California Proposition 65 Settlement on Chromium VI of Leather Gloves

Chromium VI (Cr (VI)) has been listed on the California Proposition 65 (Prop 65) list for carcinogenic and reproductive toxicity since 1987. As part of Prop 65, businesses selling products in California must provide “clear and reasonable warning” before knowingly exposing people to any chemical on the list, unless the expected level of exposure would pose no significant cancer risk. Chromium is the most versatile tanning agent. However, under certain production and storage conditions, chromium III can be converted to chromium VI, which can easily trigger allergic reactions and cause skin ulcers, tumors or even skin cancer.

Since the beginning of last year, there have been many 60-day notices issued in relation to the presence of Cr (VI) in leather goods. Among them, two 60-day notices led to a settlement and a consent judgement issued to address consumer exposures to Cr (VI) in leather gloves. These enforcements require a clear and reasonable warning label to be displayed on the covered leather gloves that contain Cr (VI).

The warning label shall consist of either the Warning or Alternative Warning as follows per settlements:

Or an alternative short-form warning:

The 60-day Notice of Violation is a legal document that often leads to settlement negotiations. Once the relevant settlement agreement or judgment is reached, it is required that the product manufacturer either reformulate the product or provide a warning label.

Reference

[1] Proposition 65 Law and Regulations

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