Chrome VI Prop 65 Settlements for Leather Goods

Chrome VI Prop 65 Settlements for Leather Goods

California Proposition 65, commonly known as Prop 65 is a legislation that was first enforced in the American state of California in 1986 as part of the Safe Drinking Water and Toxic Enforcement Act. The purpose of the legislation is to ensure that the citizens of California are well informed of their exposure to harmful chemicals in products purchased and as a result, businesses are legally obliged to notify consumers to the presence of significant amounts of any listed chemical by labelling products with hazard warnings.

Since its first publication, the list of regulated substances has increased significantly on an annual basis and now contains around 900 restricted chemicals, with hexavalent chromium (Chrome VI) added in 2008.

Whilst Chrome VI is not directly used by tanneries in the chrome tanning leather making process, there is a risk of the formation of Chrome VI through the oxidation of Chromium III. As a result, leather goods have come under target in California, with Prop 65 enforcers testing unlabelled products for the presence of Chrome VI and pursuing litigation against the relevant manufacturers and retailers in court.

In existing cases, the focus is largely on footwear and gloves however, the current litigation applies to any consumer good within the state that contains leather and is likely to shift across to other leather products such as upholstery and bags.

Currently, plaintiffs are only required to highlight the presence of the hazardous chemical within a consumer product. Manufacturers, brands, and retailers are liable for ensuring compliance of their consumer goods to product safety standards and are responsible for providing evidence that the amount of chrome VI within the product is below the maximum allowed Prop 65 limit of 3 parts per million (ppm).

To date, businesses have had few options for resolving lawsuits and failure to comply has led to the requirement of product hazard warning labels and company fines. A more recent case, however, has seen a first for Prop 65 settlements and demands for any footwear distributed by the offending company to contain chrome-free leather. Some companies have made the decision to settle, although there is concern that if these types of lawsuits expand it could be a threat to chrome tanning on a global scale.

The propensity for Chrome VI formation is specific to the individual tanneries leather making process, and so it is necessary to understand the risk relevant to each supplier. Tools such as our Eurofins | BLC Digital Chrome VI Risk Profiler can support manufacturers, brands, and retailers on Chrome VI compliance and risk mitigation by assessing multiple factors that affect the formation of Chrome VI throughout the leather supply chain, including:


  • Chemical purchasing
  • The influence of fats on the conversion of Chrome III to Chrome VI
  • The effect of pH
  • Free chromium
  • Use of oxidative chemicals
  • Addition of propriety chemicals
  • Storage and transportation of leather


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For further support on Chrome VI related issues and more information on the Eurofins | BLC Digital Chrome VI Risk Profiler, please contact one of our experts at [email protected].

25 September 2023

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