Chromium VI in Leather: EU REACH Limit and Testing

Key takeaways

Leather articles, and articles with leather parts, that come into contact with the skin must contain less than 3 mg/kg chromium VI in the EU.
The 3 mg/kg threshold matches the quantification limit of the EN ISO 17075 method. Results depend on the extraction conditions, so use an accredited lab and the full method.
Chromium VI is not added on purpose. It forms when chromium III from tanning oxidises, which can happen after tanning, in storage or in transit.
In the US, hexavalent chromium is on the California Prop 65 list. Children's leather products also fall under CPSIA lead and certification rules.
Inspection checks leather source, tannery lot and storage conditions against the tested sample; Cr VI can only be measured by a lab.

Who it applies to and from when

Commission Regulation (EU) No 301/2014 added paragraphs 5 to 7 to entry 47 (chromium VI compounds) of REACH Annex XVII. Since 1 May 2015 it has applied to anyone placing leather goods on the EU market, including importers. It followed a Danish proposal showing that chromium VI in leather that touches the skin can cause skin sensitisation and allergic reactions.

Source: REACH Annex XVII entry 47, paragraphs 5–7, inserted by Regulation (EU) No 301/2014, reviewed 13 Oct 2026.
Covered	Not covered
Leather articles in contact with the skin: footwear, gloves, belts, watch straps, wallets, bags with handles, garments	Leather that does not come into contact with the skin
Articles with leather parts in contact with the skin, such as a textile bag with leather handles or a chair with leather armrests	Second-hand articles already in end use in the EU before 1 May 2015

The ban applies to each leather part separately. If any one leather part that touches the skin reaches 3 mg/kg, the whole article cannot be placed on the market.

The limit and the test method

Item	Requirement
Limit	Must not contain chromium VI at 3 mg/kg (0.0003% by weight) or more, of the total dry weight of the leather or leather part
Test method named in the recitals	EN ISO 17075, now in two parts: EN ISO 17075-1 (colorimetric) and EN ISO 17075-2 (chromatographic)
Why 3 mg/kg	It is the determination limit of EN ISO 17075, set for enforceability
Ageing test (optional)	ISO 10195 heats leather before testing to show its tendency to form chromium VI later

ISO states that results depend strictly on the extraction conditions in the standard (a buffered salt solution at pH 7 to 8). Results from other extraction methods are not comparable. Where a sample is tested by both parts, Part 2 is treated as the reference, because the extract's color can interfere with the colorimetric method.

How chromium VI forms in leather

Most leather is chrome tanned with chromium III salts, which cross-link collagen and make the leather stable and heat resistant. Chromium III is not the restricted form. Regulation 301/2014 explains that chromium VI forms when chromium III oxidises, and that the conditions are known and can be controlled.

Formation can continue after the leather leaves the tannery. ISO 10195 heat-ages leather before testing to show this tendency, so a leather that passes at the tannery can test higher later. The regulation notes that most EU tanneries already control and minimise chromium VI formation. Your supplier should be able to explain its tannery's controls and show recent test reports for the leather it uses.

US notes: Prop 65 and CPSIA

We found no US federal limit specific to chromium VI in leather goods. Two US rules are still relevant:

California Proposition 65. OEHHA lists chromium (hexavalent compounds) as causing cancer (since 1987) and reproductive toxicity (since 2008). Leather goods sold in California may need a warning unless exposure is below the safe harbor levels. Many US retailers set their own Cr VI limits and test requirements in vendor manuals.
CPSIA. Leather products designed mainly for children 12 and under, such as kids' shoes, belts or bags, must meet the lead content limit and need third-party testing, a Children's Product Certificate and tracking labels.

What this means for leather made in India

India's leather clusters include Kanpur (saddlery, harness and tanned hides), Agra (footwear) and Tamil Nadu, around Chennai and the Vellore, Ambur and Ranipet belt (tanning, footwear and leather goods). Points to watch:

Leather source. A product maker often buys leather from several tanneries or traders. Each source needs its own Cr VI evidence, linked to the lot used in your order.
Storage and transit. Because Cr VI can form over time, and heat is used to show that tendency, hot storage is a risk. Testing finished goods close to shipment gives a more useful result than an old tannery report.
Mixed materials. Leather trims on textile bags, footwear linings and watch straps all count if they touch the skin.
Other chemicals. EU buyers often test leather for azo dyes, PCP and other restricted substances at the same time. See azo dyes and restricted substances.

What inspection can check, and what needs a lab

An inspector at the factory can check	Needs lab testing
Leather type, color and finish match the tested sample	Chromium VI to EN ISO 17075-1 or -2
Tannery invoices and lot numbers link the leather in store to the test reports	Ageing tests to ISO 10195, if the buyer asks
Storage of leather and finished goods: heat, sunlight and ventilation	Azo dyes, PCP and other restricted substances
Labels and Prop 65 warnings, where the buyer requires them	Lead content for children's products (CPSIA)

How Clear To Load checks this in India

We cover every city in India, including the Kanpur, Agra and Chennai leather clusters. On a pre-shipment inspection, the inspector compares leather with the tested sample, checks tannery lot records against the order and records workmanship defects against your AQL. For Cr VI tests, we draw random samples from finished goods, seal them and send them to an ISO/IEC 17025-accredited lab you choose or we suggest, through lab testing coordination.

Reports arrive within 24 hours of the inspection with a verdict of Cleared to load, Hold or Not cleared. Travel outside our inspector base cities is charged at actual cost; see pricing or book an inspection.

Sources

Frequently asked questions

Is the EU limit 3 mg/kg or less than 3 mg/kg?

Leather must not contain chromium VI at 3 mg/kg or more of its total dry weight. In practice, any result at or above the method's 3 mg/kg determination limit fails. A report of “not detected” at a 3 mg/kg limit is a pass.

Does vegetable-tanned leather need Cr VI testing?

The restriction covers all leather that touches the skin, whatever the tanning method. Leather tanned without chromium carries less risk, but buyers often still ask for a test, because combination tannages and mixed leather sources are common.

Why did my leather pass at the tannery but fail later?

Chromium VI can form over time when chromium III oxidises. ISO 10195 heat ageing is designed to show this tendency. Testing finished goods close to shipment, and controlling storage, reduces the risk.

Is there a chromium VI limit for leather in the US?

We found no federal limit specific to leather. California Prop 65 lists hexavalent chromium, so goods sold there may need a warning, and many US retailers set their own limits. Children's leather products must also meet CPSIA lead rules.

Can a factory inspection detect chromium VI?

No. Chromium VI can only be measured in a lab with EN ISO 17075. An inspection checks that the leather in production matches the tested lot and sample, and can draw and seal samples so the lab tests real goods.

Know before it ships

Tell us the product, the factory's city and your ready date. We confirm the inspector, the notice time and the price before you book.

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Chromium VI in leather goods made in India