EU Issues Guideline for BPA and Other Hazardous Bisphenols in Food Contact Materials

SafeGuardSHardgoodsJanuary 13, 2026

SG 002/26

The European Union (EU) has issued guidance for the use of bisphenol A (BPA), other hazardous bisphenols and bisphenol derivatives in certain food contact materials (FCMs).

In 2024, the EU published Commission Regulation (EU) 2024/3190 (the Regulation) on the use of BPA and other bisphenols and bisphenol derivatives in certain FCMs and articles (SafeGuardS 5/25).

In December 2025, the EU issued a guideline (C/2025/67621) to assist stakeholders with the implementation of the Regulation, with harmonized classification for specific hazardous properties in certain FCMs and articles.

Key highlights of the guideline are summarized in Table 1.

Guidance on Commission Regulation (EU) 2024/3190	Highlights
Scope	Emphasizes that the Regulation does not apply to a) paper and board, b) recycled FCMs, c) enamels and d) FCMs for pets Provides rationale on when external parts of FCMs are within the scope of the Regulation Clarifies that pipes permanently affixed to vats and tanks, and the self-supporting material or article in its entirety, which have a capacity of more than 1,000 liters, are considered to fall under the scope of the derogation
Other bisphenols and bisphenol derivatives	Emphasizes that BPA salts are prohibited Explains that BPA derivatives are not specifically banned, unless they are ‘hazardous bisphenols other than BPA or hazardous bisphenol derivatives’ under Article 5 of the Regulation. At present, BPA derivatives such as bisphenol-A diglycidyl ether (BADGE) may be used in FCM manufacturing, but they must comply with residual BPA requirements under Article 4 of the Regulation Clarifies that the Regulation bans other bisphenols or bisphenol derivatives listed in Part 3 of Annex VI to Regulation (EC) No 1272/2008 on classification, labeling and packaging of substances and mixtures (CLP Regulation, current consolidated version to September 2025) as a result of their harmonized classification as carcinogenic, mutagenic or toxic to reproduction (CMR), category 1A or 1B or endocrine disrupting for human health (ED HH) category 1 Indicates that Article 6 of the Regulation permits authorization of hazardous bisphenols or hazardous bisphenol derivatives for specific food contact applications, subject to the authorization procedure under Regulation (EC) No 1935/2004 (current consolidated version to March 2021) Identifies the following bisphenols and bisphenol derivatives as hazardous and falling under Article 5 of the Regulation: 4,4’-isobutylethylidenediphenol (CAS 6807-17-6, Repr. 1B) Bisphenol AF (BPAF, CAS 1478-61-1, Repr. 1B) Bisphenol S (BPS, CAS 80-09-1, Repr. 1B) Phenolphthalein (CAS 77-09-8, Carc. 1B) Tetrabromobisphenol-A (TBBPA, CAS 79-94-7, Carc. 1B) Indicates that bisphenol F (BPF, 4,4’-methylenediphenol, CAS 620-92-8) is planned for listing as a Repr 1B substance Clarifies that all bisphenols and bisphenol derivatives used in the manufacture of FCMs, including those that are defined as hazardous, must be listed in the declaration of compliance (DoC) to meet Article 4
Compliance and testing	Details how economic operators may demonstrate compliance with the use of BPA, other bisphenols and bisphenol derivatives, as well as the issuance of DoCs
Placing on the markets	Emphasizes that all imported FCMs from third countries, including those that are not yet in contact with food as well as articles already in contact with food, are subject to the same rules for placing on the Union market
Transitional provisions	Addresses the transitional provisions for single-use and repeat-use final food contact articles, as well as a helpful table outlining their transitional periods/application dates

Table 1

Stakeholders are encouraged to refer to the Regulation and guideline for additional details.

We help manufacturers and suppliers of food contact materials (FCM) achieve compliance with markets worldwide while supporting sustainability and market growth through product certification. Our experts offer extensive experience in testing materials and articles for multiple markets, ensuring they meet regulatory and environmental standards.

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