- Regulation (EU) 2023/988 — GPSR
- Regulation (EC) No 1907/2006 — REACH, Annex XVII
- Regulation (EU) No 1007/2011 where textile
- Regulation (EU) 2023/1542 for smart luggage batteries
Who has to appoint one
Brands and sellers outside the Union placing bags and luggage on the EU market, including print-on-demand and private label operations.
Thresholds and exemptions
None. Smart luggage with a battery adds electrical and battery producer obligations in every country of sale.
What must appear on the label
Manufacturer and responsible person details with an EU address, batch identification, material information where claimed, and for battery-equipped luggage the removal instructions and battery markings required by airlines and by the batteries Regulation.
Marketplace fields
Marketplaces enforce the responsible person. Smart luggage with non-removable batteries has been refused by airlines, which is a commercial as well as a regulatory problem.
Documentation you must hold
Technical documentation with the risk analysis, REACH evidence for chromium VI in leather, azo dyes, phthalates in coated fabrics and nickel release in fittings, and battery documentation with UN 38.3 summaries for powered models.
Standards and testing
Chromium VI testing for leather under REACH entry 47, nickel release under EN 1811 for skin-contact fittings, phthalate screening for PVC components, and handle and wheel durability testing.
Language requirements
Care and warning information in the language of each member state of sale.
When it applies
Before the product is made available.
How long records are kept
Ten years.
What happens if you do not comply
Withdrawal, Safety Gate alerts for chromium VI in leather goods, and marketplace suppression. Battery-equipped luggage additionally faces per-country battery registration fines.
Who enforces it
Market surveillance authorities, customs, and battery registers for smart luggage.
Where the boundary lies
Leather goods fail most often on chromium VI, which forms during tanning and is not visible in the finished product. Smart luggage crosses into electrical, battery and transport regimes simultaneously.
Questions we are asked
- Is leather regulated?
- Chromium VI in leather articles in skin contact is restricted under REACH, and it is one of the most common Safety Gate findings for bags and shoes.
- Can we sell luggage with a built-in power bank?
- Only with the battery obligations met and, practically, only if the battery is removable, since most airlines refuse otherwise.
Who signs for you
EU representative Europe Services, SE — Na Čečeličce 425/4, Smíchov, 150 00 Praha 5, Czech Republic
UK representative REP27 LTD — Unit 82a James Carter Road, Mildenhall, Suffolk IP28 7DE, United Kingdom