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Regulatory News

Chromium in Leather Shoes Judgement Issued Under California Proposition 65

Jul. 15 2022

The California Environmental Protection Agency’s Office of Environmental Health Hazard Assessment (OEHHA) includes hexavalent chromium (CrVI) in their Proposition 65 List. It is listed as a chemical known to cause cancer and reproductive toxicity.  

Background 
There have been many 60 Day Notices issued to companies over the last few years for allegedly containing hexavalent chromium (CrVI) in leather products, including, but not limited to footwear. 

Update
The first known settlement for leather footwear which contains chromium has been finalized.  Within this judgement, the California Center of Environmental Health contends that leather used to make footwear that is tanned with chromium compounds can under certain circumstances expose consumers to hexavalent chromium, which is a Proposition 65 listed chemical.  The settlement requires reformulation and states that all leather used in footwear must be chrome-free leather. 

Definition of Chrome-Free Leather per the judgement: 

Leather that:
• was not at any point in the production process treated or tanned with chromium based tannins, including, but not limited to chromium sulfate;
• was not otherwise treated, dyed or exposed to chemicals that contain chromium as an intended ingredient; and 
• was not produced in tanneries that have material residual chromium contamination; and 
• has extractable chromium of less than 2 parts per million (ppm) by weight when tested to ISO 17072-1.
Labeling is not included as an option in the judgement. 

How Does this Impact You? Contact Us to Discuss
By monitoring Proposition 65 actions and settlements, Bureau Veritas help retailers and manufacturers take a proactive and comprehensive approach to compliance. We assist our clients in determining if listed Prop 65 chemicals are present in their products; identifying exposure routes and assessing the risk levels in items. We then help our clients to build in the appropriate requirements into their testing and quality assurance program an ongoing basis.  

If you have any comments and/or questions, please contact your customer service representative or email: info@us.bureauveritas.com
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