Bill of Materials (BoM) for EU Importers and Manufacturers

At EaseCert, we treat the Bill of Materials as the backbone of your EU compliance program. A BoM lists every part and material in your product, in a clear hierarchy. It underpins your GPSR technical file, makes the risk analysis complete, and supports chemical rules like REACH and RoHS. This guide explains the regulatory role of the BoM, how to build one, common mistakes, and how it links to labels, testing, and recalls.

Why the BoM matters for EU compliance

GPSR: foundation of your technical file

The General Product Safety Regulation requires technical documentation that proves your product is safe. The BoM provides the factual core of that file. It ties design, materials, tests, labels, and supplier data together. For structure and retention rules, see our technical file guide and detailed documentation checklist.

REACH: substances in articles and SCIP

Under REACH you must know if any article in your complex product contains a Candidate List substance above 0.1 percent by weight. A granular BoM lets you check each sub-component and prepare communications and, where required, SCIP submissions. Plan your evidence with supplier declarations, SDS, and targeted tests. See our overview of chemical testing for EU compliance.

RoHS: restrictions at homogeneous material level

For electrical and electronic equipment, RoHS applies limits to each homogeneous material. A BoM that goes down to solders, plastic resins, cable jackets, paints, and inks allows you to collect and map evidence per part. Many retailers ask for a parts list as part of onboarding. For marketplace expectations, see Amazon EU and GPSR.

Packaging, WEEE, and other regimes

Include packaging in the BoM. Inks, coatings, and adhesives can be restricted. If you place EEE on the market, align your BoM with WEEE registrations and component traceability. See our guides for WEEE registration and LUCID packaging in Germany.

BoM vs. Bill of Substances (BOS)

When a BoM is enough, and when to add a BOS

A BoM lists parts and materials. A BOS lists substances and their concentrations. For many products, a well-detailed BoM with linked declarations and tests is sufficient. In higher-risk categories (toys, certain coatings, batteries), consider maintaining a BOS derived from the BoM and supplier data. Keep substance records with SDS and test reports, then cross-reference them back to the BoM lines.

How to create a compliance-ready BoM

Scope and granularity

List every component and material that forms the product placed on the market. Do not skip small items: screws, washers, adhesives, coatings, inks, heat-shrink, cable ties, trims, and all packaging. Break complex assemblies into child parts. For children’s items, record dimensions and mass where relevant. Align this scope with your age grading and the risk analysis.

Structure and data fields

Use an indented, multi-level structure. Level 1 is the finished product. Level 2 lists major assemblies. Lower levels list parts and materials. For each line include at least: unique part ID, description, material (be precise, for example ABS FR grade, 304 stainless steel, PU coating), quantity or weight, supplier name, supplier part number, and a reference to evidence. Link labels and instructions where the part drives a warning or use restriction. See labelling requirements and warning examples.

Supplier evidence and traceability

Map each BoM line to its evidence: declarations, test reports, SDS, certificates, and drawings. Store files with version control, dates, and expiry tracking. For non-EU brands, appoint an EU Responsible Person to hold the file and respond to authorities. See how to appoint an EU Responsible Person and read the role overview in EU Responsible Person under the GPSR. Cost guidance is here: GPSR and Responsible Person costs.

Version control and change management

Assign BoM revision numbers. When a part or supplier changes, update the BoM, re-check risks, and refresh evidence. Keep the BoM and the technical file in step. If a change adds hazards, update warnings and IFU. For file maintenance, see our GPSR file guide.

BoM template

Copy this starter table into your CMS or export it to a spreadsheet. Add or rename columns to match your product and evidence model.

Examples by sector

Electronics (EEE)

Break down to coatings and solders. Record homogeneous materials like plastic housings, solder joints, cable jackets, and inks. Link each line to RoHS declarations and testing. Keep SVHC checks for connectors, adhesives, and labels. For testing scope, see chemical testing.

Textiles and soft goods

List fabric, trims, prints, coatings, fillers, zippers, cords, toggles, and packaging. Capture dyes and finishes that may trigger REACH restrictions. If the product targets children, align with age grading. For launch planning, use our EU launch checklist.

Toys and hobby products

Document small parts, magnets, coatings, and accessible materials. Cross-reference the BoM with chemical and physical tests and warnings. See toy safety in the EU and our guides on warnings and labeling.

Common mistakes

Leaving out small items

Missing screws, coatings, inks, glues, cable jackets, heat-shrink, or packaging breaks traceability and can hide restricted substances. Include them.

Vague material names

Generic terms do not work. Specify the polymer grade, alloy, coating system, adhesive chemistry, or textile fiber. Keep SDS and supplier specs linked to the BoM line.

No supplier linkage

Every BoM line should name a supplier and part number. Keep current declarations, test reports, and SDS. Update when suppliers change.

Manufacturing BoM reused without compliance detail

Shop-floor BoMs often collapse parts or omit materials. Extend them for compliance. Add material specifics and evidence references. Tie each line to your technical file index.

Confidentiality used to skip detail

Authorities can request parts and materials. Handle confidentiality by contract, not by removing detail. Share the BoM under NDA if needed.

How the BoM fits your GPSR technical file

• Risk analysis uses the BoM as its checklist. See our GPSR risk analysis process.
• Evidence mapping. Cross-reference BoM lines to test reports, declarations, and instructions. See the technical file guide.
• Labelling and warnings. If the BoM adds small parts or hazardous mixtures, update labels and warnings. See labeling requirements and warning examples.
• Traceability and recalls. A precise BoM speeds corrective actions. Read how to handle a GPSR recall, new recall requirements, and EU Safety Gate registration.

Governance, costs, and who holds the file

Responsible Person

If you are outside the EU, appoint an EU Responsible Person to hold the technical file and respond to authorities. See how to appoint and why retailers require it in why you need a Responsible Person.

Costs and planning

Budget for document creation, testing, and maintenance. Use our pricing overview: GPSR and Responsible Person costs. For project scoping, see what we offer and the service catalog under GPSR compliance.

Penalties and liability

Inadequate documentation can lead to enforcement, delistings, and recalls. Learn more about what happens if you do not comply, GPSR penalties, and the EU Product Liability Directive.

Practical add-ons

Testing plan linked to the BoM

Use the BoM to drive testing. Prioritise high-risk materials and children’s products. Combine screening and targeted analytics. See chemical testing.

Supplier handbook

Give suppliers a BoM template and evidence checklist. Specify accepted declaration formats, test methods, and timelines. Align on re-testing triggers and change control.

Market entry and onboarding

Use the BoM to support retailer and marketplace onboarding. For a complete route-to-market view, see EU compliance guide and how to sell to the EU.

Get help

EaseCert helps to complete GPSR files for importers and manufacturers, including marketplace sellers. See what we offer, browse our GPSR services, check the FAQ, or contact us to start.