Update on chromium VI restrictions

A report on the latest European regulation on the use of this substance.

by John Hubbard

On 25th March 2014, the European Commission published a new regulation 301/2014. This was a little over two years after the Danish government applied to the European Chemicals Agency (ECHA) to extend the REACH Annex XVII restriction on chromium VI to include leather articles and other leather articles containing leather parts which will come into contact with the skin. This regulation amends entry 47 of Annex XVII of the REACH regulation (1907/2006), and contains the following clauses:

5. ‘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 3mg/kg (0,0003 % by weight) of the total dry weight of the leather’.

6. ‘Articles containing leather parts coming into contact with the skin shall not be placed on the market where any of those leather parts contains chromium VI in concentrations equal to or greater than 3mg/kg (0,0003 % by weight) of the total dry weight of that leather part’.

7. ‘Paragraphs 5 and 6 shall not apply to the placing on the market of second-hand articles which were in end-use in the Union before 1 May 2015’.

The requirements will apply to all products within the scope placed on the market from 1st May 2015. The regulation cites EN ISO 17075 as the reference test method. The determination limit of this method is 3mg/kg, and this is the basis for monitoring and enforcing these requirements. However, this limit is higher than the ‘Lowest-Observed Adverse Effect’ level used by the EHCA risk assessment committee. Therefore, there is pressure for a more sensitive test method to be developed.

The new regulation is aimed at reducing the occurrence of chromium VI-related allergic dermatitis from leathergoods, and it is envisaged that the instance of such reactions will drop by 80 per cent when the regulation is in place.

If the regulation does not bring the required reduction in incidents of allergic dermatitis, or a more sensitive method becomes available, then this regulation will be reviewed.

Publishing Data

This article was originally published on page 6 of the May 2014 issue of SATRA Bulletin.

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