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Information | [EU New Regulations] Detailed explanation of the ban on bisphenol A in food contact materials, these key points need to be paid attention to!
Author.
LCS
Source:
Post time:
2025-12-26
On December 17, 2025, the European Union officially released an important message - Guidance Note on the Implementation of the European Commission Regulation (EU) 2024/3190 on the Prohibition of Bisphenol A and Related Hazardous Bisphenol Substances and Their Derivatives in Food Contact Materials (C/2025/6721). This implementation guide provides a detailed explanation of key information such as the scope of the ban, controlled substances, testing requirements, and transition period. Let's explore further below.
Why is the event significant?
Bisphenol A, also known as BPA (CAS No. 80-05-7), is a common industrial chemical used in the synthesis of polycarbonate, epoxy resin, etc. It is commonly found in can coatings, adhesives, printing inks, and rubber products. But it has potential health risks, especially endocrine disruption. Since the EU Food Contact Plastic Regulation (EU) 10/2011, it has been revised multiple times, such as banning BPA from PC baby bottles in 2011 and extending it to baby cups and kettles in 2018. A global consensus has been reached that the United States, China, South Korea, Japan, and other countries have restrictions, especially a complete ban on BPA in infant and toddler products. The EU is further tightening this time to protect consumer health.
Scope of application: Almost full coverage
Full chain applicability: From raw materials, intermediates to finished products, all must comply with the BPA ban.
Indirect contact also applies: If external components may come into contact with food or harmful substances may migrate to food during normal use, they must also meet the requirements.
Exemption exception: Large containers (>1000 liters) with permanently connected pipelines can be exempted, but pipelines with high S/V ratios or small pipelines cannot.
Not applicable: Food contact paper/cardboard, recycled materials, enamel products, and pet food contact materials - these have temporarily escaped danger.
Controlled substances: BPA and its' relatives' are completely banned
Core prohibition: BPA and its salts are prohibited from being used in all food contact materials. Products containing BPA diglycidyl ether (BADGE, CAS 1675-54-3) must not have BPA residue.
Specific Hazardous Bisphenol: According to Annex 6, Part 3 of (EC) 1272/2008, five types of CMR (Carcinogenic/Mutative/Reproductive Toxic) Bisphenol are currently banned, including:
Bisphenol B (CAS 77-40-7)
Bisphenol S (CAS 80-09-1)
Bisphenol F (CAS 620-92-8, note: ECHA proposed to upgrade to Repro. 1B in September 2024)
4,4 '- methylenebis (2,6-di-tert-butylphenol) (CAS 128-37-0)
Other listed derivatives.
Future expansion: If other bisphenols are classified as Class 1A/1B CMR or Class 1 endocrine disruptors (ED), they will also be automatically banned (except for exemptions).
When conducting enterprise testing, it is necessary to ensure that these substances do not exceed the standard, and it is recommended to use a reliable laboratory for verification.
Compliance requirements:
All related products must be accompanied by a declaration of conformity (excluding the retail sector).
Transition period arrangement:
Before July 20, 2026: Allow the circulation of original compliant disposable/reusable products.
Before January 20, 2028: Specific fruit and vegetable/aquatic product packaging and metal coated products may be postponed.
January 20, 2029: Complete ban on the sale of reusable devices!
Global trend: BPA has been restricted in countries such as the United States, China, Japan, and South Korea, and there is a consensus to completely ban BPA in infant and toddler products.
Enterprises need to adjust their supply chain and product compliance strategies as soon as possible to ensure compliance with new regulations.
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