Chinese shoe manufacturers have not yet won the EU anti-dumping tax lawsuit over leather shoes, and now they may face new technical trade barriers as Germany prepares to implement stricter regulations. Recently, the German Federal Ministry of Food, Agriculture, and Consumer Protection issued TBT No. 11, an amendment to the Commodity Act that restricts the use of chrome tanning in leather production and limits the sale of leather products in contact with human skin. This includes items such as bags, backpacks, textiles, straps, shoes, and toys. The regulation prohibits the presence of hexavalent chromium in final products and is expected to come into effect this year. This new rule could significantly impact Chinese shoe exports. In response, some Chinese companies have expressed confidence in overcoming these challenges by leveraging their experience in dealing with technical barriers and by improving communication and coordination within the industry. Chen Zhanguang, deputy secretary-general of the China Leather Industry Association, told *First Financial Daily* that this is a classic example of a technical barrier to trade. While it may increase production costs for Chinese shoe manufacturers, it also pushes them to invest more in research and development. He emphasized the importance of understanding the difference between trivalent and hexavalent chromium. Trivalent chromium, widely used in leather processing, is stable, non-toxic, and even considered an essential trace element. Hexavalent chromium, on the other hand, is toxic. In practice, small amounts of trivalent chromium can sometimes convert to hexavalent chromium under certain conditions during transportation or storage, but the quantities are usually too low to cause harm. Chen pointed out that the issue of hexavalent chromium in leather remains controversial, with no clear consensus on detection limits or health risks. Errors in testing methods can also lead to false positives. The chrome tanning method has been used for over 100 years and has been proven safe. Currently, 85% of global leather is processed using trivalent chromium, which offers excellent durability, softness, and resistance to moisture and heat. This tanning agent is widely used across the world, including in major leather-producing countries like Italy. The new German regulation will affect all EU members, not just Germany. Chen also stressed the need to prevent trivalent chromium from oxidizing into hexavalent chromium. Although many global leather companies, including those in China, Italy, and Spain, are working on solutions, no definitive answer has been found yet. He suggested that Germany should consider practical implementation when revising the regulation. Many shoe companies interviewed said they haven’t received specific test requirements from German customers yet. They believe that as long as the new standard is applied reasonably, Chinese shoes can meet the requirements. Guo Weiwen, secretary general of the Guangdong Footwear Federation, noted that in recent years, safety standards for footwear have become increasingly strict worldwide, especially for children's shoes. Companies are now focusing more on chemical component testing, which increases costs. However, through continuous R&D improvements and scale expansion, these costs can be managed effectively.

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