the UK, it’s crucial to understand what has changed and review your current and planned registrations to assess the financial impact.
What has been changed, and why?
This update is the first major change of UK REACH fees since the UK’s departure from the EU. The fee structure, previously inherited from EU REACH, has now been adjusted in line with HM Treasury’s guidance on Managing Public Money
As a result, significant changes have been made across the board, including the introduction of a flat standard registration fee, which eliminated the complexity of different fees dependent on tonnage band and submission types.
Key Fee Changes
- Flat Registration Fee for All Tonnages
Registration fees, previously dependent on the tonnage band and whether the registration was submitted individually or jointly, have been replaced with a flat fee of £2,222, which is now applied to full registrations of all tonnages for large companies. This is a substantial reduction for most tonnage bands, especially for the highest tonnage band registration where the fee was reduced from £29,419 or £22,064 for individual and joint registrations, respectively. However, for the 1–10 tonnes per year (t/y) band registrations, the new fee is higher than it was previously, increasing from £1,518 or £1,138 for individual and joint registrations, respectively.
The new SME (Small, Medium or micro-Enterprises) fees are determined solely by company size, rather than tonnage or submission type, and are £740, £399, and £57 for medium, small, and micro-companies, respectively. All SMEs benefit from reductions, particularly for high-tonnage registrations, with the largest fee reduction observed for medium-sized companies registering substances at >1000 t/y, where the fee was reduced from £19,122 to £740.
- Dossier Updates under Article 22 (Tonnage Band Increases):
Fees for dossier updates under Article 22 have been also simplified. The flat fee of £2,222 now applies to all updates by large companies, regardless of the tonnage band increase. Again, in most cases companies will pay less than previously, and only the joint registrants increasing the tonnage band of their registration from 1-10 t/y to 10-100 t/y will be affected by an increase, albeit rather small (increase from £1,921 to £2,222).
SMEs also benefit from streamlined and reduced dossier update fees. Similar to the approach for the registration fees, the new fees for tonnage band increases are based on the company size, rather than the tonnage band increase, and are £1,249, £672 and £96, for medium, small, and micro-companies, respectively. Again, the most significant reduction in fees is observed for medium companies, especially upgrading registration from 1-10 to >1000 t/y, where the fee has been reduced from £18,136 to £1,249.
- Change of Identity of Registrant involving a change in Legal Personality
Changing the registrant’s legal personality now costs £290 for large companies (previously £1,424). Fees have also been reduced for small and medium companies, and are £232 (previously: £925) and £261 (previously: £498), respectively, however the fee remained the same for micro-companies (£72).
- Authorisation Fees (Article 61 and Article 62)
The fees for authorisation application (Article 62) and review of authorisation (Article 61) for large companies have increased. The base fee increased from £47,229 to £57,689, and the fees for additional substance and additional use increased from £9,446 and £42,506 to £11,538 and £51,920, respectively.
SMEs can benefit from reduced fees for authorization application and review of authorisation, which depend on the company size. The new base fees for small and medium companies are £25,590 and £43,267, respectively, the fees for additional substance are £5,192 and £8,653 and additional use are £23,364 and £38,940, respectively.
The new fee structure is applicable from 1 April 2025 and is available on the HSE website.
More Information
Here at wca we are closely monitoring the developments of the UK REACH and our experts can provide advice on your obligations under UK REACH, support with developing a registration strategy, or act as your UK Only Representative, if you need one. If you need any help or have any questions regarding your obligations under UK REACH, please do not hesitate to contact us and we can discuss with you how to proceed.
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