EU Publishes Guidance for Industry on BPA Food Contact Materials Ban

In December 2024, the European Commission officially adopted a ban on the use of Bisphenol A (BPA) and other hazardous bisphenols in food contact materials (FCMs). Commission Regulation (EU) 2024/3190 came into effect on January 20, 2025, but has transition periods spanning 18–48 months for different articles.
To support industry compliance with Regulation 2024/3190, the Commission has published a guidance on the use of BPA and other bisphenols and bisphenol derivatives in FCMs and articles intended to come into contact with food. The guidance is structured in 40 questions-and-answers, making key clarifications about:
- Scope: BPA is prohibited in the manufacture of FCMs, including plastics, coatings, inks, and adhesives. Paper and cardboard are not included in the ban, unless combined with other regulated materials. The regulation does not cover enamelware, pet food contact materials, external components not intended to come into contact with food, or recycled materials containing trace amounts of unintentionally added BPA.
- Other bisphenols and bisphenol derivatives: Other bisphenols (in addition to BPA) considered to be “hazardous” due to their harms to human health that are also banned under Regulation 2024/3190 include Bisphenol S (BPS), Bisphenol AF (BPAF), tetrabromobisphenol-A (TBBPA), phenolphthalein, and 4,4'-isobutylethylidenediphenol. BPA derivatives such as bisphenol-A diglycidyl ether (BADGE) are not banned from use in FCMs but, if used, must not contain residual BPA.
- Compliance and testing: Regulated materials must be accompanied by a Declaration of Compliance (DoC) demonstrating that BPA has not been used in their manufacture. Laboratory testing is not compulsory but may be useful to ensure compliance when another bisphenol or derivative (e.g., BADGE) has been used in the manufacture of the FCM. If other bisphenols are used, they must not contain BPA residues above the detection limit of 1 microgram per kilogram (μg/kg).
- Transition periods: The dates by which various FCMs on the market must comply with Regulation 2024/3190 are: July 2026 for most single-use FCMs, July 2027 for reusable FCMs, January 2028 for select single-use FCMs like produce packaging, and January 2029 for some professional-grade reusable FCMs. Products placed on the market prior to the end of the applicable transition period may be sold until their stocks are exhausted, even after the transition period ends.
Products imported into the EU must comply with Regulation 2024/3190, the same as domestic goods.
The full guidance document can be read here.
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