The direct answer
RoHS restricts ten substances at defined limits: lead, mercury and hexavalent chromium at 1000 mg/kg, cadmium at 100 mg/kg, PBBs and PBDEs at 1000 mg/kg summed, and four phthalates (DEHP, BBP, DBP, DIBP) at 1000 mg/kg each. In luggage with electronics, the risks concentrate in predictable places - metal plating and alloys for the metals, flame-retardant materials for PBB/PBDE, and soft plastics and coatings for the phthalates. Our Model 1338 report found all ten substances below detection in the tested non-metal material.
The substance table
|
Substance |
Limit (mg/kg) |
Where it typically hides |
|
Lead (Pb) |
1000 |
Solders, metal alloys, pigments, PVC stabilizers |
|
Mercury (Hg) |
1000 |
Switches, lamps, some sensors |
|
Cadmium (Cd) |
100 |
Pigments, plating, battery components |
|
Hexavalent chromium (Cr VI) |
1000 |
Metal plating and coatings |
|
PBBs |
1000 (sum) |
Flame-retardant additives in plastics |
|
PBDEs |
1000 (sum) |
Flame-retardant additives in plastics and foams |
|
DEHP |
1000 |
Soft PVC, coated fabrics, flexible parts |
|
BBP |
1000 |
Soft plastics, vinyl |
|
DBP |
1000 |
Soft plastics, coatings |
|
DIBP |
1000 |
Soft plastics, coatings |
The cadmium limit deserves a second look: at 100 mg/kg it is ten times tighter than the others, and it is the limit most likely to catch a cheap bright pigment or plating process.
The phthalate update that changed the scope
Before (EU) 2015/863, RoHS covered six substances - the four metals plus the two flame-retardant families. The 2015 amendment added DEHP, BBP, DBP and DIBP, and the new limits became mandatory for most EEE in July 2019. The practical effect: compliance teams that once thought about metals now also think about plastics, coatings and inks - exactly the materials where phthalates live.
Factory data: The phthalates are the reason a RoHS report must name its test scope. A "RoHS report" from before 2019 may only cover six substances; the ten-substance scope is the current standard. Our report tests all ten and states each limit - so a buyer can see at a glance that the scope is the modern one.
Where these substances show up in a charging suitcase
- Metal hardware and plating - zippers, buckles, rivets: lead and cadmium in alloys, hexavalent chromium in plating.
- Printed circuit and solders - lead in solder (now largely replaced, but worth confirming).
- Soft plastic parts - handles, grommets, cable jackets: the four phthalates.
- Foam and coated fabrics - flame retardants: PBB and PBDE families.
- Pigments and inks - cadmium and lead compounds in bright colors.
The tested non-metal material in our report - the grey fabric - is exactly the kind of material where flame retardants and phthalates would appear, which is why it was screened rather than assumed clean.
Reading the results
The report lists each substance group with its limit, method and result:
- Metals: N.D. at MDL 2 mg/kg - far below the 1000 and 100 mg/kg limits.
- PBB/PBDE: every congener from mono- to deca-bromo N.D. at MDL 5 mg/kg.
- Phthalates: N.D. at MDL 50 mg/kg - twenty times below the 1000 mg/kg limit.
FAQ
What are the ten RoHS substances?
Lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs, DEHP, BBP, DBP and DIBP - the four phthalates added by (EU) 2015/863.
What is the RoHS limit for cadmium?
100 mg/kg (0.01%) - ten times tighter than the 1000 mg/kg limits for the other substances.
Which RoHS substances are most likely in luggage?
Lead and cadmium in metal hardware and pigments, hexavalent chromium in plating, flame retardants in foams and coated fabrics, and phthalates in soft plastics and coatings.
Why did RoHS add phthalates?
Directive (EU) 2015/863 added DEHP, BBP, DBP and DIBP to Annex II, effective for most EEE from July 2019, because of their reproductive toxicity and use as plasticizers in electronics materials.
Is a six-substance RoHS report still valid?
It covers only the original scope. The current ten-substance scope is what buyers and authorities expect; a six-substance report from before 2019 does not address the phthalates.
What does N.D. mean in our RoHS report?
Not detected - the substance is below the method detection limit stated on the report (2 mg/kg for metals, 5 mg/kg for PBB/PBDE congeners, 50 mg/kg for phthalates).
About this report
The substance data in this article comes from report No. S250827030001-1 for our Model 1338 - all ten RoHS substances below detection in the tested non-metal material, with limits and methods on every line. We share the substance pages with buyers and can review your bill of materials for RoHS risk before you spend on testing. Send your component list to clkbusiness@clkluggage.com or WhatsApp +86-18879628221.