According to information from the British Coatings Federation (BCF), 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. 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 tonnages.
For current intermediates and registrations of 1-10 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 tonnes |
[£1,518] £2,142 |
[£1,138] £2,142 |
| Fee for substances in the range 10 to 100 tonnes |
[£4,080] £2,142 |
[£3,061] £2,142 |
| Fee for substances in the range 100 to 1000 tonnes |
[£10,913] £2,142 |
[£8,185] £2,142 |
| Fee for substances above 1000 tonnes |
[£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 smaller 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 tonnes range to 10-100 tonnes range |
[£2,562] £2,142 |
[£1,921] £2,142 |
| From 1-10 tonnes range to 100-1000 tonnes range |
[£9,395] £2,142 |
[£7,046] £2,142 |
| From 1-10 tonnes range to over 1000 tonnes range |
[£27,901] £2,142 |
[£20,926] £2,142 |
| From 10-100 tonnes range to 100-1000 tonnes range |
[£6,833] £2,142 |
[£5,125] £2,142 |
| From 10-100 tonnes range to over 1000 tonnes range |
[£25,339] £2,142 |
[£19,003] £2,142 |
| From 100-1000 tonnes range to over 1000 tonnes 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 personality have been reduced, with the fees for large enterprises dropping from £1,424 to £290.
Table 4 Fees for other updates
| Type of update | |
| Change in identity of the registrant involving a change in legal personality |
[£1,424] £290 |
The reduced fees for SMEs are as follows:
Table 5 Reduced fees for SMEs for other updates
| Medium enterprise | Small enterprise | Micro enterprise | |
| Change in identity of the registrant involving a change in legal personality |
[£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 PPORD Notifications
The standard fee for PPORD notifications has increased, while the fee for SMEs remains 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 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.
