The German Federal Environmental Agency has published a study in which the authors examine various ways that the activities of the ECHA can be financed in the future. The trigger for the study was the funding shortfall at the ECHA.
How did the shortfall develop? The agency originally assumed that considerably less effort would be involved in examining and evaluating registration dossiers. However, the quality of the dossiers has been shown to be quite far from the requirements. Accordingly, the ECHA plans to examine dossiers more closely. To do so, the EU agency needs additional resources that cannot be covered by a one-time registration fee, as required in Article 74 (3) of REACH.
The study covers possible financing methods. The authors recommend collection of an annual fee for each existing dossier. The authors claim that €100 million could be raised this way, making the ECHA less dependent on contributions from the EU budget.
For this scenario, the costs for large companies for each dossier would fall between €199 (for tonnage bands of 1–10 tons) and €3,860 (for tonnage bands greater than 1,000 tons). The costs are appropriately lower for small companies and lie between €70-€1,351.
The authors have also run the numbers for scenarios that apply to different frequencies (three, five, and ten years) for the updates. However, the EU Commission has not yet decided how often the dossiers must be updated. A draft regulation for Article 22 of REACH that would define the frequency is expected in the first quarter of 2020.
The study also discusses other options. For example, it must be possible to demand additional update fees when the ECHA must explicitly require an update of a dossier.
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