Software bill of materials (SBOM)

A formal record of the components, libraries, and modules contained in a software product, drawn up in a commonly used and machine-readable format. Under Annex I Part II of the CRA, manufacturers must produce an SBOM covering at least the top-level dependencies of their product. The SBOM does not need to be made public but must be available to market surveillance authorities on reasoned request.

Source citations

Regulation text

Annex I Part II §1 of Regulation (EU) 2024/2847 requires manufacturers to:

"identify and document vulnerabilities and components contained in products with digital elements, including by drawing up a software bill of materials in a commonly used and machine-readable format covering at the very least the top-level dependencies of the products".

Key requirements

  • Format: Must be machine-readable and use a commonly accepted format. Widely used formats include CycloneDX (ECMA-424) and SPDX (ISO 5962).
  • Scope: At minimum, top-level dependencies must be covered. Deeper transitive dependencies are recommended best practice.
  • Confidentiality: Manufacturers are not obliged to make the SBOM public (Art. 13 recital 77). It is provided to market surveillance authorities on reasoned request.
  • Commission specification: The Commission may adopt implementing acts specifying the format and elements of the SBOM (Art. 13(24)).

Purpose

The SBOM enables manufacturers to:

  • Track which third-party components are used
  • Quickly assess whether known vulnerabilities (e.g. from the EU vulnerability database or CVE databases) affect components in the product
  • Demonstrate due diligence when integrating third-party and open-source components

Relationship to Union dependency assessment

Market surveillance authorities may request SBOMs from manufacturers as part of a Union-wide dependency assessment for specific categories of products (Art. 13(25)), to understand dependencies on FOSS components.

Software bill of materials (SBOM) — CRA Compliance Hub