Türkiye Consults on BPA and other Bisphenols in Food Contact Materials

SG 056/26

Türkiye notifies the World Trade Organization (WTO) of its draft regulations on bisphenol A (BPA) and other hazardous bisphenols and bisphenol derivatives in certain food contact materials (FCMs) and articles.

On April 8, 2026, the WTO announced two draft communiqués from Türkiye’s Ministry of Agriculture and Forestry (T.C. Tarım ve Orman Bakanlığı) on FCMs and articles:

• Turkish Food Codex Draft Communiqué on the ‘Restriction of the Use of Bisphenol A, other Hazardous Bisphenols and Bisphenol Derivatives in Certain Substances and Materials in Contact with Food’ (Draft Communiqué 1, WTO document number 26-2758), a communication largely harmonized with European Regulation (EU) 2024/3190 (SafeGuardS 19/26 and references therein)
• Draft Communiqué on ‘Amendments to the Turkish Food Codex Communiqué on Plastic Substances and Materials in Contact with Food’ (Draft Communiqué 2, WTO document number 2754), a document complementing the requirements in Draft Communiqué 1

What do these draft communiqués require?

Key provisions in Draft Communiqué 1 include:

• Establishing specific rules governing BPA, its salts and other hazardous bisphenols and hazardous bisphenol derivatives in the manufacture of seven categories of materials: i) adhesives, ii) ion-exchange resins, iii) plastics, iv) printing inks, v) rubber, vi) silicones and vii) varnishes and coatings
• Establishing specific requirements for BPA content in FCMs that have been produced using another bisphenol or bisphenol derivative
• Introducing several terms and their definitions, including ‘bisphenol’, ‘bisphenol derivative’ and ‘hazardous bisphenol or hazardous bisphenol derivative’
• Prohibiting BPA in the manufacture of FCMs and articles other than the specified applications in Annex 2 (see Table 1 below)
• Prohibiting residual BPA if another bisphenol or bisphenol derivative is used in the manufacture of FCMs and articles
• Prohibiting the use of hazardous bisphenols other than BPA or hazardous bisphenol derivatives in the manufacture of FCMs and articles and the placing on the market of such products, unless the specific application is specified in Annex 2 or an application for authorization has been made
• Mandating economic operators using BPA, other hazardous bisphenols or hazardous bisphenol derivatives listed in Annex 2 (see Table 1 below) to provide the General Directorate with information on the status of alternative substances
• Authorizing economic operators to provide a written declaration of conformity (DoC) and supporting documents at all marketing stages other than the retail stage for FCMs and articles that are not yet in contact with food
• Requiring the use of specified methods in Article 12 of the Regulation on Official Controls of Food and Feed for verification of compliance with the requirements of this communiqué
• Specifying additional rules for the selection of methods used to verify that a FCM or article does not contain residual BPA, other hazardous bisphenol or a bisphenol derivative, or does not release these substances into food above the specified detection limit (DL) or specific migration limit (SML). These include, but are not limited to, a DL of 1 µg/kg for the method, unless a different DL has been defined under Annex 2
• Indicating the use of the Turkish Food Codex Communiqué on food contact plastics (Communiqué No 2019/44) and the Turkish Food Codex Communiqué on the list of food simulants used in migration testing of food contact plastics (Communiqué No. 2019/43) for compliance with migration limits
• Setting transitional provisions for single-use and repeat-use final food contact materials

Table 1. Annex 2 to Draft Communiqué 1

Key provisions in Draft Communiqué 2 include:

• Adding new language to reflect the use of BPA, other hazardous bisphenols and bisphenol derivatives as described in Draft Communiqué 1.
• Updating the Turkish Food Codex Communiqué on food contact plastics (Communiqué No 2019/44) by deleting the entry for BPA (Number 151 to Annex 1 of Table 1)

Who is impacted?

The draft communiqués would affect stakeholders operating across the food contact material and article supply chain, including manufacturers, importers, distributors and retailers.

When do they apply?

The two draft communiqués are intended to enter into force on the day of their publication in the nation’s official gazette.

According to WTO document number 26-2758, Draft Communiqué 1 is intended to enter into force on July 10, 2026.

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