REACH compliance series — hub index. Start with this article for what REACH actually is, then go deeper:
- REACH for Luggage — the luggage-level overview
- The 251+4 scope & how to read the report
- REACH in your supply chain
- How to verify a REACH report
- SVHC risk map of luggage components
- The Candidate List & why 251+4 grows
- The 0.1% rule
- The 10 substances & their limits
- Phthalates in luggage
- Lead & the 100 ppm rule
- How the lab tests 251 substances
Each article in this series explains one piece of REACH for luggage — definition, documents, verification or the supply chain.
An EU Buyer Asked Me: "Is This REACH Compliant?"
I get that question a lot. My answer has three parts, and the third one usually surprises people.
Part one: here is the report showing every tested component below 0.1% for the current Candidate List. Part two: here is the declaration. Part three: 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 Actually Is
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.
| 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 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%. 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 Actually 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's 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 a Suitcase 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.
What "REACH Compliant" Means — and What It Doesn't
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.
Honestly, the phrase gets abused in sales emails. "REACH compliant" is a precise statement about a tested sample against a dated list. Anything broader is someone's interpretation, and you should ask for the document behind it.
The Documents Behind This Article
Everything above is documented, not asserted. The REACH framework here sits 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. Ask for the evidence pack at clkbusiness@clkluggage.com or WhatsApp +86-18879628221 if you need help reading a factory's REACH documents.
Frequently Asked Questions
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 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