A small but potentially temporary victory for the EU leather sector.
The European SEAC committee has published its draft opinion on the proposed Skin Sensitisers Regulation, noting the responses to the RAC consultation. The good news is that they have proposed maintaining a 3 mg/kg limit for CrVI in leather, on the basis that it is not currently possible to reliably measure below that limit (page 27-29).
However, they have also said, "SEAC therefore recommends the 3 mg/kg concentration limit to have a temporary nature and advises that the consultation of the SEAC draft opinion is used to gather information on the time window and practical needs to achieve a reliable 1 mg/kg detection limit for Cr (VI) in leather."
As such, it is very important that our sector responds to the draft proposal with technical, but more importantly, economic reasons why a lower limit is not possible, i.e. those options that are available are not financially-viable options for routine monitoring of leather. We should also draw attention to and provide examples of, the contradictory results that are sometimes seen with the current method and the financial implications this has for the sector.
It is important to note that UK leather manufacturers, exporting to the EU, will still have to comply with EU standards after Brexit. As such, it is important that we challenge the proposed limit.
The link to the SEAC draft and for responding can be found here.