UEAPME Calls for Clarification of Planned Modifications of REACH Fees

The European Association of Craft, Small and Medium-Sized Enterprises (UEAPME), which represents the interests of small and midsize enterprises (SMEs) throughout Europe, has called upon the EU to formulate more clearly its planned changes to the current fee structure. UEAPME expressed its position on this matter in a letter to the EU.

The cause of the criticism is a section that could be disadvantageous to SMEs. The text states: “Where the applicants that are party to a joint application for an authorisation are of different sizes, the highest fee applicable to any of those applicants shall be levied for that application.” In its letter, UEAPME warms that this formulation leaves the exact division of fees open. The situation would create room for conflict between individual negotiators and make the already difficult talks even more challenging.

Representatives of the UEAPME used a sample calculation to illustrate an alternate method for distributing the fees fairly – according to the size of the enterprise. Say that the fee for a large enterprise is €48,690 and one-tenth of that (€4,869) for the smallest company. This would result in the following sample calculation:

  • The total costs of authorization in the UEAPME example are €53,559.
  • The costs (€48,690) are divided by the total cost (€53,559), giving a factor of 0.90909091.
  • The distribution factor would serve as a multiplication factor for additional fees. The large company would pay €48,690 x 0.90909091 = €44,263.64; the small company would pay €4.869 x 0.90909091 = €4,426.36.

The UEAPME states that such a calculation is fair because:

  • All the companies involved profit from the cost distribution equally.
  • The distribution rule protects SMEs from discrimination.

If you have any questions about fees, please contact us at reach@kft.de.

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