How the European restriction on Chromium VI in leather products stimulates technological changes in Asia

Much of the world's leather is tanned with chromium salts that allow end leather to be suitable for various uses. Hexavalent Chromium (Cr VI) is not intentionally used in the preparation of leather or production of leather goods, but can be formed in leather through the oxidation of chromium III compounds, which are added in some tanning processes in order to increase leather’s dimensional stability, as well as its resistance to mechanical action and heat. The conditions under which chromium VI compounds are formed are known, as well as their risk of allergis in case of dermal contact even at lower concentrations. For this reason, most tanneries in Europe have already developed and widely implemented measures in order to control and minimise their formation. 

On 19 January 2012, Denmark submitted to the European Chemicals Agency (ECHA) a dossier (REACH Annex XV dossier) providing evidences that exposure to Chromium VI, when contained in leather articles coming into contact with the skin, poses a risk to human health by inducing new cases of sensitisation and elicit allergic response. Through the dossier, Denmark asked the European Commission to introduce regulatory restrictive measures in Europe. The Danish dossier was evaluated by Risk Assessment Committee (RAC) and the Committee for Socio-Economic Analysis (SEAC).

On 28 November 2012 RAC concluded that a content in leather of 3 mg/kg (0,0003 % by weight) of chromium VI is expected to be 80 % effective in reducing the occurrence of new chromium VI-related allergic dermatitis cases due to chromium VI in leather articles. On 6 March 2013 SEAC adopted by consensus the opinion that an European restriction was the most appropriate Union-wide measure to address the identified risks in terms of the proportionality of its socioeconomic benefits to its costs.

On 8 April 2013 ECHA submitted to the European Commission the opinions of RAC and SEAC based on which the Commission concluded that an unacceptable risk to human health arose where Chromium VI compounds were present in leather articles coming into contact with the skin. On March 2014 the new restriction was introduced in REACH Annex XVII. From May 2015 leather articles coming into contact with the skin shall not be placed on the market where they contain Chromium VI in concentrations equal to or greater than 3 mg/kg (0,0003 %) of the total dry weight of the leather. The restriction does not apply to second-hand articles, but impact a wide range of products such as footwear, gloves, clothing and accessories (hats, belts, bracelets, wallets, bags and suitcases).

European tanneries are changing production techniques, incorporating more tests and using certification processes, while presenting in the market leather with no chromium, more ecofriendly. According to the Portuguese Footwear Technological Center (CTCP): “There is an increasing number of companies aware of the benefits of placing on the market a product free of harmful chemicals to the environment and for the final consumer”. In fact, “consumers are more demanding and attentive to these issues, so it is essential that companies bear these issues in mind, test their products and communicate this information to the clients”.

According to numbers published by the Indian press: “almost 60 per cent of India’s leather exports, worth 5 billion USD in 2012-13, go to the EU”, and as such, restrictive regulations on leather goods imported into the EU could impact heavily trade relations of India, and other Asian countries, such as China and Vietnam. To avoid commercial disruption, technology upgrades are required in Asian countries too, to cut Chromium VI  levels to the minimum. This will require improved tanning and processing techniques developed and used by EU tanneries”.

All companies trading its leather products in the EU market must be aware of the new framework, and ensure they take the necessary actions to be in line with the new legislation to avoid disruption on their trade relations.

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