Background

The European Union has released an extensive Note for Guidance supporting the implementation of Commission Regulation (EU) 2024/3190, which restricts the use of bisphenol A (BPA) and other hazardous bisphenols in food‑contact materials (FCMs). Published in the Official Journal of the European Union on 17 December 2025, the guidance aims to ensure consistent compliance across industries as the ban progresses toward full applicability in 2026.

Scope & Key Provisions

The guidance clarifies the scope of the regulation, reaffirming coverage of materials where BPA may be used as a monomer or in coatings—such as plastics, epoxy varnishes and coatings, printing inks, adhesives, silicones, rubber, and ion‑exchange resins. 

Although paper and board are not directly included in the ban, combination materials—such as printed or coated paper—fall within the scope when they incorporate regulated components.  The guidance further confirms that recycled FCMs are excluded when BPA or other bisphenols appear only as incidental, unavoidable contaminants in recycled inputs such as plastic or paper fibers.

Beyond BPA, the regulation bans several bisphenols and bisphenol derivatives classified as carcinogenic, mutagenic, toxic to reproduction, or endocrine‑disrupting under EU chemical safety rules, as shown below:

How SGS can help?

With the transition period ending 20 July 2026, businesses that manufacture or rely on food‑contact materials—including packaging for food, pharmaceuticals, cosmetics, and various consumer goods—must rapidly transition away from bisphenol‑based components that may come into direct or indirect contact with consumable products. 

Additional Information: