REACH for Luggage: SVHC, the 251+4 Scope and How to Read the Report

Q: Is a REACH report valid forever?

No - it is valid for the sample and the Candidate List version tested. As the list grows, the evidence ages; that is why the list date on the report matters.

REACH compliance series. This article is how to read the SVHC report and understand the 251+4 scope. Start at the hub: What REACH Actually Is: The EU Regulation Explained.

"Is Your Luggage REACH Compliant?" — The Question Every EU Buyer Asks, and How to Read the Answer

The question comes up in nearly every first call with an EU buyer. Usually while we're standing at the sample table, cases open, zippers pulled. And it's a good question — but the honest answer is rarely a yes or no.

REACH — Regulation (EC) No 1907/2006 — controls chemicals in products sold in the EU. For luggage, the practical question is always the same: does any component contain a Substance of Very High Concern (SVHC) above 0.1%?

Our Model 8404 report (No. S260120016001-1, January 2026) screened the full ECHA Candidate List of 251 SVHCs published on or before November 5, 2025, plus 4 substances under assessment. Every result came back below 0.1% — the non-metal sample at not-detected for all 251, the metal sample at not-detected for the 73 SVHCs that apply to metal. The matching Declaration of Conformity (No. S260120016001-2) documents the conclusion.

What REACH Means for a Suitcase

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It's the EU's framework for managing chemical risk, and it reaches far beyond raw chemicals — it covers the substances inside finished articles.

A suitcase is a bundle of materials: shells, fabrics, zippers, buckles, wheels, handles, coatings, and adhesives. Each one can carry SVHCs. That's why REACH compliance for luggage is a materials-and-components question, not a single-material question.

SVHC and the Candidate List

SVHC stands for Substances of Very High Concern — chemicals with serious hazard properties such as carcinogenicity, mutagenicity, reproductive toxicity, persistence, or bioaccumulation. ECHA maintains a Candidate List of these substances, and the list grows over time.

The scope in our report is date-stamped: 251 substances on the Candidate List published on or before November 5, 2025. That date is the whole game — REACH reports are only as good as the version of the list they test against.

The "251+4" Scope

Scope	What it is	Result
251 SVHC	Full Candidate List as of Nov 5, 2025	All below 0.1%; non-metal N.D. for all 251
4 assessing SVHC	Substances submitted by EU member states to ECHA, still under assessment	Screened per client requirement; pass

The +4 are the substances in the pipeline toward the Candidate List — not yet listed, but already on the radar. Testing them early is a head start, because when a substance is added to the Candidate List, the report that already screened it doesn't have to start from zero.

The Test Summary, Read in One Minute

Report element	What it tells you
Report No. S260120016001-1	Unique ID; the declaration cites the same number
Sample: Luggage Storage Series, Model 8404	The exact tested product — same model as our CPC program
Scope: 251 SVHC + 4 assessing	The list version (Nov 5, 2025) and the extra screening
Threshold: 0.1% (w/w)	The REACH article threshold
Methods: ICP-OES, UV-Vis, HPLC-PDA, GC-MS, LC-MS/MS	Instrumental coverage for metals and organics
Result	Non-metal: all 251 N.D.; metal: all 73 applicable N.D.
Declaration No. S260120016001-2	The conformity conclusion based on the report

Report vs. Declaration: Know Which One You're Holding

The test report is the laboratory evidence — every substance, every method, every result line. The Declaration of Conformity is the summary document that states the conclusion.

The declaration itself carries an important note: it is based on a single evaluation of one sample, it does not imply an assessment of the whole production, and it does not permit use of the test lab's logo. That note is not a defect — it's the honest limit of any REACH certificate, and it's why batch-level material control still matters (Article F7).

What This Report Does NOT Cover

Honest boundaries, because you should know them before you rely on a document:

REACH is EU. Other markets have their own chemical rules — US CPSIA lead and phthalates, California Prop 65, China GB standards — covered by other documents.
SVHC screening is not a ban. REACH manages risk through the Candidate List, authorisation, and restriction. A screening report demonstrates compliance with the communication threshold, not that a substance is banned everywhere.
The list changes. The Nov 5, 2025 version is correct as of the test date. The Candidate List will grow, and a report from 2024 is not evidence for 2026.
One sample, one configuration. Change materials, suppliers, or components, and the evidence needs revisiting.

Frequently Asked Questions

What does REACH stand for?

Registration, Evaluation, Authorisation and Restriction of Chemicals — Regulation (EC) No 1907/2006, the EU's framework for managing chemical risk in products placed on the EU market.

What is an SVHC?

A Substance of Very High Concern — a chemical with serious hazard properties (carcinogenic, mutagenic, toxic to reproduction, persistent, bioaccumulative, or of equivalent concern) listed by ECHA.

What is the 0.1% threshold in REACH?

0.1% weight by weight per article — the concentration above which suppliers of articles have communication and notification obligations under Articles 33 and 7(2) of REACH.

Why does our report say 73 SVHCs for the metal sample?

Not all 251 substances can occur in a metal matrix. The lab applies the full list to non-metal materials and the applicable subset (73) to metal components — an efficient and technically correct scope.

Is a REACH report valid forever?

No — it's valid for the sample and the Candidate List version tested. As the list grows, the evidence ages; that's why the list date on the report matters.

Do I need REACH for the US market?

No — REACH applies to the EU. US programs need their own chemical compliance picture: CPSIA for children's products, Prop 65 for California, and so on.

About This Report

The document behind this article is report No. S260120016001-1 with declaration No. S260120016001-2, covering our Model 8404 luggage storage series — the same model documented in our CPC program — screened against 251 SVHCs (Candidate List, Nov 5, 2025) plus 4 assessing substances, all below 0.1%. We share the full report and declaration with buyers building EU programs. If you need to know which chemical scope applies to your product and market, send your component list to clkbusiness@clkluggage.com or WhatsApp +86-18879628221.

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.