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Feeding bottles are ubiquitous serving containers for babies and young children. They come in different sizes and shapes, and are both convenient and durable. Plastic feeding bottles are practically indestructible but glass bottles, although easier to clean, are not shatterproof. To legally protect our youngest population, these food contact products must not transfer their constituents to food in quantities which could endanger the health of our young children or to give unacceptable changes in the composition of food. 

Bisphenol A

Over the years, there have been concerns on the use of bisphenol A (BPA) in plastic feeding bottles. Bisphenol A is an industrial chemical used in the manufacture of polycarbonate; a clear, hard plastic used in many consumer products, including feeding bottles. Bisphenol A is an endocrine disruptor and interferes with our body’s hormones, a class of signalling molecules essential for physiology and behaviour such as metabolism, sexual functions and reproductive processes. The hormonelike properties of BPA raise concerns about its suitability in feeding bottles.  According to studies, BPA can be released from these products when boiling water is poured into the bottle to create formula feeds.

Regulation of Plastic Feeding Bottles

The use of plastic feeding bottles is highly regulated in the European Union (EU) and the United States (US). It is important for manufacturers, importers and retailers to understand and to comply with the laws and standards, and often very different specifications, for identical products destined for these regions.

In the EU, plastic feeding bottles must conform to the general requirements as mandated in the EU-wide framework for food contact materials and articles. A wide variety of substances are allowed to be used in the manufacturing process but the use of bisphenol A (BPA) in polycarbonate feeding bottles is strictly prohibited.

The prohibition of BPA is also evident as part of a wider scope of products for young children in some member states. The relevant legislation and scope for these include:

  • Regulation (EC) 1935/2004 ‘Framework for food contact materials and articles’
  • Regulation (EU) 10/2011 ‘Food contact plastics’
  • Regulation (EU) No 321/2011 ‘Prohibition of BPA in polycarbonate infant feeding bottles’
  • Prohibition of BPA in food containers for children up to the age of 3 (Belgium, Denmark and France)
  • Sweden ‘Prohibition of BPA in paints and coatings in food packaging for children up to the age of 3’

In the US, plastic feeding products are regulated by the Food and Drug Administration (FDA) and other jurisdictions. Under the FDA, epoxy resins derived from BPA as coatings in packaging for powdered and liquid infant formula are prohibited. The use of BPA in food containers for young children, including feeding bottles, is highly restricted in California but prohibited in 14 jurisdictions across the nation; Connecticut, Delaware, Illinois, Maryland, Maine, Massachusetts, Minnesota, Multnomah County, Nevada, New York, Vermont, Washington, Washington DC and Wisconsin. The relevant FDA laws and their scope include:

  • 21 CFR 175.300 Resinous and polymeric coatings.  Prohibition of BPA in epoxy resins as coatings in packaging for powdered and liquid infant formula
  • 21 CFR 177 ‘Indirect food additives: polymers’

Other Applicable Standards

In the EU, there are a number of EU-wide and member state specific standards for feeding bottles. Examples of these include:

  • Directive 93/11/EEC ‘Release of N-nitrosamines and N-nitrosatable substances from elastomer or rubber teats and soothers’
  • The restricted substances such as organotins (entry 20), cadmium (entry 23), polycyclic aromatic hydrocarbons (PAHs, entry 50) and phthalates (entries 51 and 52) under ANNEX XVII of REACH
  • Denmark Statutory Order 855 of 5 Sept 2009 (phthalates in products for children 0-3 years old)
  • EN 14350:2 ‘Child use and care articles – drinking equipment’
  • PAHs under Germany’s voluntary GS Mark (Committee on Product Safety, AfPs)

Across the US, feeding bottles are regulated by federal, state and county laws. Examples of these include:

  • CPG Sec. 500.450 ‘Nitrosamines in rubber baby bottle nipples’
  • The Consumer Product Safety Improvement Act of 2008 (CPSIA, lead and phthalates)
  • Illinois Lead Prevention Poisoning Act (LPPA, PA 95-1019 and 97-0612, lead labelling)
  • California Proposition 65 (Prop 65)
  • California Chapter 672, Statutes of 2007 (AB 1108, phthalates)
  • Maine Toxic Chemicals in Children’s Products (Title 38, Chapter 16-D, priority chemicals(PCs))
  • New York Counties of Albany, Rockland and Suffolk (Toxic Free Toys Act)
  • New York Westchester County (Children’s Product Safety Act)
  • Oregon Toxic Kids Act (Chapter 786, Laws 2015, high priority chemicals of concern (HPCCs))
  • Vermont 18 V.S.A. Chapter 38A (chemicals of high concern to children,CHCCs), Act 188 (2013-2014)
  • Washington Children’s Safe Product Act (CSPA, chemicals of high concern to children, CHCCs)

SGS Solutions

  • SGS has an international team of professional experts with a comprehensive knowledge of feeding bottles and other food contact products for international markets.
  • Full range of services to assist you, whether you need to check products against legislative standards, retailer requests, or for your own peace of mind and brand protection.
  • Consultancy, factory audits
  • Can be customised to suit your needs and budget

For further information about SGS food contact services, contact your local representative or our global experts.

HingWo Tsang, Ph.D.
Toys and Juvenile Products
Information and Innovation Manager
SGS Hong Kong Limited
t: +852 2774 7420