EU Bans BPA in Plastics, Varnishes, Coatings and Other Materials

Effective January 20, 2025, the use of 4,4’-isopropylidenediphenol (more commonly known as bisphenol A or BPA) and its salts shall be prohibited in the manufacture of materials that are intended to be marketed in the European Union, including:

• Food-contact plastics
• Varnishes and coatings
• Printing inks
• Adhesives
• Ion-exchange resins
• Silicones
• Rubber

This effectively removes BPA and its salts from Annex I of the EU’s Plastic FCM Regulation (Regulation (EU) 10/2011), which lists the substances authorized to be intentionally used in the manufacture of plastic layers in plastic FCM. Exceptions to this ban are specified in Annex II of the Regulation.

The following transitional provisions are established:

• Single-use final FCM that are manufactured using BPA and comply with the rules as applicable before this ban is implemented may be placed on the market until July 20, 2026.
• Single-use FCM manufactured with BPA that do NOT comply with the rules in this regulation may be placed on the market until January 20, 2028, if:
  • They are intended for the preservation of fruits or vegetables (except if listed in Annex I of Directive 2001/112/EC) and fishery products.
  • They are single-use FCM on which a varnish or coating manufactured using BPA has only been applied to the exterior metal surface.
• Repeat-use final food contact articles that are manufactured using BPA and comply with the rules as applicable before the date of entry into force of this Regulation, which do not comply with the rules in this Regulation, may be first placed on the market until July 20, 2026.
• Repeat-use final food contact articles used as professional food production equipment, complying with the rules as applicable before the date of entry into force of this Regulation, which do not comply with the rules in this Regulation, may be first placed on the market until January 20, 2028.

The new Regulation also establishes that FCM shall be accompanied at all stages of marketing (other than retail sale) by a written declaration containing specific information (as detailed in Annex III).