Author name: bilgi@chemleg.com

DEFRA (UK’s Department for Environment, Food & Rural Affairs) has announced updates to certain registration and authorisation fees under UK REACH. The new fees came into effect on 1 April 2025. According to UK authorities, this update is based on the price indices and fee structures proposed by HSE. The updated fee schedule was published on 10 March 2025 under the name The REACH Fees and Charges (Amendment of Commission Regulation (EC) No 340/2008) Regulations 2025. Updated UK REACH Fees Registration Fees Fees for full registrations and intermediate-only registrations have been revised as follows: 1. Standard Fees Tonnage Band Individual Submission Joint Submission All Tonnage Bands £2,222 £2,222 2. Reduced Fees for SMEs Tonnage Band Medium (Ind.) Medium (Joint) Small (Ind.) Small (Joint) Micro (Ind.) Micro (Joint) All Tonnage Bands £740 £740 £399 £399 £57 £57 The lack of tonnage differentiation in standard fees means the base registration cost is the same whether 1 tonne or 1000 tonnes of a substance is manufactured. It is a different approach compared to the EU REACH regulation. However, the reduced fees can help SMEs. A micro-enterprise may pay up to 97% less than a large company for the same registration. Update Fees To maintain transparency and oversight in UK REACH processes, fees for updates under Article 22 have also been revised: Tonnage Band Updates 1. Standard Fees Type of Update Individual Submission Joint Submission All Updates £2,222 £2,222 2. Reduced Fees for SMEs Type of Update Medium (Ind.) Medium (Joint) Small (Ind.) Small (Joint) Micro (Ind.) Micro (Joint) All Updates £1,249 £1,249 £672 £672 £96 £96 Identity Change Identity change fees apply in cases such as mergers, name changes, etc. 1. Standard Fees Type of Change Fee Change in identity of the registrant involving a change in legal personality £290 2. Reduced Fees for SMEs Type of Change Medium Small Micro Change in identity of the registrant involving a change in legal personality £261 £232 £72 Other Changes 1. Standard Fees Type of Update Individual Submission Joint Submission Degree of purity and/or identity of impurities or additives £4,271 £3,203 Relevant tonnage band £1,424 £1,068 A study summary or a robust study summary £4,271 £3,203 Information in the safety data sheet £2,847 £2,135 Trade name of substance £1,424 £1,068 IUPAC name for non-phase-in substances referred to in Article 119(1)(a) of Regulation (EC) No 1907/2006 £1,424 £1,068 IUPAC name for substances referred to in Article 119(1)(a) of Regulation (EC) No 1907/2006 used as intermediates, in scientific research and development or in product and process orientated research and development £1,424 £1,068 2. Reduced Fees for SMEs Type of Update Medium (Ind.) Medium (Joint) Small (Ind.) Small (Joint) Micro (Ind.) Micro (Joint) Degree of purity and/or identity of impurities or additives £2,776 £2,082 £1,495 £1,121 £214 £160 Relevant tonnage band £925 £694 £498 £374 £72 £53 A study summary or a robust study summary £2,776 £2,082 £1,495 £1,121 £214 £160 Information in the safety data sheet £1,851 £1,388 £996 £747 £142 £107 Trade name of the substance £925 £694 £498 £374 £72 £53 IUPAC name for non-phase-in substances referred to in Article 119(1)(a) of Regulation (EC) No 1907/2006 £925 £694 £498 £374 £72 £53 IUPAC name for substances referred to in Article 119(1)(a) of Regulation (EC) No 1907/2006 used as intermediates, in scientific research and development or in product and process orientated research and development (not specified)           PRORD Fees Under Article 9 of the UK REACH Regulation, the fees for PRORD notification and PRORD exemption extension are as follows: PRORD Notification Standard fee £751 Reduced fee for medium enterprise £308 Reduced fee for small enterprise £166 Reduced fee for micro enterprise £24 PRORD notification fees are relatively low compared to other categories, which supports research and development activities. Fees for Extension of PRORD Exemption Standard charge £751 Reduced charge for medium enterprise £617 Reduced charge for small enterprise £332 Reduced charge for micro enterprise £47 Authorisation Application and Review Fees Authorisation Application 1. Standard Fees Application Type Fee Base Fee £57,689 Additional Fee Per Substance £11,538 Additional Fee Per Use £51,920 2. Reduced Fees for SMEs Application Type Medium Small Micro Base Fee £43,267 £25,960 £5,769 Additional Fee Per Substance £8,653 £5,192 £1,154 Additional Fee Per Use £38,940 £23,364 £5,192 Authorisation Review 1. Standard Charges Review Type Fee Base Charge £57,689 Additional Charge Per Substance £11,538 Additional Charge Per Use £51,920 2. Reduced Charges for SMEs Review Type Medium Small Micro Base Charge £43,267 £25,960 £5,769 Additional Charge Per Substance £8,653 £5,192 £1,154 Additional Charge Per Use £38,940 £23,364 £5,192 Authorisation and review fees are notably high, representing a significant cost for companies dealing with SVHCs. Firms are advised to support their applications with thorough justification and explore safer alternatives. Strategic Recommendations • Cost PlanningCompanies are advised to prepare annual budgets that consider costly processes like authorisation and review. • SME DeclarationTo benefit from reduced fees, companies must complete their SME declarations accurately and on time. • Alternatives to SVHCsWhere possible, firms should prioritize substitution of SVHCs to avoid the authorisation process. • Consultancy SupportErrors in these processes may lead to serious financial consequences; expert guidance is strongly recommended. How Chemleg Consultancy Can Help At Chemleg, we support companies in navigating UK REACH registration, notification, and authorisation processes, including: • Development of compliance strategies• Accurate SME declarations• Technical dossier and IUCLID preparation• Data sharing management for lead registrants and obtaining Letter of Access (LoA) for co-registrants with LoA-Pro. Learn more about our UK REACH registration services.

The Ministry of Environmental Protection of Ukraine has prepared a draft notification form in accordance with the requirements of the Technical Regulations on Classification, Labelling, and Packaging of Chemical Products. This draft aims to ensure consistency in the forms completed and submitted to the Ministry at the email address clp@mepr.gov.ua, in the process of Ukraine C&L notification. According to the Ministry of Environmental Protection and Natural Resources (MEPR) website, before chemical products are placed on the market in Ukraine: It is recommended to use this draft form in relevant notifications. Click here to access the draft. You can simplify the legal compliance process for your company by using our Ukraine C&L notification service.

The Regulation on the Registration, Evaluation, Authorization, and Restriction of Chemicals (KKDIK) requires existing and/or potential registrants to make every effort to reach an agreement on data sharing and to ensure that the cost of sharing the information required for registration is determined fairly, transparently, and in a non-discriminatory manner. The rules necessary to ensure the efficient implementation of existing obligations regarding joint submission and data sharing are included in the Data Sharing Guidance. Update Content Summary of Key Aspects Explained in the Data Sharing Guidance The key aspects explained in the Data Sharing Guidance are summarized below: The Data Sharing Guidance ensures that the information required for the registration process is shared fairly, transparently, and in a non-discriminatory manner. This guidance outlines the obligations related to agreements and the management of data and cost-sharing required under KKDIK. Fundamentally, under KKDIK, a registrant or potential registrant must: The rules required to ensure the efficient implementation of existing obligations regarding joint submission and data sharing by registrants or potential registrants are provided in this guidance. The relevant guidance states that both administrative costs and costs related to information requirements must be shared transparently among only the registrants concerned and clarifies the mandatory elements that must be included in each agreement. Data Sharing Agreement According to the Data Sharing Guidance, a data-sharing agreement must be established. The parties are free to agree on the format of the data-sharing agreement within the scope of contractual freedom. However, regardless of the chosen format, the fundamental principles of fairness, transparency, and non-discrimination outlined in the KKDIK Regulation must be upheld.In any case, data sharing is designed not to generate profit for the data owner(s) but to share the actual costs incurred. The following mandatory elements must be included:a) A list of the data to be shared and associated costs,b) A list and justification of administrative costs,c) A cost-sharing model that must include a reimbursement mechanism; the inclusion of potential future data needs in the cost-sharing model should also be considered. Each registrant must be the legal owner of the study report or have permission to refer to the study report for the study summary and/or robust study summary submitted for registration. Joint registrants should have access to all the information submitted on their behalf in the joint registration dossier that they need for registration and have paid for. By paying for access to the joint submission, joint registrants should have access to at least the endpoint conclusions they have paid for, or if available, a copy of the robust study summary and study summary. Regarding the content of the dossier and the type of access obtained through the agreed cost-sharing, the following elements should be clear and understandable for all parties in the data-sharing agreement: In the event of a data-sharing dispute under the KKDIK Regulation, the Ministry will consider whether the parties have acted in accordance with the obligations specified in the guidance. During data-sharing negotiations, the parties are obligated to make every effort to reach an agreement on data sharing in a fair, transparent, and non-discriminatory manner.