Common Compliance & Recall Risks for Bags Sold in the EU & UK


Sofeast commissioned some research recently on which chemical compliance incidents occurred in EU countries in the past year 22/23, the substances found, where, and the actions taken by authorities.

Let’s look at issues found in bags by market surveillance authorities. This is understandable because they commonly use leather, plastic, and metal parts, three materials where banned or restricted substances can often be found if manufacturers haven’t followed compliant industry regulations.

Note: we only cover chemical compliance in this article, but it is probably the most important compliance aspect for bags in general.



What are the main applicable regulations & directives?

In general, we investigated these common regulations and standards that market surveillance authorities tend to check products against:

For bags, we would expect to find them fall foul of REACH, RoHS, and POPs.


Market surveillance on chemical substances: recalls and withdrawals from market

As you can see, bags were not the product type with the most incidents discovered, but we can learn about their niche from the data:

bags chemical compliance incidents These banned substances were found in bags:

  • Di-(2-ethylhexyl) phthalate (DEHP) – most commonly
  • Cadmium (likely in metal parts)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

Phthalates are plasticizers which are added to plastics to increase strength, durability, flexibility, and transparency. They’re banned or restricted because they’ve been scientifically shown to disrupt hormones and cause birth defects and are banned under RoHS.

Cadmium is a harmful metal which is often found in metal parts and jewellery as it is a by-product of zinc production, a metal commonly found in these types of products. However, it’s one of the RoHS-banned substances because it is a toxic carcinogen.

Which regulations were not complied with and by whom?

incidents and materials per product category In the 13 incidents we found connected to bags, only the REACH regulation was found to have been breached due to the nature of the substances found.

12 of the incidents occurred in bags from the PRC, while one was of an unknown location.

What steps did the authorities take?

It should be noted that the incidents were picked up by market surveillance authorities from different EU countries:

  • Estonia 1x
  • Hungary 9x
  • Italy 1x
  • Poland 1x
  • Sweden 3x

Authorities took several steps to reduce the risk posed by the offending bags:

  • 6 were withdrawn from the market.
  • 2 were recalled from end users.
  • 3 had their online marketplace listings taken down.
  • 5 were banned from being marketed moving forward along with accompanying measures.
  • However, in this case, none were stopped and rejected at the border.


General advice to reduce such risks

Make sure you work with suppliers who are aware of the regulations in the countries where the bags are to be sold.

Ask your supplier for confirmation that every material is compliant, with testing reports if possible as evidence.

If you have a doubt, run a risk analysis (and the list of most common issues found, as laid out above, will be useful) and take action. It could mean that you select the suppliers of certain materials directly (and you ensure those are reputable manufacturers that show evidence of compliance) and/or you run some laboratory tests.

Finally, if you are still unhappy about the product’s risk profile, you may have to re-design it and choose less risky materials.

About Renaud Anjoran

Our founder and CEO, Renaud Anjoran, is a recognised expert in quality, reliability, and supply chain issues. He is also an ASQ-Certified ‘Quality Engineer’, ‘Reliability Engineer’, and ‘Quality Manager’, and a certified ISO 9001, 13485, and 14001 Lead Auditor.

His key experiences are in electronics, textiles, plastic injection, die casting, eyewear, furniture, oil & gas, and paint.

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