The control of restricted substances has become a major constituent of quality control for many consumer products. This stems in part from tighter regulations brought in to protect both human health and the environment.


Traditional assessment for restricted substances has tended to focus on product testing, but this can be inefficient and result in costly product recalls. By focusing on input chemicals and products, manufacturers can mitigate against many of the risks associated with restricted substances.

Manufacturers of leather and leather products find there are many advantages to shifting their restricted substance focus from testing end products to assessing input chemicals. The concept is very simple – if no restricted substance is inputted into the manufacturing system, then the risk of the product or waste stream containing a restricted substance is greatly diminished. It cannot completely negate the occurrence of some substances, such as chromium VI and formaldehyde, but it does significantly reduce the possibilities of restricted substance non-conformance.

Brands and retailers of leather and leather products are increasingly emphasizing the need for assessing input chemicals through the adoption of Manufacturing Restricted Substance Lists (MRSL); Restricted Substance Lists (RSL) are already standard practice in the tanning industry. MRSLs enable the processing chemicals and auxiliaries, such as dyes, retannages and fatliquors, to be profiled to ensure conformance.

The problem for many brands and retailers is that tanneries often use local small suppliers, so, whilst third party assessment systems do exist, they may not be applicable to the tannery’s situation. A better solution is to have a mechanism within each tannery that can assess input chemicals and meet the responsibilities to their buyers. However, in many cases, the necessary expertise will not exist in the factory, leading to a knowledge gap that requires specialist training.

Overcoming the Knowledge Gap

Pressure from brands and NGOs to introduce the control of hazard substances at the input stage has already resulted in its implementation in the textile and apparel sector. Observations of the textile industry showed that, whilst there was initial support for the adoption of hazardous substance control strategies, a knowledge gap usually existed in how to practically implement this at the factory level. It became clear that classifying risk was the most challenging aspect, since most factories received insufficient information about each substance.

To overcome this knowledge gap, SGS has developed a comprehensive but compact training course to guide textile mills and factories through hazardous substance control (HSC). [1] It was noted that whilst the concepts could be taught within a manageable timeframe with a combination of presentation materials, case studies and interactive sessions, the most critical element was to provide practical tools to support the individual once they returned to the factory setting. These comprehensive toolkits covered each stage of the manufacturing process and enabled individual factories to catalogue their chemical inventory and identify the means by which each chemical could be assessed for hazard level. A combination of the specially adapted training course and toolkit system provided factories with the means to introduce their own chemical control systems.

Leather manufacturing differs greatly from textile manufacturing but, from the perspective of HSC, they are very similar. It should, therefore, be possible to use the experience gained from overcoming the knowledge gap in the textile industry, to benefit the leather industry.

Chemical Flow Management in the Tannery Environment

One approach that found approval from the apparel and footwear industry is the concept of chemical flow management (CFM). This system uses the concept that chemicals ‘flow’ or cascade through a factory from input materials (e.g. processing chemicals, auxiliaries and raw / part processed leather), through processing, and into either the final product or a waste stream (aqueous, solid or air emission). Understanding where all the chemical components are at each stage increases traceability and allows continuous improvement of the risk profile of the chemicals employed.

This system must be introduced in a systematic and informed manner with full management support, who must consider how this can be effectively integrated into standard working practices. In addition to training, it is critical the right guidance material is provided, to ensure that the appropriate steps are taken. The use of appropriate toolkits are made available to the participants to conduct risk assessment at the factories.

Application of knowledge gained from appropriate training in conjunction with such toolkits allows the practical introduction of CFM into daily tannery operation systems.

What are the benefits?

Tanneries benefit in several ways from introducing effective control and monitoring systems for chemicals at all stages of the production process. The principle benefit is a reduction in risk and increased chemical use efficiency. Optimizing the chemical hazardous risk profile at the purchasing stage can significantly reduce the use of a whole range of restricted substances and mitigate against environmental issues. This should be the primary strategy for all tanneries. By focusing on input rather than output chemicals, the tannery will achieve greater efficiencies during conformance testing.

Once the input chemicals have been optimized, CFM will also bring about greater efficiencies in chemical usage. By ensuring more of the chemical goes into the leather and less is discharged into the waste stream, the tannery will achieve reductions in chemical costs and in effluent/waste treatment and disposal costs.

Finally, the introduction of effective CFM will increase supply chain confidence in the tannery. Being able to prove both chemical compliance and environmental credentials, the tannery will find its products are sought by brands and consumers who demand high levels of sustainability.

SGS Solution

CFM is the practical solution to controlling hazardous substances in the leather industry. It is a proven system, which can be practically implemented in manufacturing situations, and will bring about tangible results in terms of benefits for both the organization and the environment.

Whilst the concepts of CFM are relatively simple, it is imperative that the right knowledge is imparted and that the teams responsible for delivering the system are given the right means and support. SGS has developed a Hazardous Substances Control (HSC) workshop to impart the right knowledge to leather factory professionals and provides a range of services to help manufacturers.

With global brands and retailers focusing heavily on chemical compliance, such methodologies are becoming increasingly more important for maintaining market share in the competitive leather goods sector. Training and support is a key solution for the supply chain to adopt to close the gap between the requirements and expectations of the brand, and the capability of the tannery.

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To learn more, contact:

Skarlett Leung
SGS Global Softlines
t: +852 22048350