Denmark Announces Dossier regarding Hexavalent Chromium in Leather

The European Chemicals Agency (ECHA) received a notice of intention by Denmark to submit a dossier regarding the restriction of Chromium VI in leather with skin contact based on its allergic effects. The dossier according to Annex XV of the REACH-directive is expected to be submitted in January 2012. If approved by the ECHA, Chromium VI could become regulated under Annex XVII in the future for products placed on the European market.

Background
Denmark has notified ECHA of its intentions to submit a dossier according to Annex XV of REACH (EC 1907/2006) regarding restrictions of Chromium VI in leather with skin contact. According to the proposal, Chromium VI would be included to Annex XVII of the Regulation EC 1907/2006. The dossier includes suggestions for limits as well as field of application and is expected to be submitted by 19 January 2012 according to the ECHA “Registry of intentions.”

The proposal comes as the result of a survey conducted by the Danish Ministry of the Environment which analyzed the contents and the sensitization potential of Chromium in leather shoes. Both Chromium III and Chromium VI were taken into account by the study. The results indicated that 50 of 60 reviewed shoes contained Chromium. Migration studies of 18 shoes determined that 44% of the reviewed shoes emitted Chromium VI. The Chromium VI-release of three of the 18 samples was more than 10 mg/kg. Furthermore, sandals seemed to be over-represented in the group of Chromium VI-containing shoes. The study also outlined that Chromium VI has a sensitizing effect and can cause skin reactions with allergic people.

No conclusion could be drawn on the influence of Chromium III on sensitization. Chromium III is used during the tanning process of 80% of the world’s leather production. Under certain production and storage circumstances, Chromium III can transform to Chromium VI. The content of Chromium VI in leather with skin contact is already prohibited in concentrations above limits of detection in leather products with skin contact in Germany according to the Consumer Goods Ordinance, Annex 5, Nr.2 (Bedarfsgegenständeverordnung). However, currently there is no such regulation concerning the whole of the EU.

Additional information:
Danish survey and health assessment of Chromium in leather shoes
http://www2.mst.dk/udgiv/publications/2011/08/978-87-92779-22-9.pdf

ECHA “Registry of intentions” http://echa.europa.eu/chem_data/reg_int_tables/reg_int_en.asp?substance_type=Restriction&substance_state=current

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