A guide into stress-free product compliance

You need a Bill of Materials (BOM)

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

Chemicals are risk #1

Restricted and banned chemical substances are the major reason for recalls of non-food consumer goods in the EU.
About 40% of the recalls in the EU are related to chemical risks.

Phthalates in toys, flame retardants in electronics, lead in solder, cadmium in jewellery, chromium-VI in leather, strong skin sensitisers in cosmetics, cancer causing substances (carcinogens) in glue, tattoo inks or cosmetics; the list is longandversatile.

A proper chemical regulatory safety assessment (CRA) will reduce the business risks and at the same time savecostsontesting.

An appropriate Bill of Materialsis the key element in this assessment.

Safety gate image

SAFETY GATE, formerly known as RAPEX is the EU's rapid alert system for dangerous non-food products.
Every day authorities in 31 European countries exchange insightful information on product recalls via the official website.

REACH diagram

Products consist of parts. These parts are made from different materials such as:

  • plastics,rubbers;
  • textiles,fabrics;
  • metals;
  • wood;
  • paper,cardboard;
  • glass;
  • organicmaterials;
  • substances,mixtures;
  • othermaterials.

Parts are made from or treated by chemicals. For instance wood can be treated with preservatives and/ or having varnish layers or coatings. Substances can be mixed with plastic to create UV stability, make them easier to clean, extra bright or scratch resistant. Some chemicals can be harmful for public health and/or the environment. Chemical regulatory requirements exist for this reason. You must investigate if these restricted chemical substances are present in the materials/component of your consumer product.

It starts with a Bill of Materials

A Bill of Materials (BOM) is a list of the materials and components of your product. For each material you must try to obtain information about the chemical composition.

If a part is made from a plastic, you should know or ask which plastic (PVC, ABS, Nylon..).
Once you know the type plastic you should try to obtain the chemical composition, that is what kind of additives are used, what kind of plasticisers, colourants and so on.

This underlaying knowledge can be presented in so-called bill of substances (BOS) or material formulation. A well organised and responsible B2B supply chain should be able to present the underlying information relative easy. After all substances may not be delivered without a SDS. That means information should be present.

Obtaining underlaying knowledge about the listed materials in your bill of materials will result in a more comprehensive assessment which will safe you costs on chemical analysis.

The Bill of Materials will enable you to perform a chemical risk assessment on the presence of hazardous elements in your products.


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