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ECHA launches a six-month public consultation on the proposed restriction of chromium VI in leather articles

The Danish authorities submitted a report proposing a restriction on the placing on the market of leather articles containing chromium VI in concentrations above a certain limit that come into direct and prolonged or repetitive contact with the skin. Chromium VI is known to cause severe allergic contact dermatitis in humans and is able to elicit dermatitis at very low concentrations. In particular, the risk assessment demonstrates that chromium VI present in shoes and other leather articles may cause contact allergies.

Chromium VI is not intentionally used in the preparation of leather from skins and hides and in the manufacturing of articles of leather, but may be formed during the processing by oxidation of chromium III used for the tanning of the leather. According to industry, measures for preventing the formation of chromium VI in leather are implemented in tanneries all across the European Union. Furthermore, many importers of leather articles require that they do not contain chromium VI in measureable concentrations. Nevertheless, surveys have demonstrated that more than 30% of the tested leather articles contain chromium VI in concentrations above 3 mg/kg, which is the concentration limit proposed by the Danish authorities.

Product Application
The list below contains the background and justifications for the proposed restriction. It includes the identified risks, information on alternatives, the effectiveness of the restriction in reducing the risks and the costs of the restriction.

Product group

Application

Footwear

Leather shoes, sandals and boots.
When used without stocking the skin is in prolonged contact with both the leather i.e. sole and the uppers.

Gloves

Many leather gloves (apart from protective gloves) have inner lining which reduces the direct exposure to the leather.
Some types of thin soft leather such as suede and gloves used for riding, driving, cycling, etc. are not equipped with a lining.
All types of gloves usually leave a small part of the leather in contact with the wrist.
Leather is widely used in protective gloves for personal protection which often do not have inner lining. Gloves have been more common as causative exposure in male patients than in female, which may be due to the males’ more common use of protective gloves. Today regulated at < 3 mg/kg Cr VI).

Underwear

The leather is probably in direct contact with the skin although some products may have lining.

Watch straps and other wrist straps / bands / braces

Commonly used for watches but also for braces and bracelets. The straps or braces are in direct contact with the skin. Some wrist straps e.g. used as bandages have a lining.

Neck straps

Commonly used as small straps used for necklaces. The strap is in direct contact with the skin.

Covers for car steering wheels

Prolonged contact with the hands.

Jackets and coats

Jackets and coats usually have inner lining, but the leather will be in direct contact with the skin around the wrist and the neck.

Trousers

Most leather trousers have inner lining, but trousers often do not have lining below the knee. A small part of the skin below the knee may be in prolonged contact with the leather.

Hats

Leather hats may have inner lining, but usually a part of the leather is in contact with the head.

Auto seats

The contact between the auto seats and the skin highly depends on the clothing of the user. During summer where many users of the cars wear shorts or short dresses, the legs are in prolonged contact with the leather.

Other furniture

The contact between the other furniture and the skin highly depends on the clothing of the user. During summer where many people wear shorts or short dresses, the legs are in prolonged contact with the leather.

Bags

For most types of bags contact between the handle and the skin of the hand when the bag is carried or opened/handled. Small handbags may be in prolonged contact with the hand. Shoulder bags may be in prolonged contact with the shoulder if the user wears a dress with bare shoulders.

Toys

E.g. leather dolls and animals. Prolonged contact with hand when playing with the toy.

Riding gear

In contact with the hand when handled. Prolonged contact with the reins when riding.

Dog leashes

Prolonged contact between the leash and the hand when the dog is taken out.

Although the six month public consultation concludes on 16 September 2012, the rapporteurs of RAC and SEAC would welcome any comments by 1 June 2012 to assist them in the first discussion of the restriction proposal in committee meetings of June 2012. 

The Solution
Intertek has the capability to evaluate chromium VI in leather articles to meet the safety requirement. By leveraging our local services and global network, we enable our customers to dedicate their primary energies to their core business activities.

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