EU Issues Guidance on Implementation of BPA and Bisphenol Restrictions in Food Contact Materials

On December 17, 2025, the Official Journal of the European Union published the European Commission's guidance document for the implementation of Commission Regulation (EU) 2024/3190. The guidance provides a compliance roadmap for businesses using Bisphenol A (BPA) or its alternatives (such as BPS, BADGE, or Bisphenol AF) in materials, coatings, inks, or adhesives, addressing key aspects through 40 Q&As covering the scope of application, other bisphenols and bisphenol derivatives, compliance and testing, market placement, and transitional provisions.

Scope of Application

• The use of BPA in the manufacture of food contact materials (e.g., plastics, coatings, inks, adhesives) is prohibited.
• Paper and cardboard are not subject to the ban. However, if combined with other regulated materials, the entire product must comply.
• Recycled materials containing only trace amounts of BPA (non-intentionally added) are exempt from the ban.
• The regulation does not apply to enamelware, materials contacting pet food, or external parts not intended to come into contact with food.

Other Bisphenols

• BPA derivatives (e.g., BADGE) are not entirely banned but must be free from BPA residues.
• Five bisphenols, including BPS, BPAF, and TBBPA, are uniformly classified as "hazardous bisphenols" due to reproductive toxicity or carcinogenicity and are prohibited, except under specific authorization.
• Companies needing to use these hazardous substances must apply to the EU for authorization and submit safety assessment data required by EFSA.

Compliance and Testing

• Laboratory testing is not mandatory, but companies must demonstrate the absence of BPA use through documentation, such as a Declaration of Compliance (DoC).
• If other bisphenols are used, it must be ensured that they contain no BPA residue (with a detection limit of 1 μg/kg).
• All regulated materials (even those not using BPA) must be accompanied by a DoC, covering both intermediate and final products.

Market Placement and Transitional Provisions

• The regulation takes effect from January 20, 2025, but includes transition periods:
• Single-use food contact materials: Can be sold until July 20, 2026, at the latest (some, like fruit and vegetable packaging, until January 20, 2028).
• Reusable food contact articles (e.g., beverage bottles, kitchenware): Can be sold until July 20, 2027 (some professional equipment until January 20, 2029).
• Imported products are subject to the same rules as those produced within the EU.
• After the transition periods end, products already on the market may continue to be sold until stocks are depleted but cannot be placed on the market anew.

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Further Information

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