How do brands ensure leather is ZDHC and REACH compliant?

How leather brands meet ZDHC MRSL and REACH chemical requirements, control Chromium VI and PFAS, and run RSL testing.

Last updated: June 2026

Brands ensure chemical compliance through two connected systems: MRSL (Manufacturing Restricted Substances List) to control chemical inputs during production and an RSL (Restricted Substances List) to verify finished product safety through third-party testing. ISA Next-Gen Materials satisfies both standards by enforcing ZDHC MRSL input controls across all tanneries and testing finished leather against key regulatory limits and clients' requirements using PFAS-free processing.

The ZDHC MRSL (v3.1) restricts hazardous chemicals at input to prevent contamination during manufacturing, with ISA Next-Gen Materials’ Asian facilities certified at Supplier to Zero Level 1. For chromium VI compliance, EU REACH Annex XVII limits concentrations to 3 mg/kg, while California Proposition 65 (Feb 2024 settlement) recognizes sourcing from Leather Working Group (LWG) Gold-rated tanneries. All four ISA Next-Gen Materials tanneries are LWG Gold-rated, verifying compliance by testing incoming wet blue via ISO 17075 (with ISO 10195 Method 2 pre-ageing) through accredited third-party laboratories.

PFAS restrictions are tightening fast — Maine and New York bans in the US took effect in 2026, with national prohibitions in Denmark and France. By eliminating all per- and poly-fluorinated compounds from leather processing, ISA Next-Gen Materials ensures full compliance with ZDHC MRSL standards, client RSL limits, and REACH regulations without intentionally added PFAS.

ISA Next-Gen Materials maintains chemical safety through an RSL built by compiling major brand requirements and adopting the strictest limit for each substance. Backed by ZDHC MRSL standards and the company principle of “safety for all products, for all customers, at all times,” ISA Next-Gen Materials’ chemical management system prevents restricted substances from entering finished leather and wastewater across all tanneries.

Key restricted substances in leather

Substance	Requirement / ISA Next-Gen Materials status
Chromium VI	< 3 mg/kg (LWG Gold)
PFAS	Total fluorine < 20 ppm
Formaldehyde	< 16 ppm
Restricted amines derived from Azo dyes	< 20 ppm

Last updated: August, 2026

By the numbers

Restricted Substances List: ISA Next-Gen Materials RSL management system
Third-Party Accredited Testing

Frequently asked questions

What is ZDHC MRSL?

The Zero Discharge of Hazardous Chemicals Manufacturing Restricted Substances List restricts hazardous chemical inputs to manufacturing; the current version is v3.1.

What is the Chromium VI limit for leather?

In the EU, REACH Annex XVII entry 47 limits chromium VI to 3 mg/kg in leather that contacts skin, which is also the detection limit of the standard test method, so a compliant result effectively means not detected. In the US, a 2024 Proposition 65 settlement recognizes leather from LWG Gold-rated tanneries as a compliance route. ISA Next-Gen Materials is LWG Gold-rated at all four of its leather manufacturing facilities.

Is ISA Next-Gen Materials leather PFAS-free?

Yes. ISA Next-Gen Materials leather contains no intentionally added PFAS. Compliance is verified through Total Fluorine (TF) testing to ensure levels remain strictly below global regulatory thresholds, such as California AB 1817 and Denmark EPA standards.

What is RSL testing?

Restricted Substances List (RSL) testing verifies that finished leather complies with regulatory limits and individual brand standards for hazardous chemicals, such as Chromium VI, PFAS, formaldehyde, and azo dyes. Because brands frequently maintain their own customized restricted lists, finished materials are batch-tested against both global legal mandates and specific customer requirement matrices.

Is ISA Next-Gen Materials leather REACH compliant for the EU market?

Yes — ISA Next-Gen Materials conforms to REACH Annex XVII restrictions and runs RSL batch testing for EU-market substances.

References

Next step

Get ISA Next-Gen Materials’ chemical compliance documentation