What will it cost?
Essentially, the regulations prescribe three types of fees: (i) registration fees; (ii) authorisation fees; and (iii) other fees and charges.
Registration fees proposed in the regulations range from €1600 per manufacturer/importer for substances produced below ten tonnes, to €31,000 for those produced above 1000 tonnes.
Manufacturers/importers who register in collaboration with other producers (i.e. as part of a consortium) would be eligible for a 25% discount in registration fees. SMEs would be entitled to a further 30% discount.
Further registration fees would apply where, for example, an increase in production volumes to a new tonnage threshold has occurred.
Authorisation of dangerous substances incurs the highest charges. The standard fee for authorising a substance of very high concern would be €50,000. The same fee would apply to authorisation renewals.
Criticism from industry
European industry is critical of the Commission’s draft regulation. In particular, industry is requesting 'more transparency on the structure of the fees, the Agency’s overall budget, and the amount covered by fees and charges payable by industry and the amount covered by other sources.'
Next steps
The regulation on fees and charges must be adopted before 1 June 2008, when the REACH registration process begins in earnest. However additional time will be required to ensure that the European Chemical Agency's IT system has been suitably tested. It is expected that the approved regulation on fees and charges will therefore be published early in the new year.