REACH is the European Union's regulation on the registration, evaluation, authorisation and restriction of chemicals. For a brand selling leather goods in the EU, it is the framework determining which substances may be present in your product and what you must be able to demonstrate.
It is often treated as the factory's problem. It is not — the obligation generally sits with the party placing the goods on the EU market, which is usually the brand.
This is general guidance, not legal advice. REACH is amended regularly. Verify current requirements with a compliance specialist or the relevant authority for your specific products and markets.
Who carries the obligation
Under REACH, duties fall principally on manufacturers, importers and downstream users established in the EU.
If you are an EU brand importing finished leather goods from outside the EU, you are the importer, and the compliance obligation is yours. A supplier declaration is evidence supporting your position. It does not transfer the legal duty.
This distinction matters when enforcement authorities come asking. They will ask you, not your factory.
What REACH restricts in leather goods
Chromium VI is the substance most associated with leather. It is not intentionally added, but can form from chromium III used in chrome tanning under certain conditions — heat, incorrect pH, ageing, poor process control.
REACH restricts chromium VI in leather articles that come into contact with skin, with a strict limit expressed in milligrams per kilogram. This applies to leather goods that touch the skin in normal use, which covers a great many products.
Practical implications: control lies with the tannery and with storage conditions, chromium VI can form after manufacture if goods are stored badly, and testing at a single point in time does not guarantee compliance throughout shelf life. Vegetable-tanned leather avoids the issue at source, which is one reason some brands specify it.
Azo dyes that can release certain aromatic amines are restricted in textiles and leather articles in prolonged skin contact.
Other commonly relevant substances include certain phthalates in plasticised components, nickel release from metal parts in prolonged skin contact, cadmium and lead in metal components and coatings, formaldehyde, and PFAS in water-repellent treatments — an area under increasing regulatory pressure.
SVHCs and the notification duty
Substances of Very High Concern are listed on the REACH Candidate List, which is updated periodically.
If an article contains an SVHC above a threshold concentration, obligations arise: information must be passed down the supply chain and, on request, to consumers; and notification to the European Chemicals Agency may be required above certain volume thresholds.
Because the Candidate List changes, compliance is not a one-time exercise. A product compliant when launched can acquire an obligation when the list is next updated.
What to request from your manufacturer
Ask for specific documents rather than general assurances.
- Test reports from an accredited laboratory, for the specific materials used in your product, with dates
- Supplier declarations from the tannery covering chromium VI and azo dyes
- Declarations for components — hardware, zips, linings, adhesives, coatings — since these are frequently overlooked and are a common source of nickel, cadmium and phthalate issues
- Material composition for each component
Two frequent gaps: brands test the leather and forget the hardware, and brands accept a generic statement of compliance rather than a test report tied to their actual materials.
Testing
When to test. During development, on the pre-production sample, and periodically during production — particularly when a material, colour or supplier changes.
What to test. Leather for chromium VI and azo dyes; metal components for nickel release, lead and cadmium; plasticised components for phthalates; coatings and treatments as relevant.
Who tests. Accredited third-party laboratories. In-house results carry little weight with enforcement authorities.
Cost. Testing is a real budget line, though modest relative to the cost of a non-compliant shipment being refused or recalled.
A practical note: a new colour in an existing style is a new material. It has been through a different dye process and needs its own evidence.
Beyond the EU
The United Kingdom operates its own UK REACH regime post-Brexit, broadly parallel but separately administered. Other markets have their own chemical regulations, and several US states impose additional requirements. Selling into multiple markets means meeting the strictest applicable standard, not the average.
Practical steps
- Identify which of your products contact skin in normal use
- List every material and component, not just the leather
- Obtain test reports and declarations for each
- Retest when any material, colour or supplier changes
- Monitor Candidate List updates
- Keep records for the required retention period
- Write compliance obligations into supplier contracts explicitly
The commercial reality
Retailers increasingly require compliance documentation before accepting goods, and many operate restricted substance lists stricter than the regulation. Having documentation in order is frequently a condition of getting shelf space, quite apart from the legal position.
The manufacturers worth working with will have this documentation available and will be clear about what belongs to them and what belongs to their leather suppliers. Vagueness on this point is a meaningful warning sign — one of the red flags worth taking seriously.
If you are preparing a product for the EU market and want to understand what documentation would accompany it, get in touch.