REACH, Chrome-VI and Restricted Substances in Leather Imports to the EU and UK
What REACH means for leather-goods buyers importing to the EU and UK, why chrome-VI is the critical test, and how to get the documentation right before the container ships.
If you are importing leather goods into the EU or UK, REACH compliance is not optional, negotiable, or something to sort out after the container has shipped. It is a legal requirement, and the specific restriction that catches leather buyers most often is hexavalent chromium — chrome-VI, or Cr-VI — in leather articles. A single failed Cr-VI test can result in a market withdrawal, a border detention, or a product recall, and it is entirely preventable with the right documentation in place before your order leaves origin.
This guide covers what REACH requires for leather goods, why Cr-VI is the priority test, what documentation you need, and how to build compliance into your sourcing process rather than retrofitting it.
What REACH is
REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is EU chemical-safety regulation — formally Regulation (EC) No 1907/2006. It restricts or bans specific hazardous substances in products placed on the EU market, including imported goods. The UK retained a domestically administered version of REACH (UK REACH) post-Brexit, which currently maintains broadly equivalent restrictions.
For leather goods, the relevant restriction is in REACH Annex XVII, Entry 47: the restriction on hexavalent chromium (Cr-VI) in leather articles.
The chrome-VI restriction: what it requires
REACH Annex XVII, Entry 47 restricts Cr-VI in leather articles that come into contact with the skin. The restriction applies to articles, not just materials — meaning the obligation falls on whoever places the finished leather article on the EU or UK market. As the importer of record, that is you.
The restriction currently sets a maximum concentration of 3 mg/kg (3 ppm) of Cr-VI in any leather component of the article. This applies to all leather articles, regardless of whether the leather is chrome-tanned or not — the pathway to Cr-VI formation can affect even some vegetable-tanned leathers under certain conditions, though the risk is substantially lower.
The practical implication: Before placing leather goods on the EU or UK market, you need a test report demonstrating that Cr-VI content in the leather is below 3 mg/kg. The test must be conducted by a recognised, accredited laboratory — SGS, Intertek, QIMA, Bureau Veritas, or equivalent — and must cover the specific article or leather lot in the production run being placed on the market.
Why this matters for chrome-tanned leather specifically
Chrome tanning uses chromium III (Cr-III) salts, which are not restricted. The issue is that Cr-III can oxidise to Cr-VI under specific conditions: elevated pH in finishing processes, certain oxidising agents used in dyes or finishes, or heat. A well-run modern tannery using best-practice chemistry typically produces leather with undetectable or very low Cr-VI levels. A tannery using poor chemical management, incorrect pH control, or substandard finishing chemistry may produce leather that fails the test.
This is why:
- LWG certification of the tannery is an indicator of good chemical management but does not substitute for a finished-article Cr-VI test. The LWG audit covers tannery practices; the REACH test confirms what is in your specific goods.
- A supplier saying "we use LWG-certified leather" is not sufficient compliance documentation for REACH. You need a test report on the finished article (or at minimum on the leather lot used in production).
- Vegetable-tanned leather substantially reduces (but does not entirely eliminate) Cr-VI risk. A test report is still the only definitive proof.
SVHC and the full restricted substances picture
Cr-VI is the primary but not the only restricted substance concern in leather goods. The REACH Substances of Very High Concern (SVHC) list is a living document, updated periodically by ECHA (European Chemicals Agency), and currently contains over 240 substances. Relevant to leather goods:
- Azo dyes — certain azo colorants that can cleave to release restricted aromatic amines are restricted under REACH. Dyestuffs used in leather finishing should be confirmed as azo-dye compliant.
- Dimethylformamide (DMF) — used in some PU coatings and synthetic leather processes. Restricted under REACH.
- Biocides — some preservatives used on hides during transport and storage are restricted. Confirm with your tannery.
- Phthalates — used in some PVC and PU components (linings, coated elements). REACH restricts specific phthalates in articles.
- Heavy metals in hardware — cadmium, lead, and certain nickel-releasing alloys are restricted. Hardware should be tested to relevant restrictions if your retailer requires it.
A ZDHC (Zero Discharge of Hazardous Chemicals) MRSL-compliant supply chain provides a broader chemical-management framework that covers many of these. For most commercial buyers, a Cr-VI test plus a statement of ZDHC alignment from the tannery and factory provides a workable compliance baseline.
UK REACH: the post-Brexit position
The UK retained REACH restrictions domestically as UK REACH when it left the EU. As of 2026, UK REACH Annex XVII restrictions on Cr-VI in leather articles are broadly equivalent to EU REACH. Buyers placing goods on both the EU and UK markets need to meet both frameworks — in practice, complying with EU REACH generally satisfies UK REACH for leather goods as the critical restrictions are aligned. Monitor for any divergence; the UK government has authority to amend UK REACH independently and has signalled some areas of review.
The documentation you need
For any leather-goods shipment destined for EU or UK retail:
| Document | What it covers | Who provides it | When you need it |
|---|---|---|---|
| Cr-VI test report | Hexavalent chromium in leather components | Accredited lab (SGS/Intertek/QIMA/Bureau Veritas) on finished articles | Before goods are placed on the market; ideally pre-shipment |
| Azo dye compliance statement | Restricted aromatic amines from azo colorants | Tannery or dye supplier, with test report | At material approval stage |
| SVHC declaration (no SVHC above 0.1%) | Broader restricted substance coverage | Factory, based on supply chain verification | Requested by many EU/UK retailers |
| ZDHC MRSL alignment | Chemical management at tannery and factory | Tannery/factory, ideally with higg data or ZDHC roadmap | If required by your retail customer |
| LWG tannery certificate | Environmental management at tannery | Tannery (verify on LWG database) | At supplier approval stage |
Building compliance into the sourcing process
The common mistake is treating compliance documentation as a post-production task. By the time you are asking for a Cr-VI test report, the goods are finished and in the warehouse. If the test fails, you have a problem on goods you have already paid for.
The better approach:
- Specify REACH compliance at the brief stage. Include "Cr-VI test required, max 3 mg/kg per REACH Annex XVII Entry 47" and any additional SVHC requirements in your tech pack.
- Confirm tannery compliance at the material approval stage. Before bulk leather is committed, ask for the tannery's current Cr-VI test history and ZDHC alignment.
- Order a finished-article Cr-VI test at pre-production or early-bulk stage. Test the PP sample or early-bulk leather before production is complete. If the test fails, you have time to re-source the leather.
- Include test reports in your final documentation package. Commercial invoice, packing list, origin certificate, and compliance test reports should all be in hand before the container loads.
A factory-direct partner who understands your market handles this as standard process, not an extraordinary request. We prepare Cr-VI test reports and REACH documentation for EU and UK-destined orders as part of the standard shipping package.
Frequently asked questions
Does vegetable-tanned leather need a Cr-VI test? The risk is substantially lower, but a compliant finished-article test is still the only definitive evidence. Many EU retailers require test reports regardless of tannage.
Can my factory provide the test report? The factory should coordinate the test, but the report is issued by the accredited laboratory, not the factory. Ensure the report is from a recognised body, covers the specific production lot, and shows the methodology used (typically EN ISO 17075).
What happens if a test fails? EU and UK market surveillance authorities can require a product withdrawal. Some retailers require mandatory pre-shipment testing and will reject shipments without reports. Failing goods found in the market can trigger a RAPEX (EU) or OPSS (UK) notification — a public safety alert that affects the brand's reputation.
Does this apply to accessories as well as bags? Yes. REACH Annex XVII Entry 47 applies to all leather articles that come into contact with the skin, including wallets, belts, watchstraps, and keyfobs.
For the broader supply-chain due-diligence picture covering labour standards and environmental rules, see UK and EU due-diligence requirements for leather. For the LWG environmental certification context, see LWG certification explained.
How we handle REACH at EliteHeights
We include Cr-VI test reports as standard for EU and UK-destined orders. We source leather from tanneries with documented REACH-compliant chemistry and ZDHC MRSL alignment, and we can provide the full compliance documentation package — Cr-VI test report, azo dye compliance, SVHC declaration, LWG tannery certificate — with every shipment.
If your retail customers have specific compliance requirements beyond the standard package — a named testing body, a ZDHC Roadmap level, or specific SVHC substance thresholds — tell us at the brief stage and we will confirm whether we can meet them before you commit to sampling. Talk to Nehal about your compliance requirements before the order is placed, not after the container is loaded.