EU BPA and Derivatives Ban (EU) 2024/3190 Implementation Guide Officially Released

On December 17, 2025, the European Commission officially published the guidance document (C/2025/6721) for the implementation of Commission Regulation (EU) 2024/3190 concerning the ban on bisphenol A and related bisphenols of specific hazard classification and their derivatives in food contact materials. This implementation guide details the scope of the ban, controlled substances, testing requirements, and the relevant transitional period.

Background:
Bisphenol A (BPA, CAS No. 80-05-7) is an industrial chemical widely used in the manufacture of food contact materials and articles. It is a monomer or starting substance for synthesizing polycarbonate, polysulfones, and epoxy resins. Epoxy resins are primarily used for the internal and external coatings of metal packaging (e.g., cans, lids). Additionally, BPA is widely used as an additive in adhesives, ion-exchange resins, printing inks, rubber, varnishes, and silicone products.

Since its publication, the food contact plastic regulation (EU) 10/2011 has undergone multiple amendments. These include several revisions concerning the use of BPA in food contact materials and articles, such as (EU) 321/2011 prohibiting BPA in polycarbonate (PC) infant feeding bottles and (EU) 2018/213, which extended the BPA ban to PC drinking cups and bottles for young children. Beyond the EU, regions including the United States, China, South Korea, and Japan also have relevant restriction requirements for BPA in food contact materials and articles, with a comprehensive ban on BPA in infant and young children's products becoming a global consensus.

Scope of Application

● The BPA ban applies to raw materials, intermediate products, and final products.
● If external parts of food contact materials and articles may indirectly contact food during normal use, or if hazardous substances can migrate into food during use, they must also comply with the BPA ban requirements.
● Pipes permanently connected to large containers (capacity exceeding 1000 liters) are exempt. However, pipes with a large surface-to-volume ratio (S/V) and small pipes are not exempt.

Areas not within the scope of the BPA ban:
It is clarified that food contact paper and board, recycled materials, enameled ware, and materials and articles intended for contact with pet food are not within the scope of the BPA ban.

Controlled Substances
Bisphenol A and its salts shall not be used in food contact materials and articles. Food contact materials and articles containing bisphenol A diglycidyl ether (hereinafter ‘BADGE’) (CAS No 1675-54-3) shall not contain any residues of bisphenol A.

The bisphenols or bisphenol derivatives explicitly prohibited are those listed in Part 3 of Annex VI to Regulation (EC) 1272/2008. Currently, this includes the following five: 

Furthermore, on September 17, 2024, ECHA published an opinion proposing a harmonized classification for bisphenol F (CAS No: 620-92-8) (Repro. 1B).

In the future, other bisphenols or bisphenol derivatives classified in Part 3 of Annex VI to (EC) 1272/2008 in category 1A or 1B for "mutagenicity", "carcinogenicity", "reproductive toxicity" (CMR) or category 1 for "endocrine disruptors" (ED) will also be prohibited by (EU) 2024/3190 (unless exempted).

Declaration of Compliance
All food contact materials and articles falling under the BPA ban must be accompanied by a declaration of compliance, regardless of whether BPA is used. Operators at all stages (except the retail stage) must draw up and transmit the declaration of compliance.

Transitional Period
Single-use and reusable food contact products complying with the previous legislation may continue to be placed on the market until July 20, 2026.

The following two types of products may continue to be placed on the market until January 20, 2028:

1. Single-use products intended for preserving fruits, vegetables (excluding juices, etc.), and fishery products, and varnishes and coatings for external metal surfaces; professional reusable food production equipment.
2. Single-use food contact products already placed on the market may be used to contain and seal food and sold until stocks are exhausted within 12 months after the end of the transitional period.

Professional reusable food production equipment must not be placed on the market after January 20, 2029.