Restrictions on Chrome VI

Restrictions on Chrome VI

By Erik de Potter

Restrictions are normally used to limit or ban the manufacture, placing on the market (including imports) or use of a substance, but can impose any relevant condition, such as requiring technical measures or specific labels. Restriction is one of the available instruments in EU-REACh to protect human health and the environment from unacceptable risks posed by chemicals. Restrictions are normally used to limit or ban the manufacture, placing on the market (including imports) or use of a substance, but can impose any relevant condition, such as requiring technical measures or specific labels.

Restrictions are in Annex XVII of the REACh Regulation. Chrome VI is mentioned in several restrictions. Entry 47 in Annex XVII restricts the presence of Chrome VI in leather articles coming into contact with the skin to a maximum of 3 mg/kg of the total dry weight of the leather.

On 12 October 2018 an amendment to the REACh Regulation was published adding entry 72 to the list of restrictions. This restriction sets limits for certain CMR substances in clothing and accessories, textiles and shoes. One of the restricted substances is Cr(VI); the limit is set to 1 mg/kg (=ppm).

Entry 72 of Annex XVII would introduce a stricter limit, which would be hard to meet for chrome tanned leather. However, in point 3 of entry 72 of the restirciton conditions an exemption is made for clothing, related accessories or footwear, or parts of clothing, related accessories or footwear, made exclusively of natural leather, fur or hide.” This exempts natural leather from this new restriction. Restriction 47 remains valid.

A new restriction covering skin sensitizing substances is in preparation. In the current proposal a limit of 1 ppm for Chromium VI in leathers is set. The current analytical method (ISO 17075) has a detection limit of 3 ppm, however. Smit & Zoon is participating in preparing a joint and well-documented comment to the proposed restriction. Only after having assessed all comments, the decision making process will be continued by authorities.

As Chrome VI has been a hot topic in leather industry for many years, we have a SmiTool on the prevention of Chrome VI formation in leather available on our website.