The direct answer
REACH is the EU's chemicals regulation, and its four pillars - Registration, Evaluation, Authorisation and Restriction - form one system: manufacturers and importers must know what is in their products, prove it is safe, and manage the most hazardous substances through authorisation and restriction. For a luggage factory or an EU importer, REACH rarely means registering a suitcase as a chemical; it means knowing which SVHCs are in the components and meeting the communication duties when they exceed 0.1%. The regulation binds the economic operators placing goods on the EU market - and that includes the importer, not only the factory.
The four pillars
|
Pillar |
What it does |
Where luggage meets it |
|
Registration |
Companies register substances above certain tonnages with ECHA |
Rarely relevant to a finished suitcase |
|
Evaluation |
ECHA and member states assess registrations and substances |
Indirect - drives what gets restricted |
|
Authorisation |
SVHCs on the Candidate List need authorisation for continued use |
The Candidate List is the list your report screens |
|
Restriction |
Certain uses of dangerous substances are banned or limited |
Entry points 51-74 of Annex XVII, among others |
For an article like a suitcase, the Candidate List and its 0.1% threshold are where REACH becomes a daily question. The other pillars operate upstream, in the chemical industry - but their output, the Candidate List, is exactly what a REACH report tests.
Who REACH binds
REACH places obligations on the operators who put products on the EU market:
- EU manufacturers of substances and articles.
- EU importers - the party that brings the product into the EU. This is the key one for overseas factories: your EU customer is the responsible economic operator.
- EU downstream users and distributors who supply articles.
A factory in China is not directly bound by REACH, but it is the source of the data the EU importer needs. That is why importers ask factories for REACH reports, declarations and component information - the regulation puts the obligation on the importer, and the importer pulls the evidence back through the supply chain.
Where luggage sits in REACH
Luggage is an "article" under REACH - an object with a shape, surface or design that determines its function more than its chemical composition does. Articles are not registered like substances, but two article-specific duties matter:
- Communication (Article 33) - if an article contains an SVHC above 0.1%, the supplier must provide the recipient with enough information for safe use, including the substance's name.
- Notification (Article 7(2)) - if the SVHC is present above 0.1% and the total quantity exceeds one tonne per producer or importer per year, the importer must notify ECHA.
The threshold in both cases is 0.1% weight by weight - the number our report tests against.
Factory data: When an EU buyer asks us "is this REACH compliant?", the honest answer has three parts: here is the report showing every tested component below 0.1% for the current Candidate List, here is the declaration, and here is the piece that belongs to you - the importer's communication and notification duties, which only the EU economic operator can fulfil. We supply the evidence; the obligation travels with the goods.
What "REACH compliant" does and does not mean
- It means the tested sample meets the 0.1% communication threshold for the Candidate List version screened.
- It does not mean the substances are "banned everywhere" - the Candidate List manages risk through communication, authorisation and restriction, not a blanket ban.
- It does not mean other EU rules are covered - RoHS, the toy safety framework, packaging rules and battery rules are separate directives with their own scopes.
- It does not mean every batch is identical - a report covers a sample; production control keeps the sample representative.
FAQ
Is REACH a ban on dangerous chemicals?
Not exactly. REACH is a risk-management system: some substances are restricted or need authorisation, while Candidate List SVHCs mainly trigger communication duties above 0.1%. "Restricted" and "listed as SVHC" are different categories.
Does my factory need to register the suitcase under REACH?
No - articles are not registered like substances. The relevant obligations for articles are the 0.1% communication and notification duties, which fall on the EU importer.
Who is responsible for REACH compliance - the factory or the importer?
The EU importer is the responsible economic operator under REACH. The factory's job is to provide the evidence - test reports, declarations and component information - that makes the importer's compliance possible.
What is the difference between the Candidate List and Annex XVII?
The Candidate List identifies SVHCs heading toward authorisation. Annex XVII contains restrictions on specific uses of dangerous substances. Both matter, and a full compliance picture may reference both.
Does REACH apply to products sold only outside the EU?
No - REACH is an EU regulation. Products destined for other markets need the chemical rules of those markets.
How do I prove REACH compliance to a buyer?
Provide a test report with a date-stamped Candidate List scope, the matching declaration, and component information. The report proves the sample; the importer's processes prove the ongoing supply chain.
About this report
The REACH framework in this article is documented in report No. S260120016001-1 and declaration No. S260120016001-2 for our Model 8404 - screened against the 251-substance Candidate List (Nov 5, 2025) plus 4 assessing substances, all below 0.1%. We share the documents and the importer-side explanation with EU buyers. Contact clkbusiness@clkluggage.com or WhatsApp +86-18879628221 for the evidence pack or for help reading a factory's REACH documents.