RoHS compliance series — hub index. Start with this article for what RoHS actually is, then go deeper:
- RoHS for luggage — does it apply?
- RoHS for smart luggage & the 10 substances
- How the lab measures RoHS
- Non-metal vs metal in the report
- Does luggage need RoHS? (EEE scope)
- RoHS in your supply chain
- How to verify a RoHS report
Each article in this series explains one piece of RoHS for luggage — definition, documents, verification or the supply chain.
Here's a question that sounds easy and isn't: what actually is RoHS? Most people answer "something about chemicals in electronics" and move on. The regulation is more specific than that, and the specifics decide whether your product is in or out.
RoHS Directive 2011/65/EU (RoHS 2) restricts ten hazardous substances in electrical and electronic equipment (EEE) placed on the EU market, applying to each homogeneous material in the product.
The original 2003 directive covered six substances. The 2011 recast brought it under the CE framework and expanded scope. Directive (EU) 2015/863 added four phthalates, creating the "RoHS 10" scope used today. For a suitcase, the trigger is simple: electronics in the product bring the product into scope.
From Six to Ten Substances
| Step | What changed |
| RoHS 1 (2003) | Restricted lead, mercury, cadmium, hexavalent chromium, PBB, PBDE |
| RoHS 2 (2011) | Recast the directive, aligned it with CE marking, expanded scope categories |
| (EU) 2015/863 | Added DEHP, BBP, DBP and DIBP to Annex II — the phthalate update |
| July 2019 onward | The ten-substance scope applies to most EEE categories |
The report in this series tests the full ten-substance scope, which is why the cover page cites both 2011/65/EU and (EU) 2015/863.
What Equipment Is in Scope
RoHS covers electrical and electronic equipment — products that depend on electric currents or electromagnetic fields to work. The directive defines categories (from large appliances to IT equipment and consumer electronics), and any EEE within scope must comply unless an exemption applies.
Where luggage sits:
- A mechanically simple suitcase is not EEE.
- Add a charging circuit and USB ports, and the product depends on electricity to perform part of its function — which brings it into scope.
This is exactly why our Model 1338, a charging multi-function trolley box, carries RoHS documentation alongside its EMC report.
How RoHS Is Enforced
RoHS compliance is part of CE marking for EEE:
- The manufacturer or importer assesses the product against the applicable directives.
- Testing to the EN 62321 series provides the evidence for the restricted substances.
- A Declaration of Conformity and technical file support the CE mark.
Market surveillance authorities can check products at any time — and the substance restrictions are the kind of thing enforcement labs actually verify.
The Responsibility Chain
Like REACH, RoHS places obligations on the EU economic operator. The factory supplies the test evidence; the importer or EU manufacturer holds the CE responsibility and the technical file. A foreign factory's RoHS report is the evidence layer; it is not the whole CE story.
When we prepare RoHS evidence for Model 1338, we test the actual materials that go into production — in this case the non-metal fabric — using the harmonized EN 62321 methods. The report is part of the CE technical file the importer assembles, which is why we keep the method, sample and result pages complete and verifiable.
Frequently Asked Questions
What is the difference between RoHS 1 and RoHS 2?
RoHS 2 (2011/65/EU) recast the 2003 directive, aligned it with CE marking and expanded the scope categories. The ten-substance list came later with (EU) 2015/863.
Is a USB-charging suitcase electrical and electronic equipment?
Yes — if the product depends on electricity to perform a function (charging), it falls within the EEE scope and RoHS applies to its materials.
What does homogeneous material mean in RoHS?
A material that cannot be mechanically disjointed into different materials — for example, the shell plastic, the zipper plating or the fabric. Limits apply to each homogeneous material, not to the whole product.
Is RoHS part of CE marking?
Yes — for EEE, RoHS is one of the CE-relevant directives, alongside EMC and others. The CE mark covers the whole set, not just substance restrictions.
Who is responsible for RoHS compliance?
The EU manufacturer or importer holds the CE responsibility. The factory supplies the test evidence and material data that make the importer's compliance possible.
Does a mechanical suitcase need RoHS?
No — RoHS applies to EEE. A suitcase with no electronic function is outside the directive's scope, though REACH considerations still apply to EU sales.
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