Chromium in Leather: Why Most Pakistani Exporters Are Running the Wrong Test

There are two chromium tests for leather. One measures total chromium content. The other measures hexavalent chromium — the toxic, carcinogenic form that EU law actually restricts.

Most Pakistani leather and footwear exporters run the total chromium test. They receive a clean result. They assume their product is compliant. It is not a safe assumption — and a European market surveillance authority will not make it for them.

This misunderstanding has caused EU border rejections, product recalls, and buyer contract terminations for Pakistani leather exporters who believed their testing was in order.

Why chromium is in leather in the first place

Approximately 80% of leather produced worldwide is chrome-tanned — treated with chromium(III) sulphate, a stable, non-toxic compound that produces soft, durable leather that holds colour well. Chrome tanning has been the global industry standard for over a century.

The problem is not the chromium(III) used in tanning. The problem is what it can become.

Under certain conditions — exposure to heat, light, bleaching agents, alkaline pH, or oxidising chemicals during finishing and dyeing — chromium(III) can oxidise to chromium(VI), also known as hexavalent chromium or Cr(VI). Chromium(VI) is classified as carcinogenic. It causes allergic contact dermatitis, is a known respiratory carcinogen, and is listed as a substance of very high concern (SVHC) under EU REACH.

The EU REACH limit for Cr(VI) in leather

EU REACH Annex XVII, Entry 47 restricts the placing on the EU market of leather articles — footwear, gloves, garments, watch straps, handbags, belts, accessories — containing Cr(VI) at or above 3 mg/kg (3 ppm) of total dry leather weight. This restriction has been in force since May 1, 2015.

There is no “grace period.” There is no threshold for “trace amounts.” If a leather article contains Cr(VI) at or above 3 mg/kg, it cannot legally be sold in the EU. Market surveillance authorities in Germany, the Netherlands, Sweden, and other active enforcement markets test leather products routinely and order recalls when the limit is exceeded.

For Pakistani leather exporters, this restriction sits alongside PFAS restrictions in leather finishing chemistry as one of the two most frequently triggered EU enforcement actions in the Pakistan leather sector.

Total chromium vs hexavalent chromium — why they are not the same test

Total chromium tells you how much chromium is present in all its forms. It does not tell you what proportion is Cr(VI). A leather article with 5,000 mg/kg total chromium (entirely as Cr(III) from chrome tanning) could theoretically have zero Cr(VI) — or it could have 10 mg/kg Cr(VI). The total chromium test cannot distinguish between them.

EN ISO 17075 is the only internationally recognised analytical method that satisfies EU REACH Entry 47. A Cr(VI) test by any other method, or a total chromium test presented as Cr(VI) compliance evidence, will not satisfy a European market authority. This is the same principle that applies to test reports more broadly — the correct standard matters as much as the test result.

Why Cr(VI) is found even in properly chrome-tanned leather

Chrome tanning begins with Cr(III). Cr(VI) should not be present in newly tanned wet leather. But leather goes through many subsequent processes — fat liquoring, dyeing, retanning, bleaching, finishing — and any of these can create oxidising conditions that convert Cr(III) to Cr(VI).

Factors that increase the risk of Cr(VI) formation:

• Use of oxidising agents (certain bleaches, peroxides) in finishing
• High pH in post-tanning processes
• Use of certain fat liquors that catalyse oxidation
• Storage and ageing — Cr(VI) can form over time, particularly in warm, humid conditions
• UV exposure (light-coloured leathers are more susceptible)

A 2019 study published in the journal Contact Dermatitis found Cr(VI) in a significant proportion of leather footwear samples collected from retail markets across Copenhagen — products that had passed initial production testing but had developed Cr(VI) during storage and shipping.

This is why some buyers specify Cr(VI) testing at point of shipment, not just at point of production.

Chromium test leather EU compliance — frequently asked questions

Does the EU REACH Cr(VI) limit apply to all leather products or just footwear?

The restriction applies to all leather articles intended to come into contact with the skin. This includes footwear (all components — uppers, insoles, linings), gloves, garments, watch straps, handbags, belts, and any leather accessory that contacts the skin in normal use. Leather used in furniture or automotive interiors is not covered by Entry 47 — but may be covered by buyer specifications or other standards. For Pakistani exporters, the sectors most affected are footwear, leather garments, and leather accessories exported to the EU.

Is there a test for Cr(VI) that I can run at my factory, without sending to a lab?

There are some indicator-based field tests for Cr(VI), but these are not accepted for regulatory compliance purposes. EU REACH Entry 47 requires testing by EN ISO 17075-1 or -2:2017, performed by a laboratory — and specifically an accredited laboratory whose reports are accepted under the ILAC MRA framework. A field test result is useful for internal process monitoring but cannot appear on a compliance test report or be presented to a buyer as REACH evidence.

My tannery tests for Cr(VI) at the wet blue stage. Is that sufficient?

No. Wet blue is the leather immediately after chrome tanning, before any finishing or dyeing processes. Cr(VI) levels at wet blue stage tell you nothing about the finished article. Cr(VI) can form during any subsequent process — fat liquoring, retanning, dyeing, bleaching, surfacing — and can increase during storage. EU REACH Entry 47 applies to the finished article placed on the market, not the semi-processed raw material. Compliance testing must be done on the finished, retail-ready product.

What is the difference between EN ISO 17075-1 and EN ISO 17075-2?

Both are valid methods for Cr(VI) testing under EU REACH Entry 47. EN ISO 17075-1:2017 uses a colorimetric method (diphenylcarbazide) — it is simpler and more widely available. EN ISO 17075-2:2017 uses ion chromatography (IC) — it is more sensitive at very low concentrations. Both have the same regulatory standing. Some buyers or enforcement authorities may specify one method over the other; check your buyer’s test request carefully. If no method is specified, either is acceptable for REACH compliance.

Can chrome-free leather avoid all Cr(VI) risk?

Yes — if the leather is genuinely chrome-free (vegetable-tanned, aldehyde-tanned, or synthetic-tanned without any chromium-containing compounds), there is no Cr(VI) risk from the tanning chemistry. However, some chrome-free leathers still use chromium-containing dyes or finishes — so “chrome-free tanned” does not automatically mean “Cr(VI)-free.” If you are marketing leather as chrome-free, test the finished article to confirm, and ensure your entire process chain (tanning, dyeing, finishing) uses no chromium-containing inputs.

What Pakistani leather exporters should do

1. Replace total chromium tests with EN ISO 17075 Cr(VI) tests for any leather product exported to the EU, UK, or any market that references REACH Annex XVII Entry 47.
2. Review your finishing and dyeing chemistry with your chemical supplier. Identify any oxidising agents or high-pH processes that increase Cr(VI) formation risk.
3. Test the finished article, not just the tanned leather. Cr(VI) can form during any downstream process. Testing raw tanned leather does not confirm the finished article is compliant.
4. Consider Cr(VI) testing at multiple points — post-tanning, post-finishing, and pre-shipment — if your process uses treatments known to increase oxidation risk.
5. Check your buyer’s RSL version. Some buyers have tightened their internal Cr(VI) limits below the REACH threshold. Confirm which limit applies to your orders.

Tti Testing Laboratories’ leather testing capability

Tti Testing Laboratories conducts hexavalent chromium Cr(VI) testing in leather using EN ISO 17075-1:2017 and EN ISO 17075-2:2017, under ISO/IEC 17025 accreditation. Results are accepted in 70+ economies through the PNAC ILAC/APLAC MRA, including all EU member states.

Tti also provides comprehensive leather testing covering REACH restricted substances, heavy metals, azo dyes, formaldehyde, pentachlorophenol, and buyer RSL requirements across leather goods, footwear, garments, and accessories.

For leather testing enquiries, contact marketing@ttilabs.net or visit www.ttilabs.net.

Sources: EU REACH Annex XVII Entry 47, EN ISO 17075-1:2017 and -2:2017, SATRA chromium VI technical bulletin, EARP Corp REACH chromium guidance, ChemSafetyPro REACH Cr(VI) restriction summary.

EN ISO 17075-1 vs 17075-2: Which Test Does Your Buyer Require?

Rule of thumb: If your buyer has a published RSL (Restricted Substances List), always book ISO 17075-2. If you are only proving EU REACH compliance for customs and have no named buyer RSL requirement, Part 1 is sufficient — but Part 2 is always the safer choice.

The 4 Most Common Chromium VI Test Failures in Pakistani Leather