On October 31, 2012 the EU informed the World Trade Organisation of a draft regulation which would ban the use of certain Polycyclic Aromatic Hydrocarbons (PAH) in consumer goods. This regulation is likely to come in to force towards the end of 2013, and therefore would be mandatory at the end of 2015, two years after implementation.

Polycyclic Aromatic Hydrocarbons

PAHs are a group of over 100 different chemicals that are formed during the incomplete burning of coal, oil and gas, waste and other organic substances. PAHs are found naturally in the environment but they can also be man-made. In their purest form, PAHs are solid and range in appearance from colourless to white or pale yellow-green. These substances readily evaporate into the air from soil or surface water, breaking down through reaction with sunlight and other chemicals in the air. Furthermore, PAH’s can enter water through discharges from industrial and water treatment plants, however, most PAH’s do not dissolve easily in water and therefore they bind to solid particles and settle at the bottom of lakes or rivers.

PAHs consist of hydrogen and carbon arranged in the form of two or more fused benzene rings. There are thousands of PAH compounds, each differing in the number and position of aromatic rings, and in the position of substituents on the basic ring system. Environmental concern has focused on PAHs that range in molecular weight from 128.16 (naphthalene, 2-ring structure) to 300.36 (coronene, 7-ring structure). Unsubstituted lower molecular weight PAH compounds, containing 2 or 3 rings, exhibit significant acute toxicity and other adverse effects to some organisms, but are non carcinogenic; the higher molecular weight PAHs, containing 4 to 7 rings, are significantly less toxic, but many of the 4- to 7-ring compounds are demonstrably carcinogenic, mutagenic, or teratogenic to a wide variety of organisms, including fish and other aquatic life, amphibians, birds, and mammals. In general, PAHs show little tendency to bio-magnify in food chains, despite their high lipid solubility, probably because most PAHs are rapidly metabolised.


Carcinogenic polycyclic aromatic hydrocarbons are still frequently found in consumer products such as toys, tool handles, bicycle grips, shoes or sporting goods, despite the fact that the health hazards of these substances have been known for a long time1. Investigations by independent laboratories have revealed that a considerable number of products on the market display unacceptably high PAH contamination levels. PAHs, which are known for their carcinogenic, mutagenic and teratogenic properties, can be found in leather, rubber, plastics, lubricants, paints and other products. Currently, EU REACH Annex XVII has placed a restriction on the use of 8 PAHs in certain products and concentration limits have been applied. Furthermore, the US EPA have restricted the use of a total of 18 PAHs in consumer goods.

The proposed regulation follows a dossier submittal from Germany to the European Commission in June 2010 proposing a restriction on eight polycyclic aromatic hydrocarbons (PAH) in consumer products due to a growing concern that they may have carcinogenic properties.

The proposed regulation would amend entry 50 of Annex XVII of the REACH regulation (EC) 1907/2006, which already restricts 8 PAHs in tyres. The draft text of the regulation is as follows:

Articles shall not be placed on the market for supply to the general public, if any of their rubber or plastic components that come into direct and prolonged skin contact with the human skin or the oral cavity, under normal or reasonably foreseeable conditions of use, contain more than 1mg/kg (0,0001% by weight of this component) of any of the listed PAHs.

Such articles include:
• toys including activity toys such as swings and childcare articles
• sport equipment such as bicycles, golf clubs, racquets
• house-hold utensils, trolleys, walking frames
• tools for domestic use
• clothing, footwear, gloves and sportswear
• watch-straps, wrist-bands, masks, head-bands

Persistent, bioaccumulative and toxic chemicals may be introduced into various consumer products due to the complexities of both the supply chain and production processes. Reduction in risk is possible by using reputable chemical companies for the supply of leather chemicals. Such suppliers understand the restrictions relating to controlled chemicals and take a responsible approach to supplying chemicals that are both safe and sustainable when used appropriately.

BLC can offer chemical testing, supply chain support, guidance on EU and international legislation, including REACH Regulations as well as further information regarding PAHs.
For further information on BLC services contact info@blcleathertech.com, call +44 (0) 1604 679999 or visit www.blcleathertech.com.


1: Carcinogenic polycyclic aromatic hydrocarbons (PAHs) in consumer products to be regulated by the EU – risk assessment by BfR in the context of a restriction proposal under REACH