EU BPA restrictions are changing food-contact packaging. Learn what manufacturers need to check for coatings, plastics, migration, suppliers and compliance.

Bisphenol A, or BPA, is no longer simply a substance to check during packaging compliance.

The EU has introduced a broad restriction on its use in food contact materials, with specific transitional rules for different applications. The current legal framework is Commission Regulation (EU) 2024/3190, as corrected by Commission Regulation (EU) 2026/250. Eur-Lex

For packaging manufacturers and food companies, this means more than replacing one material with another.

The change can affect coatings, plastics, packaging components, suppliers, migration testing and compliance documentation.

What is changing?

Regulation (EU) 2024/3190 prohibits the use of BPA in the manufacture of covered food contact materials and the placing on the EU market of food contact materials made using BPA, subject to specific derogations. It also addresses certain other hazardous bisphenols and bisphenol derivatives. Eur-Lex

The restriction applies to food contact materials and articles within the scope of the regulation, including applications such as:

food packaging
coatings and varnishes
plastics
kitchenware
food-processing equipment
other materials that can come into contact with food

The EU framework for food contact materials already requires materials to be sufficiently inert and not release substances into food at levels that could endanger health. Food Safety

BPA therefore needs to be considered as part of the wider food-contact compliance system, not as an isolated packaging issue.

Why was BPA restricted?

BPA has been used in the manufacture of certain plastics, epoxy resins and coatings.

The European Commission adopted the restriction following scientific assessment and concerns about potential harmful health effects, including effects on the immune system identified by EFSA. Food Safety

The regulation therefore takes a broader approach than simply setting a lower migration limit.

In general, the use of BPA is prohibited for covered food contact applications, with narrowly defined exceptions. Eur-Lex

That distinction matters.

“BPA migration is below the old limit” is not necessarily enough to demonstrate compliance with the new rules.

The first question is now:

Was BPA used in the manufacture of the food contact material at all?

Which packaging can be affected?

BPA can be relevant to more than obvious plastic packaging.

Potentially affected applications include:

metal cans with internal coatings
coated metal lids
plastic food-contact articles
epoxy-based coatings
reusable food-contact equipment
seals and other components
certain processing equipment

The regulation covers materials and articles that fall within the relevant food-contact framework, rather than simply products marketed as “plastic packaging.” Eur-Lex

This is why a material-by-material review is necessary.

Metal packaging deserves special attention

One common misconception is:

“The packaging is metal, so BPA is irrelevant.”

That is not necessarily true.

Metal cans and lids can use internal coatings or varnishes to protect the metal and the food.

Those coatings can therefore become relevant to BPA compliance.

The regulation specifically addresses varnishes and coatings, including certain transitional arrangements for applications where alternatives require more time to scale. Eur-Lex

So packaging compliance cannot be assessed by looking only at the main structural material.

The transition periods are not all the same

This is one of the most important practical points.

For most affected single-use final food contact articles manufactured using BPA, the original transition period ended on 20 July 2026.

However, specific exceptions have longer transition periods.

For example, certain single-use articles used to preserve:

fruit
vegetables
fishery products

may be placed on the market until 20 January 2028.

The same date applies to certain articles where a BPA-based varnish or coating is used only on the external metal surface. Eur-Lex

There are also specific transitional provisions for certain repeat-use articles used as professional food-production equipment. Eur-Lex

So there is no single universal “BPA deadline.”

The deadline depends on the type and use of the food contact article.

What does this mean for packaging already on the market?

The transitional rules distinguish between placing the food contact article on the market and subsequently filling or sealing it.

Certain affected single-use articles covered by the extended transition can be filled with food and sealed for an additional period after the relevant placing-on-the-market deadline. The resulting packaged food can then remain on the market until stocks are exhausted. Eur-Lex

This makes inventory planning important.

Manufacturers should therefore not look only at:

“When can we manufacture the packaging?”

They should also ask:

“When can it be filled, sealed and placed on the market?”

BPA-free does not automatically mean compliant

This is an important distinction.

A packaging supplier may state:

“BPA-free.”

That is useful information.

But it does not by itself demonstrate complete food-contact compliance.

The material still needs to meet the applicable requirements for:

composition
migration
intended food type
temperature
contact time
manufacturing
documentation

EU food-contact rules require materials to avoid transferring substances into food at levels that could endanger health or adversely affect the food. Food Safety

So BPA-free is one property, not a complete compliance assessment.

What about other bisphenols?

The regulation does not stop at BPA.

It also establishes restrictions for certain hazardous bisphenols and hazardous bisphenol derivatives.

In particular, food contact materials manufactured using another hazardous bisphenol or bisphenol derivative must not contain residual BPA. Eur-Lex

Some hazardous bisphenols may only be used for specific applications where authorised under the regulation.

This means replacing BPA with another bisphenol should not be treated as an automatic compliance solution.

The replacement substance needs its own regulatory assessment.

“BPA-free” can therefore be the beginning of the assessment

Imagine a manufacturer replaces a BPA-based coating with another bisphenol-based system.

The old material is gone.

The company now has a BPA-free coating.

But the next questions are:

Which substance replaced BPA?

Is its use permitted?

What are its migration characteristics?

Does the finished article meet the applicable requirements?

A substitution strategy should therefore consider the entire chemical and regulatory profile.

Migration testing still matters

Even when BPA is not intentionally used, migration testing can provide important evidence about the finished food contact article.

The EU food-contact framework uses migration limits to control the transfer of substances from materials into food. For plastics, for example, Regulation (EU) No 10/2011 establishes specific migration limits for authorised substances. Food Safety

Depending on the material and application, testing can address:

specific migration
overall migration
residual substances
relevant impurities
substances introduced during manufacturing

The exact testing programme should be based on the material and intended conditions of use.

The test conditions matter

Food-contact migration does not happen under one universal condition.

The assessment depends on factors such as:

food type
contact time
contact temperature
intended use
material
surface-to-volume ratio

For example, packaging intended for a refrigerated food is not automatically assessed under the same conditions as packaging intended for hot filling.

This is why a migration test should represent the realistic intended use.

The new BPA rules also affect documentation

A compliant packaging material needs more than a test report.

Food contact materials are subject to documentation and traceability requirements under the EU framework. Food Safety

For relevant materials, companies should be able to establish:

material identity
supplier
composition information
intended use
supporting analytical data
applicable restrictions
migration evidence
compliance documentation

A supplier declaration saying “BPA-free” is therefore only one part of the evidence package.

What should packaging manufacturers ask their suppliers?

A practical supplier questionnaire could include:

BPA status

Was BPA used anywhere in the manufacture of the material?

Other bisphenols

Are other hazardous bisphenols or derivatives used?

Composition

Which substances are intentionally used?

Manufacturing

Have raw materials, coatings or production processes changed?

Migration

What migration data are available for the intended application?

Intended use

Which foods, temperatures and contact times are covered?

Documentation

Can the supplier provide the required compliance documentation?

These questions should be answered before approving a new packaging material.

What should food manufacturers check?

Food companies should not assume that packaging compliance is entirely the supplier’s responsibility.

A practical review should include:

1. Identify packaging components

List cans, lids, liners, films, bottles, seals and other food-contact parts.

2. Identify coatings

Check whether internal or external coatings are used.

3. Review supplier declarations

Look for BPA and other relevant bisphenol information.

4. Check intended use

Confirm that the documentation covers the actual food and conditions.

5. Review migration data

Verify that appropriate evidence exists.

6. Check transition deadlines

Determine whether the packaging is affected by a remaining transitional provision.

7. Update specifications

Make sure internal purchasing and quality specifications reflect the current legislation.

What about imported packaging?

The EU requirements apply to food contact materials placed on the Union market, including relevant imported materials. The Commission’s framework applies to food contact materials generally, regardless of whether they are manufactured inside or outside the EU. Food Safety

This is particularly important for companies sourcing packaging internationally.

A supplier outside the EU may still need to provide evidence that its material meets the applicable EU requirements.

“Compliant in our home market” does not automatically mean “EU compliant.”

What if the packaging supplier says the material is compliant?

That is a useful starting point.

It is not necessarily the end of the assessment.

The buyer should verify that the declaration and supporting data correspond to:

the actual material
the current formulation
the intended food
the intended temperature
the contact duration
the current legislation

A compliance declaration is only useful when it describes the material that is actually being supplied.

Existing packaging specifications may need updating

Companies should review internal specifications for:

BPA
relevant bisphenols
coatings
adhesives
plastics
migration limits
supplier documentation

This is especially important if specifications still reference older legislation or obsolete BPA requirements.

Regulation (EU) 2024/3190 also amended Regulation (EU) No 10/2011, including removing the previous BPA entry from the plastic regulation’s Union list and linking BPA use to the new regulation. Eur-Lex

What does this mean for testing laboratories?

The new restrictions create a practical analytical question:

How do you demonstrate that the relevant substances are absent or below the applicable detection or migration threshold?

The corrected regulation sets additional rules for analytical methods used to verify that food contact materials do not contain residual BPA or other relevant hazardous bisphenols, or do not release them above specified thresholds. A default detection limit of 1 µg/kg applies where no other limit is specified and no relevant EURL method determines otherwise. Eur-Lex

This makes method selection important.

A laboratory should not simply use an old BPA method without checking whether it is suitable for the current regulatory question.

A BPA test is not always the same as a BPA compliance assessment

There is an important difference between:

“BPA was measured at X.”

and:

“The food contact article complies with Regulation (EU) 2024/3190.”

The second conclusion requires more context.

You need to consider:

whether BPA was intentionally used
which material is involved
the intended application
the applicable transition period
migration requirements
analytical detection limits
relevant derogations

The laboratory result is evidence.

The regulatory assessment turns that evidence into a compliance conclusion.

Process equipment can be affected too

BPA compliance is not limited to consumer-facing packaging.

Food-processing equipment can also fall within the food-contact framework.

Examples can include:

seals
pumps
flanges
sight glasses
moulds
other repeat-use components

The regulation provides a longer transition for certain repeat-use final food contact articles used as professional food-production equipment, reflecting the difficulty of replacing individual components in complex systems. Eur-Lex

Manufacturers should therefore include relevant equipment in their review.

What about reusable bottles and kitchenware?

Reusable food-contact articles can also fall within the scope.

The EU Commission specifically described the BPA restriction as affecting products such as reusable plastic drink bottles and other kitchenware. Food Safety

Again, the correct assessment depends on the specific material and application.

A product labelled “reusable” is not automatically exempt.

A practical compliance workflow

A useful workflow looks like this:

1. Map the materials

Identify every component that can contact food.

2. Identify BPA use

Check raw materials, coatings, adhesives and manufacturing processes.

3. Check alternatives

Determine whether replacement materials contain other regulated bisphenols.

4. Determine the deadline

Check which transitional provision applies.

5. Review supplier documentation

Make sure it reflects the current material and legislation.

6. Assess migration

Select appropriate migration testing based on intended use.

7. Verify analytical methods

Ensure the laboratory method is suitable for the relevant regulatory threshold.

8. Update specifications

Align purchasing and quality requirements with the current legislation.

9. Document the assessment

Keep the evidence linking material, testing and regulatory conclusion.

Common mistakes to avoid

Looking only at plastic

BPA can also be relevant to coatings and other food-contact applications.

Treating “BPA-free” as full compliance

It is not.

Ignoring other bisphenols

Replacing BPA with another restricted substance can simply move the problem.

Using old supplier declarations

The current material and current legislation need to be covered.

Testing the wrong conditions

Migration data must reflect intended use.

Ignoring transition periods

Different applications have different deadlines.

Waiting until the last batch

Material substitution, validation and migration testing can take time.

What should companies do now?

For most packaging businesses, the practical priority is to establish a clear BPA inventory.

Create a list of all food-contact materials and classify each one:

BPA-free and documented

BPA-containing but covered by a remaining transition

BPA-containing and transition expired

Unknown

The last category deserves immediate attention.

Unknown does not mean compliant.

The bigger lesson for packaging compliance

The BPA restriction illustrates a broader point about food-contact materials.

Packaging compliance is not simply about choosing a material that looks safe.

It involves the interaction between:

material composition

manufacturing

migration

food type

contact conditions

regulatory requirements

and documentation.

A packaging material can therefore only be assessed properly in the context of its intended use.

The Makrolife perspective

For packaging and food manufacturers, BPA compliance is a good example of where analytical testing and regulatory assessment need to work together.

Makrolife can support this process by helping companies determine:

which requirements apply
which packaging components need review
which analytical tests are relevant
whether migration testing is appropriate
whether existing supplier data are sufficient
where documentation gaps exist

The goal is not simply to generate another laboratory report.

It is to establish whether the material, test result and regulatory requirement actually align.

The bottom line

The EU’s BPA restriction changes the way manufacturers need to think about food-contact packaging.

The key question is no longer simply:

“How much BPA migrates from our packaging?”

It is broader:

“Can we demonstrate that our food-contact material complies with the current EU rules on BPA and other relevant bisphenols?”

For companies, the practical response is to:

map materials → review suppliers → identify BPA use → check transition periods → assess alternatives → verify migration → update documentation.

And do not assume that BPA-free = fully compliant.

The packaging still needs to meet the wider EU food-contact framework.