UK REACH Administrative Fees May See Changes Next Year

According to information that the British Coatings Federation (BCF) distributed to its members, the UK Department for Environment, Food and Rural Affairs (Defra) recently launched a public consultation on changes to the administrative fees for UK REACH registrations, with a deadline of September 16, 2024.

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The consultation is set to last only a few weeks because Defra aims to complete the necessary regulatory amendments quickly so that the new fee levels can take effect next year.

The proposed fees for the consultation are as follows:

1. Fees for Large Enterprise Registrations

The registration administrative fee will no longer be differentiated by tonnage and type of registration, nor between individual and joint submissions, with a uniform fee of £2,142 across all tonnage bands.

For current intermediates and registrations of 1-10 tons per annum (tpa), the fee has slightly increased from £1,138 to £2,142; for other tonnages, the fees have been reduced.

Fees for registrations submitted under Article 6, 7 or 11.

Table 1 Standard fees

	Individual submission	Joint submission
Fee for substances in the range of 1 to 10 tons	[£1,518] £2,142	[£1,138] £2,142
Fee for substances in the range 10 to 100 tons	[£4,080] £2,142	[£3,061] £2,142
Fee for substances in the range 100 to 1000 tons	[£10,913] £2,142	[£8,185] £2,142
Fee for substances above 1000 tons	[£29,419] £2,142	[£22,064] £2,142

UK REACH's original administrative fees were aligned with those under EU REACH. However, the UK authorities believe that because the UK market is relatively small when compared to the EU, there should be a distinction in the administrative fees.

2. Fees for SME Registrations

The registration administrative fees will no longer be differentiated by tonnage or between individual and joint submissions. The fees are now associated with the type of business, as follows: medium-sized enterprises £740, small enterprises £399, and micro-enterprises £57. For example, for medium enterprises, the administrative fee is £740 regardless of tonnage, which is the same as the previous fee for 1-10 tpa.

3. Fees for Intermediates Registrations

For large enterprises, the administrative fee for intermediates registration is the same as the regular registration fee, at £2,142.

Fees for registrations submitted under Article 17(2), Article 18(2) and (3) or Article 19

Table 2 Standard fees

	Individual submission	Joint submission
Fee	[£1,518] £2,142	[£1,138] £2,142

The registration administrative fees for intermediates of SME enterprises are the same as the regular registration fees for SMEs, which are related only to the type of enterprise, as follows: medium-sized enterprises £740, small enterprises £399, and micro-enterprises £57.

4. Fees for the Update of the Tonnage Range

It is worth noting that, unlike the previous practice of charging update administrative fees based on the difference, Defra now proposes to unify the update fees for large businesses at £2,142.

Fees for the update of registrations under Article 22

Table 3 Standard fees for the update of the tonnage range

	Individual submission	Joint submission
From 1-10 ton range to 10-100 ton range	[£2,562] £2,142	[£1,921] £2,142
From 1-10 ton range to 100-1000 ton range	[£9,395] £2,142	[£7,046] £2,142
From 1-10 ton range to over 1000 ton range	[£27,901] £2,142	[£20,926] £2,142
From 10-100 ton range to 100-1000 ton range	[£6,833] £2,142	[£5,125] £2,142
From 10-100 ton range to over 1000 ton range	[£25,339] £2,142	[£19,003] £2,142
From 100-1000 ton range to over 1000 ton range	[£18,506] £2,142	[£13,879] £2,142

The update fees for SMEs are as follows: medium-sized enterprises £1,249, small enterprises £672, and micro enterprises £96.

5. Fees for Other Updates

Fees for changes in legal representative have been reduced, with the fees for large enterprises dropping from £1,424 to £290.

Table 4 Fees for other updates

Type of Update
Changing the identity of the registrant involving a change in legal representative	[£1,424] £290

The reduced fees for SMEs are as follows:

Table 5 Reduced fees for SMEs for other updates

Medium enterprise

Small Enterprise

Microenterprise

Changing the identity of the registrant involving a change in legal representative

[£925]

£261

[10% discount applied]

[£498]

£232

[20% discount applied]

[£72]

£72

[Current fee retained]

Other updates to information such as degree of purity and/or identity of impurities or additives, trade names of the substance, and IUPAC names for non-phase-in substances referred to in Article 119(1)(a) of Regulation (EC) No 1907/2006 will be free of charge for the time being, as there is currently no such application under UK REACH and there is a lack of evidence to support the charges.

6. Fees for Product and Process Orientated Research and Development (PPORD) Notifications

The standard fee for PPORD notifications has increased, while the fee for SMEs remain unchanged.

Fees and charges for PPORD notifications under Article 9

Table 6 Fees for PPORD Notifications

Standard fee	[£475] £751
Reduced fee for medium enterprise (fee to remain unchanged)	£308 [Retained current fee]
Reduced fee for small enterprise (fee to remain unchanged)	£166 [Retained current fee]
Reduced fee for micro enterprise (fee to remain unchanged)	£24 [Retained current fee]

The standard fee for extending PPORD exemptions has been reduced, while the fee for SMEs remains unchanged.

Table 7 Charges for the extension of a PPORD exemption

Standard fee	[£949] £751
Reduced fee for medium enterprise (fee to remain unchanged)	£617 [Retained current fee]
Reduced fee for small enterprise (fee to remain unchanged)	£332 [Retained current fee]
Reduced fee for micro enterprise (fee to remain unchanged)	£47 [Retained current fee]

7. Fees for Authorisation

For large enterprises:

Fees for applications for an authorisation under Article 62

Table 8 Standard fee

Base fee	[£47,229] £57,689
Additional fee per substance	[£9,446] £11,538
Additional fee per use	[£42,506] £51,920

Charges for the review of an authorisation under Article 61

Table 9 Standard charges

Base fee	[£47,229] £57,689
Additional fee per substance	[£9,446] £11,538
Additional fee per use	[£42,506] £51,920

If this administrative fee update can be successfully implemented, it will undoubtedly be a significant benefit for high-tonnage registration companies, especially those with more than 1000 tons.

At the same time, CIRS will provide feedback to the association, hoping that the registration administrative fee for 1-10 tons will not increase. Since the time for this review is relatively short, interested parties are urged to provide their suggestions to us before September 6, 2024, and we will provide unified feedback for you and continue to pay attention to the relevant information.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

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