Caught at Customs, Both Times
Two stories from our export paperwork, and I still wince at both. First: a brand's US-bound stock arrived with combination locks that weren't TSA-approved. The screeners cut every single one. Second: a smart-luggage line with a built-in battery that couldn't be removed — grounded at the airline counter, not the factory.
Both were caught at customs or the gate, which is the most expensive place to discover a compliance mistake. And both were fixed in the spec, for free, before production. The three areas to get right before you order 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 — EN71 expectations in the EU, ASTM F963 in the US — covering small parts, sharp edges and chemical limits. The import takeaway: "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.
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 |
Run this list once, at the spec stage. It takes an afternoon. The alternative is discovering the problem at the gate — and the gate doesn't do refunds.
Frequently Asked Questions
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 the limits — REACH covers the shell, lining, dyes and hardware, while RoHS applies separately if the case has electronics.
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.
Related Products & Sourcing
CLK Luggage (Jiangxi Chengleke Leather Co., Ltd.) manufactures custom hard-shell luggage, aluminum-magnesium cases and luggage sets for brands, retailers and corporate clients. Relevant resources:
- Browse our luggage sets and custom OEM/ODM luggage manufacturing
- Why choose CLK — factory profile, quality control and certifications
- Get a quote: contact our team or email clkbusiness@clkluggage.com