EU published guidance on BPA in food contact articles

Vol. 1517 | 22 Jan 2026

EU guidance for Regulation 2024/3190 details BPA bans across food contact materials, restrictions on hazardous bisphenol substitutes, DoC requirements, 1 μg/kg detection limits, and material-specific transition periods for compliance demonstration.

The European Commission published a Note for Guidance on the implementation of Commission Regulation (EU) 2024/3190 on the use of bisphenol A (BPA) and other bisphenols and bisphenol derivatives in certain food contact materials and articles.

The contents of the guidance include:

1. Scope
2. Other bisphenols and bisphenol derivatives
3. Compliance and testing
4. Placing on the market
5. Transitional provisions

Key highlights of the guidance

Scope and Broad Application

The guidance clarifies that the ban is not limited to plastic. It covers a wide array of materials intended to come into contact with food.

Crucially, the guidance emphasizes that the regulation applies to both the intentional use of BPA in the manufacturing process and its presence as a "non-intentionally added substance" if it results from the use of other bisphenol derivatives.

The Ban on "Other Bisphenols"

A significant feature of Regulation 2024/3190 is its proactive approach to substitution. To prevent industry from simply replacing BPA with similar harmful chemicals, the guidance details restrictions on other bisphenols and their derivatives that have a harmonized classification as:

• Category 1A or 1B Carcinogenic, Mutagenic, or Reprotoxic (CMR).
• Endocrine Disruptors (Category 1) for human health.

The guidance provides clarity on how manufacturers must assess their chemical portfolios to ensure substitutes do not fall into these prohibited categories.

Declaration of Compliance (DoC) Requirements

To ensure safety throughout the supply chain, the guidance highlights new requirements for the Declaration of Compliance. Business operators must explicitly state that their materials comply with the BPA ban.

Compliance and testing

The guidance clarifies that laboratory testing is not always mandatory. Compliance can be demonstrated in supporting documentation or analytical testing. The guidance confirms that a detection limit of 1 μg/kg (1 ppb) is generally considered feasible and practical. The non-detectable requirement applies differently depending on the material are specified.

Transition Periods

One of the most vital sections for business operators is the timeline for compliance. The guidance breaks down different transitional periods, depend on the food contact articles type.

For the full technical details, stakeholders are encouraged to read the official Note for Guidance 2025/C 6721.

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