EU BPA Ban In Food Contact Materials: Regulation (EU) 2024/3190 Explained

What Manufacturers, Importers, Food Businesses and Packaging Companies Need to Know in 2026

Since 20 January 2025, the European Union has applied new restrictions on Bisphenol A (BPA) and certain other hazardous bisphenols and bisphenol derivatives used in materials and articles intended to meet food.

The rules are established by Commission Regulation (EU) 2024/3190, adopted on 19 December 2024 and published in the Official Journal on 31 December 2024. The Regulation prohibits the use of BPA in the manufacture of specified food-contact materials and restricts their placing on the EU market.

The change is significant because BPA was historically used in applications such as plastic materials, coatings and varnishes, can linings, adhesives, printing inks, silicones and other food-contact components.

However, the headline "BPA ban" needs an important clarification: the Regulation contains specific exemptions and transitional periods, so not every existing food-contact article became illegal for sale on 20 January 2025. Companies must assess their products against the relevant provisions and deadlines.

For businesses operating in the European food-contact materials sector, this means that BPA substitution, supplier control, testing, documentation, compliance declarations and transition planning are now critical.

Why the EU Restricted BPA

BPA has been used for decades in materials that can encounter food and beverages. Its applications have included plastics and protective coatings, particularly where durability, strength and resistance were required.

Regulatory concern increased because scientific and regulatory assessments identified potential effects associated with BPA exposure, including concerns relating to reproductive, developmental, immune and endocrine systems.

The EU's approach is based on the broader food-contact safety principle that materials should not release constituents into food at levels that could harm human health. Regulation (EC) No 1935/2004 establishes this general framework for food-contact materials.

The new BPA Regulation therefore forms part of a wider EU strategy to reduce exposure to substances presenting significant health concerns.

What Regulation (EU) 2024/3190 Does

Regulation (EU) 2024/3190 goes beyond a simple prohibition of BPA.

Its address is:

• Bisphenol A
• BPA salts
• Certain other hazardous bisphenols
• Certain hazardous bisphenol derivatives
• Food-contact plastics
• Vanishes and coatings
• Printing inks
• Adhesives
• Iron-exchange resins
• Silicones
• Rubber
• Other relevant food-contact applications

The European Commission's implementation guidance confirms that the Regulation is not limited to plastic packaging and can apply across different types of food-contact materials.

This is particularly important for manufacturers that may not intentionally add BPA but could have BPA present through raw materials, recycled materials, coatings, adhesives or other components.

Where BPA Has Traditionally Been Used

BPA has historically appeared in a wide range of food-contact applications.

Examples include:

• Metal food cans
• Beverage cans
• Protective internal coatings
• Plastic food containers
• Reusable food-contact plastics
• Adhesive systems
• Printing inks
• Coatings and varnishes
• Certain rubber and silicone materials
• Food-processing equipment components

The regulation therefore requires businesses to look beyond the visible packaging material.

A food-contact article may appear to be "BPA-free" while BPA could potentially be associated with coating, ink, adhesive or another component.

What Is Covered by the EU BPA Rules?

The European Commission confirms that food-contact materials are governed by both general framework requirements and material-specific legislation, including rules for plastics, recycled plastics and other materials.

BPA Ban: Important Transition Periods

The Regulation entered into force on 20 January 2025, but companies were given transition periods for certain products and applications.

This distinction is important:

Entry into force ≠ immediate removal of every existing product from the market.

The Regulation includes different deadlines depending on the type of food-contact article. The European Commission's guidance explains that transitional provisions apply to different categories, while subsequent Regulation (EU) 2026/250 corrected the original Regulation, including transitional provisions.

Key Regulatory Timeline

Businesses should therefore avoid relying on a single "BPA ban deadline" and instead identify the specific transition period applicable to each product.

The Regulation Also Targets BPA Substitution Risks

One of the most important features of the Regulation is that companies cannot simply replace BPA with another chemically similar substance without considering its regulatory status.

The EU rules also address certain other bisphenols and bisphenol derivatives with harmonized classifications for hazardous properties, including relevant CMR and endocrine-disruption classifications.

This creates an important compliance principle:

BPA substitution must be a safety and regulatory assessment, not simply a one-for-one ingredient replacement.

Manufacturers should therefore evaluate alternative substances before changing formulations or manufacturing processes.

What Companies Need to Review

Businesses should conduct a structured review of their entire food-contact portfolio.

1. Raw Materials

Identify whether BPA or relevant bisphenol derivatives are present in:

• Resins
• Coatings
• Inks
• Adhesives
• Plastics
• Rubber
• Silicone
• Other components

2. Suppliers

Obtain updated supplier information, specifications and compliance declarations.

Supplier documentation should clearly identify the material and demonstrate conformity with applicable EU requirements.

3. Finished Products

Review every food-contact article, including products where BPA may not be part of the main structural material.

4. Existing Inventory

Determine whether products manufactured before the new requirements can continue to be placed on the market under the applicable transitional provisions.

5. Future Products

Ensure new formulations and packaging designs do not introduce prohibited BPA or problematic substitutes.

Declaration of Compliance & Documentation

Food-contact compliance depends heavily on documentation.

For plastic materials, the EU framework requires a Declaration of Compliance (DoC) supported by appropriate documentation. The European Commission explains that supporting documentation should demonstrate the safety and compliance of the material and be available to enforcement authorities when requested.

The Commission's BPA implementation guidance further emphasizes that business operators must address compliance with the BPA restrictions within their documentation and declarations.

Companies should maintain:

• Supplier declarations
• Raw-material specifications
• Formulation information
• Migration test results where applicable
• Analytical reports
• Compliance statements
• Manufacturing records
• Traceability information
• Updated Declarations of Compliance

Testing and BPA Detection

Regulatory compliance may be demonstrated through appropriate documentation, analytical testing, or a combination of both, depending on the material and circumstances.

The Commission guidance discusses a 1 μg/kg detection limit as generally feasible and practical for relevant analytical assessments, while the exact compliance approach depends on the applicable material and regulatory provision.

Companies should therefore avoid if every product requires the same laboratory test.

A risk-based approach should be considered:

• Material type
• Intended food contact
• Manufacturing process
• BPA history
• Supplier evidence
• Potential migration
• Applicable regulatory limits
• Product transition status

Impact on Food & Beverage Packaging

BPA restrictions are particularly relevant to businesses’ use:

• Metal cans
• Food tins
• Beverage containers
• Plastic packaging
• Coated packaging
• Food-contact closures
• Processing equipment
• Packaging components
• Adhesives and inks

For example, a metal can may not contain BPA in its metal structure, but its internal protective coating could be relevant to the regulatory assessment.

Therefore, food manufacturers and brand owners should not limit their review to the primary packaging material.

Impact on Manufacturers and Importers

Manufacturers must ensure that products supplied to the EU comply with the applicable requirements.

Importers and distributors should also verify that suppliers provide adequate evidence of conformity.

Key responsibilities include:

• Supplier qualification
• Regulatory screening
• Material specifications
• Compliance documentation
• Product testing where necessary
• Traceability
• Change control
• Inventory review
• Correct transition management

A supplier statement alone may not be sufficient if it is outdated or does not cover the exact product and material configuration.

Practical Compliance Roadmap

Companies can use the following approach:

1. Map all food-contact products.
2. Identify all materials and components.
3. Determine whether BPA is intentionally used.
4. Check for potential BPA from coatings, inks, adhesives or other components.
5. Review of bisphenol alternatives.
6. Obtain updated supplier documentation.
7. Conduct risk-based analytical testing where necessary.
8. Review migration data.
9. Update Declarations of Compliance.
10. Assess existing inventory against transition deadlines.
11. Update specifications and purchasing requirements.
12. Implement formal change control.

Monitor EU regulatory developments.

1. Train procurement, quality and regulatory teams.

Common Compliance Mistakes

Companies should avoid:

• Assuming only plastics are affected
• Treating 20 January 2025 as the only compliance deadline
• Ignoring coatings and adhesives
• Relying on outdated supplier declarations
• Replacing BPA without assessing substitutes
• Failing to review existing inventory
• Ignoring migration considerations
• Using incomplete compliance documentation
• Failing to update the Declaration of Compliance
• Treating every food-contact material identically
• Overlooking traceability
• Waiting until a customer or authority requests evidence

What This Means for Businesses in 2026

For companies selling food-contact materials in Europe, the BPA transition is no longer a future regulatory issue.

It is an active compliance-management requirement.

Businesses should determine:

• Which products contain or previously contain BPA
• Which components require replacement
• Which transition period applies
• Whether existing inventory can remain on the market
• Whether alternative substances are legally acceptable
• Whether additional testing is necessary
• Whether supplier documentation is current
• Whether DoCs and technical files require updating

The European Commission also published implementation guidance addressing scope, other bisphenols, compliance and testing, placing on the market and transitional provisions, giving businesses additional direction on applying the Regulation.

How Maven Regulatory Solutions Can Help

Maven Regulatory Solutions can support companies with:

• EU food-contact material regulatory assessments
• BPA compliance reviews
• Bisphenol and substitute screening
• Supplier-documentation review
• Migration-risk assessment
• Testing strategy
• Declaration of Compliance support
• Technical documentation review
• Product portfolio gap assessments
• Packaging compliance
• Regulatory intelligence
• Transition planning
• Change-control strategy

A structured review can help businesses identify affected products, prioritize high-risk materials, manage transition periods and prepare evidence for customers and regulatory authorities.

Frequently Asked Questions

1. Is BPA banned in the EU?

Regulation (EU) 2024/3190 prohibits the use of BPA in specified food-contact materials and articles, subject to specific provisions and transitional arrangements.

2. When did the Regulation enter into force?

It entered into force on 20 January 2025.

3. Does the ban apply only to plastic?

No. The Regulation covers a broader range of food-contact materials and components, including relevant coatings, inks, adhesives, silicones, rubber and other applications.

4. Can existing BPA-containing products still be sold?

Certain products may benefit from transitional provisions. The applicable deadline depends on the product category and circumstances.

5. Are BPA alternatives automatically acceptable?

No. Other hazardous bisphenols and derivatives are also addressed by the Regulation. Substitution should therefore be assessed before implementation.

6. Is testing always mandatory?

Not necessarily. Compliance may be demonstrated through appropriate documentation, analytical testing, or both, depending on the applicable requirements.

7. Do companies need a Declaration of Compliance?

For applicable food-contact materials, documentation and Declarations of Compliance form an important part of the EU compliance framework.

8. What should companies do now?

Review materials, suppliers, formulations, coatings, adhesives, migration data, inventory, transition deadlines and compliance documentation.

Conclusion

The EU's BPA restrictions represent a major change for the food-contact materials and packaging industry.

Regulation (EU) 2024/3190, applicable from 20 January 2025, moves beyond earlier BPA restrictions by addressing BPA across a wider range of food-contact materials and by introducing controls on certain hazardous bisphenol alternatives.

The key message for manufacturers, importers and food businesses is simple:

BPA compliance is not only about replacing one chemical. It requires a complete review of materials, suppliers, coatings, adhesives, testing, documentation, inventory and regulatory transition dates.

Companies that act early can reduce supply-chain disruption, avoid non-compliant materials, improve supplier control and maintain reliable access to the European market.

Why Choose Maven Regulatory Solutions?

Maven Regulatory Solutions supports businesses with food-contact material compliance, BPA and bisphenol assessments, supplier documentation, testing strategy, migration review, Declaration of Compliance support, regulatory intelligence, packaging compliance and market-readiness assessments.

Our regulatory approach helps organizations understand changing EU requirements and implement practical compliance strategies across their product and supply chain.