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Extremely strict! EU Bisphenol Ban 2024/3190 Compliance Interpretation, covering all types of food contact materials and products

Time：

2026-03-24

The EU Bisphenol Ban 2024/3190 requires food contact materials within the scope of control to undergo testing for the content or migration of bisphenol substances, all of which must meet a strict detection limit of 1 μ g/kg. The ban covers almost all food contact materials and products made of organic materials such as plastics, adhesives, rubber, ion exchange resins, printing inks, silicone, varnish, and coatings. The entire chain from raw materials, intermediate products to finished products is constrained, posing unprecedented compliance challenges for food contact material companies exporting to Europe.

History of the EU Bisphenol Ban

1. (EU) 2024/3190 ban issued

On December 31, 2024, the European Union officially issued a ban on bisphenol A and related hazardous substances (EU) 2024/3190, further strengthening the management of the use of bisphenol A and related substances in food contact materials or products. This ban amends (EU) Regulation No. 10/2011 and abolishes (EU) Regulation 2018/213.

2. Ban Implementation Guidelines Released

On December 17, 2025, the Official Journal of the European Union published the implementation guidelines document (C/2025/6721) for the ban on bisphenol and its derivatives in food contact materials (EU) 2024/3190.

3. Ban Amendment (EU) 2026/250

On February 2, 2026, the European Union issued Regulation (EU) 2026/250, revising the EU ban on bisphenol A (EU) 2024/3190. The revised regulations will come into effect on February 23, 2026.

This article will interpret the core issues of the EU ban on bisphenol A, including the scope of application, definition of restricted substances, compliance requirements, market launch, and transition period, in conjunction with the aforementioned regulatory documents.

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EU Bisphenol Ban Requirement

（1） Main content
1. Prohibit the use of BPA and its salts to manufacture adhesives, rubber, ion exchange resins, plastics, printing inks, silicone, as well as varnishes and coatings for food contact materials, and prohibit the placement of BPA made food contact materials and items on the EU market.

2. As an exemption, BPA and its salts can be used to manufacture food contact materials and articles for specific purposes, but must meet the following specific requirements:

FCM substance number	CAS number	Substance Name	Material Type	Specific Application	Other Restrictions
151	80-50-7	Dihydroxydiphenylpropane (Bisphenol A, BPA)	Clearcoat and coating	Used as a monomer or starting material for manufacturing liquid epoxy resin, for self-supporting food contact materials or items with a capacity greater than 1000 liters	Migration cannot be detected. Items that come into contact with food for the first time should be cleaned and rinsed.
151	80-50-7	Dihydroxydiphenylpropane (Bisphenol A, BPA)	plastic	Used as a monomer or starting material for manufacturing polysulfone filtration membrane components.	Migration cannot be detected. Items that come into contact with food for the first time should be cleaned and rinsed.

3. It is prohibited to use other bisphenol or bisphenol derivatives other than BPA for the manufacture and sale of food contact materials and items, unless authorized, and BPA residues are not allowed.

（2） Scope of application

1. Scope of application

Adhesives, rubber, ion exchange resins, plastics, printing inks, silicone, as well as varnishes and coatings used in contact with food are subject to the BPA ban.

Both raw materials, intermediate products, and final products are subject to the BPA ban.

If the external components of food contact materials and products may indirectly come into contact with food during normal use, or harmful substances may migrate into food during use, they must also comply with the requirements of the BPA ban.

2. Not applicable scope

Food contact paper and cardboard, recycled materials, enamel products, and pet food contact materials and products are not within the scope of the BPA ban.

Fixed pipelines permanently connected to large containers (with a capacity exceeding 1000 liters) (excluding pipelines with larger S/V and small pipelines) are not within the scope of the bisphenol ban.

（3） Controlled Bisphenol Substances

1. Prohibit the use of bisphenol A and its salts in food contact materials.

2. Prohibit the use of hazardous bisphenols or their derivatives classified as CMR 1A, 1B or ED 1 according to the EU (EC) No 1272/2008 CLP regulation. The following table is a clear list of prohibited bisphenol substances in the guidelines.

Substance Name	CAS No.	(EC) 1272/2008 Appendix VI Table 3 Unified Classification
bisphenol A	80-05-7	Repr.1B
bisphenol-s	80-09-1	Repr.1B
4,4- (1,3-dimethylbutyl) diphenyl	6807-17-6	Repr.1B
phenolphthalein	77-09-8	Carc. 1B
bisphenol AF	1478-61-1	Repr.1B
Tetrabromobisphenol A	79-94-7	Carc. 1B

Note: In the future, if other bisphenol substances are added to CLP's CMR 1A, 1B or ED 1 class of harmful bisphenol or their derivatives, they will also be automatically included in the prohibited scope.

3. Partial use of bisphenol A derivatives (such as bisphenol A diglycidyl ether BADGE, CAS No. 1675-54-3) is allowed, but food contact materials and products manufactured from them must ensure no BPA residues.

（4） Transition period

1. Disposable plastic products:

Before July 20, 2026, disposable food contact end products that comply with the original regulations before taking effect can be put on the market for the first time.

Before January 20, 2028: The following three types of products can be put on the market for the first time:

A) Used for storing fruits and vegetables (excluding juice, etc.);

B) Used for storing and processing fish products;

C) Metal products with clear varnish or coating on the outer surface.

Inventory handling: After the transition period ends, disposable products that have been released can be filled and sealed with food within 12 months, and finished products can be sold until inventory is cleared.

2. Reusable food contact products:

For reusable food contact material products first released before July 20, 2026, they can be circulated in the market until July 20, 2027; For reusable food contact material products used in food production equipment that were first released before January 20, 2028, the circulation period is until January 20, 2029.

（5） Compliance requirements and declaration of conformity

1. If other permitted bisphenol and bisphenol derivatives (such as BADGE) are used in the production process, a bisphenol A content test (detection limit: 1ug/kg) should be conducted.

2. Products exempted from Appendix II of the ban should undergo bisphenol A migration testing (detection limit: 1ug/kg).

3. According to Article 8 of the ban, all food contact materials (including multi material products) that are subject to regulatory control must issue and transmit a Declaration of Conformity (DoC); At the same time, it is possible to confirm whether bisphenol A or bisphenol substances have been used based on the raw material information transmitted by the supply chain. Although there is no mandatory requirement for materials and products to undergo testing in regulations, testing is the most effective compliance verification method to prove the absence of BPA and its derivatives residues in materials or products.

（6） Market placement

1. Export requirements: Food contact materials or products exported from the EU to third countries are generally not subject to this ban, but still need to have complete traceability documents, including clear destination labeling, so that member states can verify these materials and confirm whether they have been transferred and placed on the EU market.

2. Import requirements: Regardless of the place of origin, materials and products entering the EU market must comply with the BPA ban requirements, and the importer is responsible for compliance verification.

Introduction to Bisphenol A

Bisphenol A (BPA, CAS No. 80-05-7) is an industrial chemical widely used in food contact materials and products. Mainly used as an intermediate in the production of various polymer materials such as polycarbonate, epoxy resin, polysulfone resin, polyphenylene ether resin, unsaturated polyester resin, etc. Bisphenol A is widely used as an additive in adhesives, ion exchange resins, printing inks, rubber, varnishes, and silicone products. Meanwhile, Bisphenol A diglycidyl ether (BADGE) is a synthetic chemical based on BPA and epichlorohydrin, often used as an adhesive for epoxy resins. In addition, bisphenol A is also present in paper products such as thermal paper, commonly used in supermarket shopping receipts, takeaway documents, movie ticket stubs, etc.

Research has shown that BPA has a structure similar to estrogen and can enter the human body through dietary intake, skin contact, air inhalation, and other means, disrupting hormone balance and affecting reproductive and nervous system development. Sensitive populations such as infants, pregnant women, and adolescents are at higher risk, and exposure may pose a health hazard. In addition to the EU ban on bisphenol A, countries such as the United States, China, South Korea, and Japan have restrictions on the use of BPA in food contact materials and products, especially in infant and toddler products. A comprehensive ban on the use of BPA has become a global consensus.

Compliance recommendations

The EU ban on bisphenol A specifies the scope of application, controlled substances, compliance requirements, and declaration of conformity, emphasizing that the detection limit of 1 μ g/kg applies to both content and migration. It is recommended that production enterprises related to food contact products immediately initiate a full supply chain investigation, contact Jiayu for testing the content and migration of bisphenol substances and their derivatives, fully utilize the transition period, complete product adjustments and upgrades, and ensure that the products comply with the EU bisphenol ban requirements.

As a professional third-party testing and certification service organization, Jiayu Testing has qualifications such as CMA, CNAS, CCC, CPSC, and has obtained laboratory accreditation from multiple authoritative certification agencies at home and abroad. The laboratory is strictly built and managed in accordance with standards, equipped with advanced instruments and equipment, and has a skilled professional technical team. Jiayu Testing has rich industry service experience and strong testing technology capabilities, proficient in various regulatory standards. Jiayu Testing has rich project experience in the field of hazardous substance control and can provide customers with testing for the content and migration of bisphenol substances with a detection limit of 1 μ g/kg, assisting enterprises in actively responding to regulatory requirements, helping them achieve hazardous substance risk control, and effectively improving product compliance. Welcome to contact us at 400-9269-886!