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Manufacturing [Manufacturing & Supply](/ecosystems/manufacturing-supply)BOM 

# Bill of Materials

Structured list of every component, sub-assembly, and quantity needed to manufacture a device.

Reviewed by [Christian Espinosa, Founder, Blue Goat Cyber](/authors/christian-espinosa) Last reviewed May 5, 2026 

## Definition

BOMs are released as part of the  [Device Master Record](/terms/dmr) and drive purchasing, planning, costing, and traceability. Engineering, manufacturing, and service BOMs may differ in level of detail. 

What the regulation says

Regulators view the Bill of Materials (BOM) as a critical component of the  [Device Master Record](/terms/dmr) (DMR), essential for establishing and maintaining product conformity, as per 21 CFR Part 820.181 for medical devices in the United States and EU  [MDR](/terms/mdr-reporting) Annex II for devices marketed in the European Union. The BOM supports requirements for design control,  [production and process controls](/terms/production-process-controls), and traceability, ensuring that all components and materials used in a medical device meet specified requirements. 

## What this means in practice

BOM accuracy is foundational for  [UDI](/terms/udi) assignment,  [lot traceability](/terms/lot-traceability), and recall scoping; errors propagate broadly. 

## Examples

-   A medical device manufacturer uses the BOM to ensure that all sterile barrier system components are sourced from approved suppliers and meet specific material requirements, maintaining sterility assurance.
-   During a product recall, the BOM helps identify all affected devices by tracing specific lots of a faulty component back to the finished products in which they were used.
-   An auditor reviews the BOM to verify that all critical components listed in the design FMEA are present and correctly specified, aligning with the risk management file.

Common pitfalls

-   • A common pitfall is failing to maintain an accurate BOM throughout the device lifecycle, leading to discrepancies between the documented and actual device configurations. 
-   • Another mistake is not linking the BOM to other critical quality system elements, such as risk management files or design outputs. 
-   • Inadequate version control of BOMs can result in the use of obsolete or incorrect components in medical device manufacturing. 
-   • Failing to account for software and cybersecurity-related components in the BOM can lead to gaps in addressing software-as-a-medical-device (SaMD) requirements and cybersecurity vulnerabilities. 
-   • Not ensuring that supplier changes are reflected in the BOM can result in non-conforming materials being used in production. 

## Frequently asked questions

What is the primary regulatory purpose of a Bill of Materials in MedTech? 

The primary regulatory purpose is to document all components, raw materials, and sub-assemblies of a medical device, facilitating traceability, quality control, and compliance with design and production specifications outlined in regulations like 21 CFR Part 820 and the EU  [MDR](/terms/mdr-reporting). 

How does the BOM relate to device traceability? 

Should a software Bill of Materials (SBOM) be part of the overall BOM? 

## Related terms

Grouped by theme 

### Editor's picks

· Hand-selected related concepts 

[

Manufacturing

Device Master Record(DMR) 

Compilation of records containing the procedures and specifications for a finished device.





](/terms/dmr)[

Manufacturing

Lot Traceability

Ability to trace materials, processes, and devices forward and backward through the supply chain by lot number.





](/terms/lot-traceability)

### More in Manufacturing

· Same category 

[

Manufacturing

Bioburden

Quantification of viable microorganisms on or in a product before sterilization.





](/terms/bioburden)[

Manufacturing

Cleanroom Classes (ISO 14644)

ISO 14644 classification of cleanrooms by airborne particulate cleanliness (ISO 1 through ISO 9).





](/terms/cleanroom-iso-14644)[

Manufacturing

Container Closure Integrity(CCI) 

Demonstration that a sterile package maintains microbial barrier and contents integrity over the labeled shelf life.





](/terms/container-closure)[

Manufacturing

Counterfeit Parts and Suspect Components

Risk of unauthorized, fraudulent, or substandard components entering the supply chain.





](/terms/counterfeit-parts)

Cited by

Where this term appears across MedTech Terms.

Ecosystems (1)

-   [Manufacturing & Supply](/ecosystems/manufacturing-supply)

## Primary references

3 sources 

Link health:  3 verified · last checked 2026-06-20 

ISO· 2 FDA· 1 

1.  [1 
    
    ISO 13485 §4.2.3
    
    Verified 
    
    ISO · iso.org 
    
    
    
    ](https://www.iso.org/standard/59752.html)
2.  [2 
    
    FDA - Device Manufacturing
    
    Verified 
    
    FDA · fda.gov 
    
    
    
    ](https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-assistance/postmarket-requirements-devices)
3.  [3 
    
    ISO 13485 Standard Page
    
    Verified 
    
    ISO · iso.org 
    
    
    
    ](https://www.iso.org/iso-13485-medical-devices.html)

Inline markers like \[1\]  jump to the matching reference above.

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On this term

Category

Manufacturing

Acronym

BOM

Sources

3

Updated

5/5/2026

[Compare with another term](/compare?a=bom)

Learn in 60 seconds

Card Lesson Quiz

Structured list of every component, sub-assembly, and quantity needed to manufacture a device.

-   · BOM accuracy is foundational for UDI assignment, lot traceability, and recall scoping; errors propagate broadly. 
-   · Engineering, manufacturing, and service BOMs may differ in level of detail. 

Remember this

Watch out: A common pitfall is failing to maintain an accurate BOM throughout the device lifecycle, leading to discrepancies between the documented and actual device configurations.

Related terms

-   [Device Master Record(DMR) ](/terms/dmr)
-   [Lot Traceability ](/terms/lot-traceability)

You may also need

Auto-suggested from Manufacturing and shared keywords.

-   [Engineering Change Order / Notice(ECO / ECN) ](/terms/eco-ecn)
-   [Software Bill of Materials(SBOM) ](/terms/sbom)
-   [Device History Record(DHR) ](/terms/dhr)
-   [Device Master File(MAF) ](/terms/device-master-file)
-   [Quality System Regulation(QSR / 21 CFR 820) ](/terms/qsr)
-   [Capitalization Table(Cap Table) ](/terms/cap-table)

[All Manufacturing terms](/terms?cat=Manufacturing)

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Resources

-   [FDA Medical Devices](https://www.fda.gov/medical-devices)
-   [EU MDR](https://eur-lex.europa.eu/eli/reg/2017/745/oj)
-   [IMDRF](https://www.imdrf.org/)
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-   [Changelog](/changelog)
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