Guidance on the Use of Bisphenol A (BPA)

Last year, Commission Regulation (EU) 2024/3190 on the use of bisphenol A (BPA) and other bisphenols and bisphenol derivatives in materials that are intended to come into contact with food entered into force. The Regulation includes a ban on the use of BPA in certain food contact materials (FCMs), including plastic and coated packaging.

Guidelines for Implementation

In December 2025, the guidelines for the implementation of Regulation 2024/3190 have been published. They are structured in the form of a question and answer (Q&As) document and are intended to assist in the implementation of the Regulation. Q&As are provided to the following topics:

• Scope (e.g., "Is paper and board within the scope of the ban?")
• Other Bisphenols & Derivatives  (e.g., "From when is a hazardous bisphenol classified as such?")
• Compliance & Testing (e.g., "Whose responsibility is it to issue the Declaration of Compliance (DoC)?")
• Placing on the Market (e.g., "What about imported FCMs from third countries?")
• Transitional Provisions (e.g., "What about the transitional periods for imported FCMs?")

Transitional Provisions

A diagram at the end of the document provides an overview of transitional periods for FCMs within the scope of the Regulation. The table is for illustrative purposes only and does not cover every scenario for each and every business operator. It should be read in conjunction with the answers given to the preceding questions and with the Regulation 2024/3190. Meanwhile, some of the transitional provisions concerning single-use final food contact articles have been specified more in detail by Commission Regulation (EU) 2026/250 of 2 February 2026 correcting Regulation (EU) 2024/3190. "In order to allow enough time to bring the applications for these types of packaging to commercial scale and to avoid food waste, it is appropriate to allow final food contact articles using varnishes and coatings manufactured with BPA, specifically for the packaging used to preserve fruit, vegetables and processed fishery products, to be first placed on the market during a period of 36 months after the entry into force of this Regulation". 

For more information please see the 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 with harmonised Classification for specific hazardous Properties in certain Materials and Articles intended to come into Contact with Food.