May 28, 2014

The EU has updated its chromium legislation for leather. MADE-BY’s Chemical Expert, Viktor Fihlman discusses why this is big news for the fashion industry.



Image: Selipu

When looking at your leather bag or belt, the use of chemicals such as chromium might not come to mind, but it’s a key chemical used in 80% of all leather tanning processes. The EU’s announcement that it will be tightening up chromium legislation, means that if you produce leather articles such as bags, gloves or footwear, these changes could affect you.

Whilst most of the chromium is washed off in later stages of the garment production process, residues can remain and even transform into the more hazardous form chromium (VI), a known carcinogen. This change can occur under specific circumstances where chromium (III) is exposed to heat, UV radiation or even other chemicals. How widespread is this issue? Well a study in Denmark, found that over half of imported leather shoes and sandals in 2011 were found to contain chromium (VI).

To tackle this issue the EU has announced that it will tighten up legislation concerning the presence of chromium (VI) in leather articles that come into contact with skin. These include footwear, gloves, clothes, bags and sports equipment. So therefore, as of the 1st May 2015, no products containing chromium (VI) in concentrations above 3mg/kg can be placed on the EU market.

“What’s important to note here is that whilst the EU has set a concentration limit, this new legislation in practice is an outright ban, because 3mg/kg is the lowest amount of chromium (VI) that can be detected by current standard technology”
Viktor Fihlman,Technical Specialist: Chemicals, MADE-BY

What can I do?

The first major priority for a brand is to increase its visibility of its tanneries in the supply chain, this is especially true for brands sourcing through agents. If you find yourself answering “no” to questions such as do you know where your tanneries are located? Have you any insight into the processes or chemicals they are using? Have you any way of communicating with them? Then you need to increase your visibility via supply chain mapping before you can begin to resolve this issue.

For brands with better visibility of their tanneries, a first step would be to communicate these new legal requirements to suppliers and ask them for details around the processes used. An analysis of current compliance could also be helpful to determine the scope of the problem. If you’re lucky, your suppliers could already be on top of this issue.

Closer communication with your suppliers and a thorough analysis of current compliance can then serve as a good basis for further work in chemical management and strategy. If there is an issue with chromium (VI) in products, brands can choose to deal with this new legislation in a number of ways; most brands will probably work to minimise the formation of chromium (VI) from chromium (III) by improved chemicals management in production, something that will require significant cooperation and communication with tanneries.

Another way to deal with this problem would be to reduce the use of chromium-tanned leather altogether. Chrome-free tanning is possible, whilst for now it’s a relatively niche market, there are significant opportunities for brands to invest in these technologies and drive innovation in this area. As well, looking into sourcing materials other than leather might be also an option to consider.


Chromium (VI) content in leather has been an issue for many years, similar restrictions as the one discussed here already exist in Germany and several eco-label organisations such as Oeko-Tex and GOTS have already banned chromium (VI) in leather. Luckily enough, the methods for dealing with these issues are well-established.The EU’s move to restrict chromium (VI) further strengthens the case for brands sourcing leather products to improve their supply chain visibility of where products are tanned and finished. With greater visibility of their leather supply chain, brands can work more closely with their tanneries to develop efficient processes as part of a wider chemical management strategy.

These new requirements are not the first, nor will it be the last issue regarding chemical content in products. By implementing these steps, issues like this become that much easier to deal with in the future, allowing brands to reduce risks as well as their environmental impact.

Viktor Fihlman- Technical Specialist: Chemicals

Tags: chemistry, chromium, eu, leather, mapping, reach, supply chain, transparency.