The direct answer
For the US, the critical rule is the TSA lock: any lockable case must open with a TSA-approved override or it will be cut open by screeners; for the EU, the bigger issue is batteries - power banks and USB luggage cannot go in checked baggage under current airline rules. Add REACH/RoHS compliance for the EU market and children's safety standards where applicable, and compliance stops being a surprise. The three areas to get right before production are locks, batteries and material compliance.
US: the TSA lock rule
TSA (Transportation Security Administration) screeners may need to open checked luggage for inspection. A non-TSA lock will be cut - permanently. A TSA-approved lock carries the red Travel Sentry diamond and opens with the screeners' master key or tool.
What importers must do:
- Specify TSA-approved locks for any US-bound lockable case.
- Verify the provider on the Travel Sentry list - the diamond and approval are verifiable.
- Test the override mechanism in QC (it is a moving part that can fail).
- Publish "TSA approved" only for cases that actually carry it.
EU: the battery rule
The rules that bite luggage most in the EU are about batteries, enforced by airlines and civil aviation rules:
|
Product feature |
Checked baggage |
Carry-on |
|
Power bank (loose) |
Prohibited |
Allowed with capacity limits (typically under 100 Wh) |
|
Luggage with built-in USB charging |
Battery must be removable or the bag is restricted |
Allowed with removable battery under 100 Wh |
|
Electric/riding luggage |
Severely restricted or prohibited |
Treat as a device with a battery; verify per airline |
What importers must do: design USB luggage with a removable battery, mark the capacity, and document the removal procedure. Electric luggage is a different compliance conversation per airline and route - do not launch it without per-market verification.
Material compliance: REACH and RoHS
The EU regulates chemicals in products through REACH, with RoHS covering electronics. Your factory's material and component suppliers should be able to provide screening documentation:
|
Regulation |
What it covers |
Practical action |
|
REACH |
Restricted substances in all materials |
Ask for REACH screening of shell, lining, dyes, hardware |
|
RoHS |
Hazardous substances in electronics |
Applies if the case has charging electronics |
|
Packaging directives |
Packaging materials and waste |
Confirm packaging compliance for EU sale |
Children's luggage: a separate standard
If your product is for children, EU and US markets apply safety standards (for example EN71 expectations in the EU and ASTM F963 in the US) covering small parts, sharp edges and chemical limits. Article B8 covers kids' luggage in depth; the import takeaway is that "kids' case" is a compliance category, not just a size.
Customs: get the classification right
The HS code determines duty, and luggage classification can differ by material and type:
- Know the material-based classification for your product (plastic hard-shell vs aluminum vs textile).
- Verify the duty treatment for your destination - trade agreements can reduce or remove duty.
- Keep country-of-origin documentation consistent with the factory's license and production location.
- Match the commercial invoice, packing list and bill of lading - mismatches cause customs delays.
Factory data: In our export paperwork, the two most common compliance mistakes we see from new brands are non-TSA locks on US-bound stock and USB luggage with a non-removable battery. Both are caught at customs or the gate - which is the most expensive place to discover them. Both are fixed in the spec, for free, before production.
The compliance checklist before you order
|
Item |
Confirm |
|
TSA locks |
Approved, tested, and only on US-bound lockable cases |
|
Batteries |
Removable, capacity marked, policy documented per market |
|
REACH/RoHS |
Screening documents available for EU-bound products |
|
Kids' standards |
Applied if product is for children |
|
HS code |
Material-correct classification verified with forwarder |
|
Packaging compliance |
EU packaging rules considered |
FAQ
Are TSA locks required in Europe?
No - the TSA rule is US-specific. European screeners follow their own procedures, and a TSA lock is optional but common for cross-market products. Design a lockable case with TSA approval if it may be sold or carried into the US.
Can I ship luggage with a built-in power bank?
Checked baggage: no for loose power banks, and built-in batteries are heavily restricted. Carry-on: yes, with a removable battery under typical 100 Wh limits. Design for a removable battery and document the process.
What is REACH and do I need it?
REACH is the EU's chemical regulation. For luggage, importers should obtain material screening documentation from the factory showing restricted substances are within limits. It is a supply-chain document, not a one-time certificate.
What happens if my luggage fails customs compliance?
At best, delay and inspection fees; at worst, seizure or recall. The cost of a non-compliant container is many times the cost of getting the spec right in the RFQ.
Do electric riding luggage products need special approval?
Yes - battery-powered ride-on luggage is regulated as a battery device and faces airline-specific restrictions, and some routes prohibit it entirely. Treat it as a separate, market-by-market compliance project.
How do I prove compliance to retailers?
Provide the compliance documents: TSA approval references, battery capacity and removal documentation, REACH/RoHS screening, and for kids' products the applicable safety standard reports. Retail buyers increasingly ask for these before listing.