Tips for Indian SMEs supplying chemicals to Europe

Small and medium-sized enterprises (SMEs) benefit from fee reductions under both the REACH and CLP Regulations, depending on their size as a medium-sized, small or micro enterprise. Before declaring an SME size category in REACH-IT, companies need to make sure that they are familiar with the relevant SME definitions. The EU Commission Recommendation 2003/361/EC is the sole authentic basis for determining the conditions regarding qualification as micro, small or medium-sized enterprise.

For Only Representatives (ORs), the pertinent assessment of whether the fee reduction for SMEs applies shall be determined by the relevant data of the enterprise that is represented by that OR.

Companies should take into account following things when assessing the company size:

i) Always consult the Finance – Accounting – Legal department before declaring the company size to your OR or REACH-IT accounts. Always maintain documentary proof and review same in each FY before initiating REACH registration process.
ii) Extra attention to the linked/partner companies – need for consolidated accounts
iii) ECHA will increase these verification requests to submit documentary evidence to proof your SME status you indicated at the time of REACH registration with a deadline of 21 calendar days.
iv) If you fail to provide ECHA with sufficient documentary evidence supporting the SME category, your company will be charged the balance to the fee applicable to your company’s accurate size and the administrative charge (EUR 2070 – EUR 20700).
v) Non-payment of invoices resulting of the SME verification will have severe legal consequences including revocation of the registration
vi) Companies should perform electronic SME test to verify their status: http://smetest.uwe.be/

REACHLaw successfully completed such requests for large number of SMEs, and can provide useful assistance if needed, please write to
Further REACHLaw is working towards launching cost effective workshops, training, and other skill development programs which will benefit all stakeholders of Indian industry.

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