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According to the European Chemicals Agency (ECHA), income from REACH fees is lower than expected because the "high fees make companies creative." According to the agency, it is difficult for them to check whether companies identifying themselves as small and medium-sized enterprises, which are subject to lower fees, were making "legitimate" claims.
Although the ECHA does not charge fees for pre-registration of substances, fees are payable under REACH for processing full registrations and for other operations such as submitting dossiers concerning substances used only in research and development or in improvements to production processes. The production process improvements, known as Product and Process Oriented Research and Development (PPORD) notifications may be exempt from REACH registration for up to five years.
The ECHA director indicated that the budget shortfall will not cause any problems through 2010, however, the years from 2011 to 2013 could be "problematic" because starting in 2011, the ECHA is supposed to be funded entirely from fees paid by companies for registering chemicals and other procedures.
The ECHA director also reported that there have been some information technology problems, particularly with bulk pre-registrations, but that work is ongoing on IT tools for procedures for full registrations of substances.