In advance of the 31 May 2013 deadline for registration of phase–in substances manufactured/imported in quantities of over 100 tonnes, a draft Regulation has been proposed to alter the registration fees payable. It is proposed that the fees payable by SMEs will be reduced and the fees payable by large companies will be increased.

The new fees are expected to come into effect from the end of March 2013. The updated fees will not apply to valid submissions which are pending on the date the draft Regulation comes into force.

Whilst, when considered individually the fee changes are not substantial, when many substances are being registered by the same company the savings/increase in costs could be considerable. This is particularly significant as ECHA expects that 3075 additional substances will be registered by the 31 May 2013 deadline.

SMEs should consider whether to delay their registrations until after the new fees come into effect. Larger companies should consider whether to bring forward their submissions to avoid the increase.