EU Corrects BPA Rules for Food Contact Materials, Clarifying Transitional Deadlines

On February 3, 2026, the European Commission published a revision to the regulation governing the use of bisphenol A (BPA) in food contact materials and articles. The revised regulation entered into force on February 23, 2026. The revision aims to amend and clarify provisions in the earlier BPA regulation to address inconsistencies and improve regulatory clarity. It refines relevant definitions, clarifies transitional arrangements, and updates compliance requirements for the use of BPA in food contact materials and articles placed on the EU market, except for specific derogated applications.

1. Transitional Arrangements

For single-use final food contact articles

These may continue to be placed on the EU market until July 20, 2026. Certain products for specific uses, such as packaging intended for storing fruits, vegetables, or aquatic products, may continue to be marketed until January 20, 2028.

For repeat-use articles placed on the market under transitional rules

For repeat-use articles first placed on the market before July 20, 2026, the transitional deadline has been brought forward to July 20, 2027 (originally January 20, 2029). For repeat-use articles used in food production equipment and first placed on the market before January 20, 2028, the final deadline of January 20, 2029 remains unchanged.

2. Compliance Documentation Requirements

• Documentation must clearly specify either intermediate materials or final articles, without requiring disclosure of both.
• Analytical methods must verify the absence of residual BPA at a detection limit of 1 μg/kg, unless otherwise specified.

3. CIRS Summary

This revision once again emphasizes that, except for specific exempted uses, food contact materials and articles containing BPA are prohibited from being placed on the EU market. CIRS hereby reminds relevant enterprises to reasonably plan product adjustments and market launch schedules, make full use of the transitional period, and ensure a smooth compliance transition before the regulatory implementation dates, so as to minimize compliance risks to the greatest extent possible.

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