Non-Metal vs Metal: What This RoHS Report Covers and What It Does Not

RoHS compliance series. This article is what the report’s non-metal vs metal scope covers — and what it does not. Start at the hub: What RoHS Actually Is: Directive 2011/65/EU Explained.

Ask a factory "is your luggage RoHS compliant?" and the braver ones will say yes, full stop. Ask the same factory "which materials were tested?" and you'll find out whether that yes means something.

RoHS applies to every homogeneous material in an EEE product. A report that tests only one material family is evidence for that family — not for the product.

Our Model 1338 report covers the non-metal material: the grey fabric. Every one of the ten substances came back below detection in that scope. Metal components, other non-metal materials and any electronics boards are separate scopes that a complete compliance folder must address, either in this report or in additional ones.

Why the Scope Is the Story

RoHS limits apply per homogeneous material — each plastic, each alloy, each coating, each fabric. A product contains many homogeneous materials, and each one needs its own verdict. A report that says "the product passed" without naming the tested materials is either summarizing several submissions or hiding that most of the product was never tested. The sample description page is where the truth lives.

What Our Report Covers

Report element	Value
Sample	Multi-function trolley box, Model 1338
Tested material	Grey fabric (non-metal)
Sample quantity	1
Scope label	Non-metal
Result	All ten substances N.D.

The report's own note is explicit: it covers the content of the selected materials of the submitted sample, and the results are only responsible for that sample. That is not a weakness — it is precision. The reader knows exactly what was measured.

What the Folder Still Needs

A Model 1338 compliance folder for the EU would typically cover, beyond this non-metal report:

Metal components — zippers, buckles, rivets, frames: a metal-scope RoHS test for lead, cadmium and hexavalent chromium in plating and alloys.
Other non-metal materials — shell, handles, wheels, cables: their own non-metal scope.
The electronics — PCB, solder, components: RoHS applies to the electrical parts with full force.
The other directives — EMC (covered in our E-series report for the same model), REACH and the rest of the CE set.

When a buyer asks "is the 1338 RoHS compliant?", we answer with the scope, not a slogan: here is the non-metal report with the grey fabric tested and all ten substances N.D., and here is what the folder needs for the metal and electronic parts. A factory that says "RoHS passed" without naming the materials is leaving the most important word out of the sentence.

How to Build a Complete RoHS Picture

List every material family in the product — non-metal, metal, electronics.
Map each family to its risk — plating for Cr VI, alloys for lead/cadmium, plastics and fabrics for flame retardants and phthalates.
Test each family or obtain supplier data for each.
Keep the folder by product — the same model in a different material configuration needs its own scope.
Repeat on change — a new supplier, material or component means the evidence needs revisiting.

Frequently Asked Questions

Does our RoHS report cover the whole 1338?

It covers the submitted non-metal material — the grey fabric. The metal components, other non-metal materials and the electronics are separate scopes within the complete RoHS folder.

Why is RoHS tested per material and not per product?

Because the limits apply to each homogeneous material. A product "average" could hide a hotspot in one part, which is exactly what per-material testing is designed to catch.

What is a homogeneous material in RoHS?

A material that cannot be mechanically disjointed into different materials — a shell plastic, a plating layer, a fabric. Each homogeneous material is assessed against the limits.

Does a metal part need a different RoHS test?

Yes — metals are screened for the applicable substances (lead, cadmium, mercury, hexavalent chromium) with metal-specific methods, and the sample preparation differs from non-metal materials.

Can I reuse this report for another material?

No — the report is tied to the submitted sample. Each material family needs its own evidence, and each product configuration its own folder.

How do I know a factory's report scope matches my product?

Read the sample description page and compare it with your bill of materials. If the report names materials that match your product's components, the scope is aligned; if it describes a generic sample, ask for the material list.

About the Author

Written by the CLK Manufacturing Team — 16+ years of custom luggage OEM/ODM experience from our factory in Ji'an, Jiangxi, China. Updated: 2026-08-15.