Chromium VI Testing for Leather from India: EU & UK Importer Guide
Chromium VI testing for leather from India is a must for EU and UK importers: since 1 May 2015, leather that touches the skin cannot be sold in either market if it contains 3 mg/kg or more of hexavalent chromium. Ask your Indian manufacturer for an EN ISO 17075 lab report for each leather lot before the goods ship.
Key Takeaways
Limit: below 3 mg/kg chromium VI (0.0003% by weight) of the leather's total dry weight, for leather in contact with the skin (updated October 2026).
Legal basis: REACH Annex XVII entry 47, added by Commission Regulation (EU) No 301/2014; Great Britain applies the same limit under UK REACH.
Test method: EN ISO 17075-1 (colorimetric) to screen, EN ISO 17075-2 (chromatographic) to confirm positive results.
ISO 10195:2018 heat-ageing shows whether a leather is likely to form chromium VI later in its life.
The EU or UK company placing the goods on the market carries the compliance risk, so write the test into the purchase order.
What is chromium VI, and why can it appear in leather from India?
Chromium VI (hexavalent chromium) is a skin sensitiser that can form in chrome-tanned leather after tanning; it is not the chromium used to tan. Most leather made worldwide, including in India, is tanned with trivalent chromium salts (chromium III), which are not restricted.
The problem starts when some chromium III oxidises. The AFIRM chromium VI information sheet lists the main triggers: UV light, high temperatures, low humidity and oxidising gases; bleaching agents such as peroxides; high pH; and unprotected fatliquors that form oxidising lipid peroxides. That is why a leather can pass a test at the tannery and fail months later in a hot warehouse.
The rule exists to cut allergic contact dermatitis. When the restriction was adopted, SATRA reported projections that such reactions would fall by about 80% once it applied.
What does EU REACH entry 47 require for leather goods?
It sets a single limit of 3 mg/kg chromium VI for any leather article, or leather part of an article, that touches the skin. The details below are taken from Regulation (EU) No 301/2014 on EUR-Lex and the retained UK version on legislation.gov.uk, as of October 2026.
Point | What the rule says | What it means for your order |
Limit | Below 3 mg/kg (0.0003% by weight) of total dry weight of the leather | A result of 3 mg/kg or higher is a fail, not a borderline pass |
Scope | Leather articles, and articles with leather parts, in contact with the skin | Footwear, jackets, gloves, straps, handles and linings are all in scope |
Start date | Applied from 1 May 2015 | Any leather product you import today must comply |
Exemption | Second-hand articles in end-use in the EU before 1 May 2015 | No exemption for new production orders |
Great Britain | Same limit retained under UK REACH | One specification can serve UK and EU ranges |
Test method | EN ISO 17075 (determination limit 3 mg/kg) | Ask for the method number on every report |
Which chromium VI tests should EU and UK buyers ask an Indian supplier for?
Ask for EN ISO 17075 results from an ISO/IEC 17025-accredited laboratory, and add ISO 10195 ageing for higher-risk leathers. Each test answers a different question.
Test | What it shows | When to request it |
EN ISO 17075-1 (colorimetric) | Chromium VI content of the leather as tested | Standard screening on every bulk leather lot |
EN ISO 17075-2 (chromatographic) | Confirms or rules out a positive result, avoiding false positives from dyes | When a colorimetric result is close to or above 3 mg/kg, and for dark-dyed leather |
ISO 10195:2018 ageing + ISO 17075 | Chromium VI after thermal pre-ageing, i.e. the tendency to form it later | Light-coloured, white or pastel leather, linings, and goods sold in hot climates |
ISO describes ISO 10195:2018 as a thermal pre-ageing procedure that indicates a leather's tendency to form hexavalent chromium; it does not simulate real production or use, so treat it as a risk indicator rather than a legal pass or fail.
Who is responsible if a leather shipment from India fails?
The company that places the goods on the EU or UK market, usually the importer or brand, is the one breaking the restriction. Your Indian factory is outside EU and UK jurisdiction, so a failed market-surveillance test lands on you, along with any recall or withdrawal costs.
That is why experienced importers make chromium VI a contractual requirement, not an assumption. A tannery's environmental credentials help, but they are not a product test. Our guide to what LWG certification covers when sourcing leather explains where that line sits.
How do you build chromium VI control into a production order from India?
Write the limit, the test and the sampling point into your specification before sampling starts. A practical sequence looks like this:
State "chromium VI below 3 mg/kg per REACH Annex XVII entry 47, tested to EN ISO 17075" on the tech pack and purchase order.
Name the leather for every skin-contact part: lining, sock or insole cover, collar, straps and trims, not only the upper.
Test each bulk leather lot before cutting, so a failing lot is rejected while it is still a hide, not a finished shoe or jacket.
Add ISO 10195 ageing for white or pale leathers and for ranges going to hot or sunny markets.
File each report against the lot number and the shipment, so you can answer a customs or market-surveillance request quickly.
Close the loop with a pre-shipment inspection; our explainer on AQL inspection for leather orders covers how sampling levels work.
For sandals, slip-ons and unlined jackets, the skin-contact leather is often the whole article, so test the leather that will be worn against bare skin and keep the same tannery and recipe from approved sample to bulk.
How Sanwas International works with EU and UK brands
Sanwas International is an LWG-certified OEM and private label leather manufacturer based in Jalandhar, Punjab, India, producing footwear, outerwear, furniture leather and hides for brands in India and worldwide. We work with MOQs under 500 units per style, offer complimentary first samples, run sampling in as little as 72 hours and bulk production from around 30 days, and finish orders with AQL inspection.
If your range is going to the EU or UK, include your chemical requirements, such as the chromium VI limit and test method, in your enquiry so they are built into leather selection, sampling and costing from day one. You can see the leathers we work with on our materials and manufacturing expertise page, or request a quote for your leather order.
Frequently Asked Questions
Can I import chrome-tanned leather shoes from India into the EU if they pass a chromium VI test?
Yes. EU law does not ban chrome tanning; it limits hexavalent chromium to below 3 mg/kg in leather that touches the skin. A passing ISO 17075 result covers that one restriction, so you still need to check the other REACH Annex XVII rules that apply to leather, such as the azo dye restriction in entry 43.
Does the 3 mg/kg chromium VI limit also apply to leather jackets and bags, or only to shoes?
It applies to any leather article, or leather part of an article, that comes into contact with the skin, so jackets, gloves, watch straps and bag handles are in scope as well as footwear. Test the leather that actually touches the wearer, such as linings, collars, straps and insoles, rather than only the outer upper.
Is vegetable-tanned leather from India automatically free of chromium VI?
Not automatically. Pure vegetable-tanned leather carries a much lower risk because no chromium salts are used for tanning, but some leathers are chrome-tanned and vegetable-retanned, or chrome is used elsewhere in the process. Ask the supplier to state the full tannage on the specification and request a test report if the article touches the skin.
Do UK importers need a separate chromium VI test from EU importers for the same leather order?
Usually not. Great Britain kept the same 3 mg/kg chromium VI limit for skin-contact leather under UK REACH, and both markets rely on the EN ISO 17075 method. One report from an ISO/IEC 17025-accredited lab that clearly identifies the article and leather lot can normally support compliance files in both markets.
Who should pay for chromium VI lab testing on an export order from an Indian leather factory?
That is a commercial point to agree before the order, not something an Incoterm settles. Many buyers list the required tests, the lab and the number of samples in the purchase order and agree whether the cost sits in the unit price or is billed separately. Whatever you agree, the EU or UK company placing the goods on the market remains legally responsible for compliance.
Sourcing Chrome-Tanned Leather Goods for the EU or UK? Request a Quote
Brands, sourcing managers, retailers and importers in the EU and UK can send us the product category, leather type, target quantity, destination country, preferred Incoterm and target delivery date, along with any chemical test requirements. First samples are complimentary, and Sanwas International supplies buyers across India and exports worldwide.
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