EU REACH for Leather Goods: Chromium VI and Azo Dye Checks
For EU leather sourcing, check chromium VI and restricted azo-dye evidence as separate questions. Match each report to the proposed material, colour and relevant component, then review the legal scope and result. A generic “REACH compliant” statement does not identify which substances, samples or conditions were assessed.
Which REACH questions does this guide cover?
This guide compares two restrictions in Annex XVII of REACH, the EU chemicals framework: chromium VI in leather and certain azo dyes that can release listed aromatic amines. It is not a complete assessment of every substance, component or obligation relevant to a finished product.
Use the distinction to prepare a more precise conversation with your importer and testing laboratory. ECHA explains that a consolidated version reflects restrictions adopted up to its publication, while subsequent changes appear in amending regulations. Check the official restriction list and legal references before accepting the scope for an order. The review date of an article is not evidence that a restriction is new.
How do the chromium VI and azo-dye restrictions differ?
The substance, contact condition and concentration wording are different. Do not reduce both entries to an unexplained “3 and 30” pass/fail note.
Entry 47, paragraphs 5 and 6, addresses leather articles, and relevant leather parts of articles, coming into contact with the skin. Its placing-on-the-market restriction applies at chromium VI concentrations equal to or greater than 3 mg/kg of the total dry weight of the leather or relevant leather part. A result for total chromium is not a result specifically identified as chromium VI.
Entry 43, paragraphs 1 and 2, concerns certain azo dyes that can release aromatic amines listed in Appendix 8 through reductive cleavage. The stated condition is above 30 mg/kg in the article or dyed parts, according to the methods in Appendix 10, for textile or leather articles that may have direct and prolonged contact with skin or the oral cavity. This is not a blanket ban on every azo dye.
| Check | Chromium VI: Entry 47 | Azo dyes: Entry 43 |
|---|---|---|
| What is measured? | Chromium VI in the relevant leather. | Listed aromatic amines released from certain azo dyes. |
| Contact wording | Leather articles or leather parts coming into contact with skin. | Textile or leather articles that may have direct and prolonged skin or oral contact. |
| Cited concentration wording | Equal to or greater than 3 mg/kg, on the specified leather dry-weight basis. | Above 30 mg/kg in the article or dyed parts under the specified methods. |
| Do not substitute | A total-chromium number or an unexplained whole-product average. | A dye name, “azo-free” slogan or total-dye number without the relevant analysis. |
The table summarises the cited provisions; it does not decide whether a particular result or product is acceptable. Have the laboratory confirm applicable wording, methods and reporting limits, including any exceptions and other requirements relevant to the project.
Why is a general supplier statement not enough?
A general statement does not identify the sample behind an analytical result. Ask what was tested and how that sample relates to the material and components proposed for your order.
A document headed “REACH compliant” may be a declaration, a summary or a reference to a separate report. Request the underlying scope rather than treating the heading as proof. Likewise, a facility document does not by itself describe which analytes were measured in a particular sample. This is a document-review distinction, not a conclusion that the supplier's material has failed.
Keep any unconfirmed link visible in the approval record. Do not turn a report for one identified leather into a blanket claim covering every colour, lining, finish or future order.
How should the product, material and report be linked?
Build a traceable connection between the product brief, the sample description and the reported result. The following is a buyer's evidence checklist, not a claim that every field is a separate legal testing obligation.
- Product and use: identify the proposed item, EU destination and intended contact conditions for scope review.
- Component: show which leather face, strap, lining or other relevant part the submitted sample represents.
- Material identity: record the supplier's material reference, colour, finish and any agreed lot or batch relationship.
- Report identity: retain the report number, laboratory, date, sample description and available photographs.
- Assessment scope: check the named analytes, method and version, units, reporting limits, results and stated conclusion.
If those records cannot be connected, ask the supplier and laboratory what additional identification or evidence is needed. A similar-looking swatch or the same product title is not the missing traceability link.
What should buyers ask when reading the results?
Read the result alongside its method, units and reporting limits, not just a highlighted conclusion. Ask the laboratory to explain anything that prevents a clear comparison with the agreed requirement.
For chromium VI, confirm that the report addresses the relevant leather and basis of measurement. For azo-dye evidence, confirm the assessed aromatic amines and relevant method scope. Do not treat “not detected” as a self-explanatory zero; ask which reporting or detection limit the statement uses.
Keep the difference between “equal to or greater than” and “above” intact. Do not convert a rounded number or unclear result into an approval yourself. Record the laboratory's clarification and the buyer's agreed specification with the report.
What should happen when the order changes?
Review whether the existing evidence still represents the proposed supply before accepting a material or construction change. Do not invent a universal report expiry period or assume every reorder automatically needs the same testing plan.
- Identify what changed, such as the material source, colour, finish, component or intended use.
- Compare that change with the sample and scope described in the existing evidence.
- Ask the importer and laboratory whether the plan needs clarification, additional evidence or new testing.
- Record the decision and any open conditions before final order approval.
These are suggested purchasing controls. They are not a promise that a chosen test plan establishes compliance with all REACH provisions or every destination-market requirement.
What belongs in the sourcing brief?
Send the intended EU use, product configuration, materials, colours and required documentation together. Ask which details are confirmed and which still need supplier, importer or laboratory review.
Discuss your leather goods sourcing brief with Aarons Leather, including the proposed components and evidence requirements. Any project-specific documents and testing arrangements must be confirmed; this guide does not assert that an Aarons product has been tested, certified or approved.
Scope note: this is an explanation of two cited restrictions and a practical document-review approach, not legal advice or a complete regulatory audit. Confirm the current legal text, later amendments and project-specific scope before relying on a result for an EU order.
