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

On 17 December 2025, the European Commission published a formal Note for Guidance clarifying the implementation of Commission Regulation (EU) 2024/3190, which bans the use of bisphenol A (BPA; 80-05-7) and restricts other hazardous bisphenols and bisphenol derivatives in certain food contact materials and articles.

Scope and materials covered

The guidance confirms that the Regulation applies to the material groups listed in Article 1(2) of Regulation (EU) 2024/3190. These groups include plastics, varnishes and coatings, printing inks, adhesives, ion-exchange resins, silicones and rubber. Paper and board are not within the scope of the regulation, although the rules apply where regulated materials form part of a multi-material food contact article. Enamel, where it constitutes a glass-based material melted onto substrates, is also excluded.

Recycled food contact materials are considered outside the scope of the ban where BPA or other bisphenols are present only as unavoidable adventitious contamination and are not intentionally used in the manufacturing process.

Other bisphenols and current allowances

The guidance explains how the Regulation applies to bisphenols other than BPA and their derivatives. While salts of BPA are banned, certain BPA derivatives, such as bisphenol A diglycidyl ether (BADGE; CAS 1675-54-3), may still be used provided that residual BPA is not present. The use of other hazardous bisphenols with harmonised CMR or endocrine-disrupting classifications is prohibited unless authorisation is granted.

Use of bisphenol S (BPS; CAS 80-09-1) remains permitted for now, subject to existing limits, until the European Food Safety Authority (EFSA) publishes guidance on the data required for risk assessment. Once this guidance has been issued, businesses will have a defined timeframe in which to apply for derogations to continue placing affected materials on the market.

Compliance documentation, testing and declarations

The Commission clarifies that a Declaration of Compliance is required for all food contact materials within scope, including intermediate materials, even where BPA has not been used. All bisphenols and bisphenol derivatives used in the manufacturing process must be listed in the declaration.

While analytical testing is not mandatory in all cases, it may be required where BPA is permitted under specific derogations or where other bisphenols are used and residual BPA must be excluded. A detection limit of 1 µg/kg has been identified as feasible for both migration and residual content testing, pending further work by EU reference laboratories.

Transitional timelines through 2026 to 2029

The guidance provides detailed explanations of the transitional provisions, including the differences between intermediate materials and final food contact articles. In general, final food contact articles may first be placed on the EU market 18 or 36 months after the provisions come into force, depending on the use case. Additional sell-through periods apply for filled packaging and repeat-use articles, with timelines extending to January 2029 in some cases.

The Commission emphasises that transitional deadlines primarily apply to final food contact articles, while intermediate materials may only continue to circulate insofar as is necessary to complete compliant final products before the relevant deadlines.

Who is affected

The guidance is particularly relevant for manufacturers, converters, brand owners and importers involved in food contact materials, especially where BPA or alternative bisphenols such as BPS, BADGE or bisphenol AF (BPAF; CAS 1478-61-1) are used in materials, coatings, inks or adhesives. The guidance is intended to support consistent enforcement and compliance planning across the EU during the transition to BPA-free food contact materials.

The complete Note for Guidance can be accessed here.