Cr(VI) in Pet Leather: The Test Your Retailer Wants

Entry 47 is written around human skin contact, not animal contact. That is why the article a market surveillance authority reaches for first is not the collar on the dog — it is the hand loop on the lead.

A guide by TL San Martín, a tannery of origin in Elda (Alicante, Spain) since 1995, LWG Gold certified under the Leather Manufacturer standard.

This is written for brands and manufacturers buying leather by the hide. If you are still fixing thickness and tannage, start with what to spec before you order. The limit itself has been in force since 1 May 2015, and it is not new — what is new is how often retailers now run their own check instead of taking your word for it.

Which pet articles are actually in scope?

Entry 47 is written around human skin contact, not animal contact. That trips people up, because the intuition is that a collar sits on the dog and is therefore out of reach of the rule.

The workable rule is that if you are cutting the whole line from one hide, the whole line inherits the compliance status of that hide. There is no version of this where you test the lead and skip the collar — you would be paying for a report and still carrying the risk.

Why does chromium VI appear in leather nobody tanned with it?

This is the part that catches brands out, and it is the reason the control sits with the tannery rather than with you.

Chromium VI is not a tanning agent and nobody adds it. Chrome tanning uses chromium III, which is stable and not restricted. Cr(VI) forms afterwards, by oxidation of Cr(III), when conditions allow it: drift in pH, high temperature during drying or storage, UV exposure, residual oxidising agents, certain fatliquors ageing badly. A hide can leave a tannery under the limit and cross it three months later in a hot warehouse.

Two consequences that belong in your sourcing decision:

• A single passing report on a sample hide proves very little if the process behind it is not controlled. What you want is a process that cannot produce the failure, then a report that confirms it. That is the difference between buying from the tannery and buying from a distributor — a distributor can forward you a certificate but cannot tell you what happened in the drum.
• Chrome-free removes the mechanism, not just the number. If there is no chromium in the leather, there is no Cr(VI) to form under any storage condition. For pet articles with heavy skin contact this is the cleanest answer available, and it is why the chrome vs chrome-free comparison is a commercial decision in this category rather than a marketing one.

Which test do you ask for — ISO 17075-1 or 17075-2?

Both exist, both were published in February 2017 to replace the older single ISO 17075:2007, and both quantify down to 3 mg/kg. They are not interchangeable in every situation.

The line to put in your purchase order: if a sample is tested by both methods, the result from Part 2 is the one that counts. On a pale leather Part 1 is perfectly adequate and cheaper. On a black, deep navy or saturated brown collar leather — which is most of this category — ask for Part 2, or expect the argument to end there anyway if a retailer challenges the number.

Also specify what the report must state: the method, the accredited laboratory, the limit of quantification, and the batch or lot it belongs to. A report with no lot reference is a marketing document.

What is ECHA about to change — and what is it not changing?

The frame is tightening, but it is worth being precise about where.

ECHA submitted a restriction proposal covering hexavalent chromium substances on 11 April 2025, announced it on 29 April 2025, and opened a six-month public consultation on 18 June 2025. The mechanism is a move of Cr(VI) compounds from the Annex XIV authorisation route to the Annex XVII restriction route — from case-by-case permission toward broad prohibition with limited derogations. It now passes through ECHA's Committee for Risk Assessment and Committee for Socio-Economic Analysis before the Commission and member states decide.

Two clarifications that keep this useful rather than alarming. First, that proposal targets Cr(VI) substances in industrial use — chromates, plating, surface treatment — and does not change the 3 mg/kg article limit in entry 47, which already applies to your collar today. Second, adoption is not expected before 2027.

So nothing in your 2026 spec changes because of it. What changes is the cost of being wrong later: a brand that builds its line on a documented chrome-free or verified-process supply does not have a reformulation project waiting for it.

What should a pet brand put in the purchase order?

The spec that keeps this simple, alongside the physical requirements:

• Article and substance: firm bovine strap, 3.5–4.0 mm (9/10 oz) for collars and leads, 2.5–3.5 mm for harness parts, cut from the butt.
• Tannage: vegetable or chrome-free, stated explicitly.
• Compliance: Cr(VI) < 3 mg/kg per EN ISO 17075-2:2017, accredited laboratory, report referenced to the delivered lot.
• Traceability: the batch behind the report. This is where an origin tannery and an intermediary stop looking alike — and why it is worth knowing how to read an LWG certificate before you accept one as proof.
• Continuity: the same article, same tannage and same test regime on the repeat order. Sample-to-bulk consistency is the failure mode that costs a season.

TL San Martín tans in Elda, Spain, since 1995 and holds **LWG Gold under the Leather Manufacturer standard** — the only standard under which a Gold medal exists at all; a Trader tops out at "Approved". There is no minimum on the leather itself: a single hide is a valid order, which is what makes it possible to run a full line — collar, lead, harness, treat pouch — from one batch and get colour matching across all of it. Thickness selection follows the same logic as belt leather; German-language buyers will find the equivalent guidance in Leder für Hundehalsbänder.

You can request samples against your own spec, or, if you are still comparing suppliers and want to see who else is testing to Part 2, ask openly on the B2B board — a question posted under Materials usually gets a faster answer than four quote cycles.

Sourcing a pet line — or looking for someone to cut it?

Post the brief on the open B2B board at tlsanmartin.com/#community — free, no intermediary. Material requests go under Materials; if you need someone to manufacture the line rather than supply the hide, post it under Partners & factories, which is also the right place for a project too small to justify its own production run.

TL San Martín tans and finishes leather in Elda, Alicante, since 1995: LWG Gold under the Leather Manufacturer standard — the only standard under which a Gold medal exists at all; a Trader tops out at “Approved”. Request samples before you specify anything.