Bisphenol A (BPA) is a chemical used to manufacture some plastics and resins. Although it has been used in food packaging for decades, BPA has been under renewed scrutiny in recent years due to gaps in older scientific studies. In April 2023, the European Food Safety Authority (EFSA) published a new evaluation of BPA’s safety, significantly reducing the tolerable daily intake set in its previous assessment.1
Following EFSA's new evaluation, a ban on bisphenol A in food contact materials was introduced by Commission Regulation (EU) 2024/3190, which entered into force in January 2025.2 Additional EU regulations prohibit the use of bisphenol A in some cases and limit its migration from materials in others. Compliance with these limitations can be verified through laboratory testing.
What is bisphenol A?
Bisphenols are a large family of chemical compounds. BPA is a widely used member of the group and is manufactured on an industrial scale by the condensation reaction of phenol and acetone. Today BPA is primarily used as a starting material to produce polycarbonate plastics and epoxy resins. Previously it was used in thermal paper, such as for sales slips, parking tickets, and parcel labels, before being banned in January 2020.3
Health concerns related to bisphenol A migration
According to the EU’s harmonized classification and labeling regime, BPA in its pure form may damage fertility, is very toxic to aquatic life with long-lasting effects, causes serious eye damage, and may cause allergic skin reactions and respiratory irritation.4 The primary source of exposure to bisphenol A for most people is through the diet, as BPA can leach into food and drinks from polycarbonate bottles and internal epoxy resin coatings of cans and containers.
On 8 July 2021, bisphenol A was included on the REACH Candidate List of substances of very high concern (SVHC) due to its endocrine-disrupting properties for human health and adverse effects on the environment.5
In April 2023, EFSA published a re-evaluation of BPA’s safety based on new scientific data and research. This re-evaluation set a tolerable daily intake (TDI) of 0.2 nanograms per kilogram of body weight per day, which is significantly lower than the old level of 4 micrograms per kilogram of body weight per day.6
BPA in food contact materials
Commission Regulation (EU) 2024/3190 bans the use of bisphenol A in food contact materials and articles, apart from two exemptions specified in Annex II to the regulation. The exemptions apply to use as a monomer or starting substance in polysulfone filtration membranes and liquid epoxy resins that are used as heavy-duty varnishes and coatings. Even in these cases, there must not be detectable migration of BPA into food.
The regulation also prohibits using other hazardous bisphenols and bisphenol derivatives in most cases. When they are used (subject to the restrictions specified in Articles 5 and 6), the final food contact article must not contain residual bisphenol A.
As the regulation outlines some transitional provisions, certain single-use and repeat-use food contact articles manufactured using BPA can still be placed on the market until July 2026 or January 2028, depending on the product. These products must comply with pre-existing rules, such as the 0.05 mg/kg specific migration limit given for BPA in Regulation (EU) No 10/2011 on plastic food contact materials.
To verify compliance with the ban, companies that produce materials where BPA might be present need to have their products tested. The test method used to show that the material does not contain bisphenol A or release it into food must have a detection limit of 1 μg/kg.7
In addition to materials that have been produced using bisphenols, materials that contain recycled fibers require testing due to the increased risk of contamination. This is acknowledged by the German Federal Institute for Risk Assessment (BfR), which mandates bisphenol A and bisphenol S testing for recycled paper and board food contact materials with a migration limit of 0.05 mg/kg.8
Rules for materials in contact with water
According to the updated Drinking Water Directive (EU) 2020/2184, bisphenol A can be used as a starting substance or additive in plastic materials that come into contact with drinking water, but its concentration at the tap must not exceed 2.5 μg/l.9 Such materials must be tested to ensure that they do not cause BPA to migrate into water in higher concentrations.
Limits on BPA in toys and cosmetics
The Toy Safety Directive 2009/48/EC sets a strict limit of 0.04 mg/l for bisphenol A migration from toys intended for children under the age of three or intended to be placed in the mouth. Migration is to be measured by the EN 71-10 and EN 71-11 harmonized standards.10
Bisphenol A is also listed as a prohibited substance for cosmetics in the EU Cosmetics Regulation (EC) No 1223/2009.11 For cosmetic products to be marketed in the EU, they must undergo a safety assessment that includes information on possible traces of BPA and other prohibited substances.
Bisphenol A analysis by EU regulations
Compliance testing relating to the aforementioned restrictions can be performed using liquid chromatography-mass spectrometry (LC-MS). Measurlabs’ epoxy derivative and bisphenol test package for food contact materials includes bisphenol A and other related substances that restrictions apply to.
In addition to FCMs, we offer BPA testing options for environmental samples, cosmetics, toys, consumer products, and various other sample materials. You can read more about bisphenol A content determination here or request a quote from our experts through the form below.
References:
1 EFSA: Bisphenol A in food is a health risk
2 Commission Regulation (EU) 2024/3190 on the use of bisphenol A (BPA) and other bisphenols and bisphenol derivatives
3 Bisphenol A in everyday products: Answers to frequently asked questions by the German Federal Institute for Risk Assessment (BfR)
5 The ECHA Candidate List of substances of very high concern for Authorisation
6 Note that the European Medicines Agency (EMA) disagrees with the new TDI, and work to rectify the opinions of EFSA and EMA is ongoing.
7 Requirements for compliance testing are outlined in Article 9 of Regulation (EU) 2024/3190. A method developed by the European Union Reference Laboratory (EURL) for food contact materials shall be used once available.
8 Testing requirements for recycled paper and board are outlined in the Annex to BfR recommendation XXXVI.
9 The chemical parameters are detailed in Annex I, Part B, of Directive (EU) 2020/2184. Article 25 of Directive (EU) 2020/2184 says the Member States must have the necessary measures in place to ensure water intended for human consumption meets the new parametric values by 12 January 2026.
10 See Appendix C of the consolidated version of the Toy Safety Directive.
11 Annex II of Regulation (EC) No 1223/2009 includes the list of substances prohibited in cosmetic products. Bisphenol A is found under reference number 1176.