Core Transition Period of the Bisphenol A Ban Has Ended

On July 20, 2026, the core transition period of EU Regulation 2024/3190 expired. From that day onward, single-use food-contact articles produced with bisphenol A (BPA) can no longer be placed on the EU market.

Many factories react to this news with "it's none of our business"—we don't make PC baby bottles, and we don't do metal can interior coatings. But the scope of this ban is broader than one might imagine: coatings, inks, adhesives, sealing rings, and even residues in recycled materials are all covered. This article will discuss the BPA ban from four aspects: where the ban stands now, how the impact is layered, what factories can do, and what customers ask most often.

I. Where the Ban Stands Now: Five Key Dates

2024-12-31: The regulation was published, entering into force on 2025-01-20. BPA and its salts, other harmful bisphenols and their derivatives are banned from use in food-contact materials.

2026-07-20: The core transition period ends; single-use food-contact articles may no longer be placed on the market.

2027-07-20: Filling and sealing of non-compliant single-use packaging must cease (extended categories: 2029-01-20). This point is most easily overlooked, because it binds "those who use packaging," not just "those who sell packaging."

2028-01-20: The transition period ends for fruit and vegetable and fishery product packaging, articles with bisphenol coatings only on external metal surfaces, and reusable professional production equipment.

2029-01-20: Reusable articles already placed on the market before July 20, 2026, may continue to be sold.

II. The Impact Has Four Layers: Raw Materials, Processes, Documentation, Recycled Materials

Layer 1 | Raw materials: More than just PC

Seven categories of materials are regulated: plastics, varnishes and coatings, printing inks, adhesives, rubber, silicone, and ion-exchange resins. In concrete products, this means metal can interior coatings, bottle cap sealing rings, adhesive layers in paper-plastic composite bags, some inks, and PC chocolate molds and water dispenser components. Many packages that "look like paper or metal" have problems precisely in their coatings and adhesives.

Layer 2 | Processes: A new name doesn't necessarily let you off the hook

The first reaction is often to switch to BPS or BPF. But the regulation restricts the entire class of "harmful bisphenols and their derivatives"; simply changing the molecule's name may not circumvent it. Moreover, substitutes such as BPS and BPF are themselves being reassessed by the scientific community and regulators.

Another complication is sensitivity. EFSA has lowered the tolerable daily intake for BPA to 0.2 ng/kg body weight—about 12 ng per day for an adult. What does that mean? If BPA residue in ketchup is 1 µg/kg, at this limit, consuming about 12 grams a day would reach the ceiling. That is why the industry now pushes detection to a limit of quantification (LC-MS/MS) of 1 µg/kg.

Layer 3 | Documentation: DoC and component lists

The regulation requires companies to identify all bisphenol derivatives in their products, conduct compliance testing, and issue a Declaration of Conformity (DoC). This layer is the most time-consuming: you must clarify the source of every component, not just show that the final product "tests compliant."

In practice, what customers really ask for is three things: a component list (what is used for the film, adhesive, ink, and coating respectively), the declaration or test basis for each item, and a DoC you can sign. If any one is missing, procurement will not dare put your packaging into a food line—because when problems arise, the responsibility lies with the brand owner, not the supplier.

Layer 4 | Recycled materials: A new threshold for PCR

PCR recycled materials have been a selling point in recent years, but food-grade recycled plastics are more sensitive to bisphenol residues: recycled materials of unknown origin may carry old PC articles or coating debris. The EU already requires food-grade recycled plastics to have controllable sources and validated decontamination processes. With the bisphenol ban layered on top, the "recycled content + food contact" line must now look at more than just the percentage—it requires evidence of source and process.

Simply put: previously customers asked "how much recycled content," now they also ask "where did this batch of recycled material come from, how was it decontaminated, and has it been screened for bisphenols."

In the past, checking heavy metals and plasticizers was enough; now bisphenols must be listed as a separate screening item. One more test item means a slight increase in lead time and cost, so it's best to factor this into quotations rather than discovering the gap only after a customer asks.

III. Three Questions Customers Ask Most Often

1. We don't export food packaging—are we still regulated?

Look at the use, not the product name. As long as it is expected to contact food—including tableware, kitchen utensils, beverage equipment, and takeout packaging—it is in scope. Conversely, industrial packaging and electronics packaging are not covered; don't apply a blanket rule.

2. The core transition period has passed, so why are customers still asking?

Because two more deadlines remain: the cessation of filling and sealing on 2027-07-20, and the expiry of categories such as fruit, vegetable, and fishery packaging on 2028-01-20. Customers' goods in transit and old-version packaging inventories still need to be handled; what they ask is often "what do we do with the rest," not "what is the new regulation."

3. Is the US market the same?

No. The US FDA still permits BPA in some food-contact materials, banning it only for baby bottles, sippy cups, and infant formula can interior coatings; in addition, more than a dozen states have their own restrictions. For the same packaging exported to the EU and the US, documentation must be prepared separately—one set of reports cannot be used universally.