Relevant for: Electrical & electronics, Hardlines, Softlines, Toys & children's products
In July 2013, the European Commission notified the World Trade Organisation (WTO) the draft Regulation on the restriction of chromium (VI) compounds in leather articles and articles containing leather parts. This draft Regulation will amend the REACH Regulation, expanding the existing restriction on chromium (VI) compounds in cement under Annex XVII.
This proposed restriction began in September 2011 when Denmark notified the European Chemicals Agency its intention to submit a formal proposal to restrict chromium (VI) in leather articles. In accordance with the procedure for new restrictions under REACH, two public consultations then followed [ PDF 921 kB ], and changes were made afterwards to the wording of the original proposal. According to the details in the latest draft Regulation, once the restriction starts to apply, leather articles and articles containing leather parts that come into contact with the skin cannot contain 3 mg/kg or more of chromium (VI) by weight of the total dry weight of that leather part. This means all such articles that come into contact with the skin are within the scope, regardless of the length of time of the contact. Examples of products that are within the restriction scope include: footwear, gloves, articles of clothing, accessories such as hats, belts and braces, watch straps, purses and wallets, bags, horse riding gear, dog leashes, auto seats, covers for car steering wheels, and furniture.
Suppliers have until the new restriction requirement starts to apply in 2015 to take care of their existing stocks on the market that will not comply with the new requirement. Second-hand products that were already in end-use in the EU market before the date of application of the restriction would be exempted. Table A shows the details of the upcoming restriction.
Table A. Details of the proposed restriction
Expected date of application
Chromium (VI) compounds
Leather articles and articles containing leather parts coming into contact with the skin
Exemption: second-hand articles that were already in end-use in the EU market
(of the total dry weight of leather in the leather article or the leather parts)
EN ISO 17075 (recommended)
First quarter of 2015
The recommended testing method is EN ISO 17075, which is currently the only internationally recognised analytical method available to detect chromium VI in leather. The limit of the proposed restriction is based on the detection limit of this method, which is 3 mg/kg.
Chromium is a heavy metal element that can be present in different forms such as chromium (III) and chromium (VI). Chromium (VI) is a carcinogen and a potent sensitiser that can elicit allergic reactions at very low concentrations in already sensitised persons. Although it is chromium (III) and not chromium (VI) compounds that are used in the leather tanning process, chromium (VI) can be formed from chromium (III) via a chemical reaction called oxidation, which can happen after the tanning process, during storage of the leather or the life-cycle of the final product.
Although Germany is currently the only country in the European Union that restricts chromium (VI) in consumer products, in the past few years, many other member states have also recognised the potential health hazards posed by chromium (VI) and notified on the EU’s Rapid Alert System for Non-Food Products, RAPEX, products that contain high levels of chromium (VI) in the leather parts. Enforcement measures so far include rejection of the imported products at border, sales ban, withdrawal of products from the market, seizure of products by authorities and recalling products from consumers. [ PDF 742 kB ] It has been estimated that about 45% of new chromium allergy cases in the EU were caused by exposure to chromium (VI) in leather, thus highlighting the need for a restriction at the European Union level.