EU publishes guidelines C/2025/6721 for the implementation of the Bisphenol A Regulation

Regulation (EU) 2024/3190, which was adopted in December 2024, banned the use of bisphenol A (BPA) and its salts in food contact materials. But what exactly does that mean?

On 17 December 2025, the EU published Guideline C/2025/6721. This guideline answers practical questions on five main areas.

1. Scope of application of the Regulation

• Which materials are affected?
• What exceptions apply (e.g. paper/cardboard, enamel, materials intended to come into contact with pet food)?
• Handling of recycled materials.
• Definitions: semi-finished vs. finished food contact materials.

2. Other bisphenols and bisphenol derivatives

• Which additional bisphenols are also prohibited?
• Procedure for the approval of hazardous bisphenols (e.g. BPS).
• Requirements for risk assessments in accordance with EFSA guidelines.
• Substances currently classified as hazardous: BPS, BPAF, TBBPA, 4,4′-isobutylethylidene diphenol, phenolphthalein.

3. Compliance and auditing

• Proof of compliance: documentation, migration tests, modelling.
• Implementation of the detection limit for BPA: 1 µg/kg.
• Obligation to declare compliance – even without the use of BPA.
• Responsibilities within the supply chain.

4. Placing on the market

• Regeln für Export in Drittländer und Import aus Drittländern.
• Umgang mit BPA in Lebensmitteln aus externen Quellen.

5. Transitional provisions

Deadlines for placing on the market:

• 18 months (until July 2026) for most materials.
• 36 months (until January 2028) for certain packaging and equipment.
• Additional 12 months for filling.
• Sale of filled single-use materials until stocks are exhausted.
• Differences between single-use and reusable materials.
• Special rules for commercial equipment.