On 3 February 2026, Regulation (EU) 2026/250 was published in the Official Journal. This text contains a correction (corrigendum) to the previously adopted Regulation (EU) 2024/3190 on the use of bisphenol A (BPA) in materials and articles intended to come into contact with food. The amendment to the transitional provisions may be particularly relevant for companies that use BPA or other bisphenols and bisphenol derivatives.
It is important to emphasise that a corrigendum is legally different from an amendment. The purpose of a corrigendum is to correct errors or ambiguities in the original text and to clarify how the legislator originally intended the provision to be interpreted. In principle, therefore, it does not impose new obligations, but provides clarification that is deemed to have applied from the outset.
The correction mainly concerns the wording of the transitional measures. These provisions are crucial because they determine the conditions under which existing products may still be placed on the market or continue to be traded during the phase-out of BPA. For manufacturers, importers and users, clarification of these rules may have consequences for, among other things, stock management, contractual agreements and compliance planning.
For single-use articles, ‘placed on the market’ was corrected to ‘placed on the market for the first time’ (Article 11).
For reusable articles, the dates of expiry of the transition period were corrected as follows:
|
Category |
Placing on the market |
Availability on the market |
Use |
|
Reusable materials and articles intended to come into contact with food |
Up to 18 months after the entry into force of the Regulation (July 2026) |
Up to 12 months after the end of the transition period (July 2027) |
Until the end of their service life
|
|
Reusable materials and articles used as professional equipment for food production |
Up to 36 months after the entry into force of the Regulation (January 2028) |
Up to 12 months after the end of the transition period (January 2029)
|
Until the end of the service life |
Companies that rely on the transition periods set out in the BPA Regulation would therefore be well advised to check whether their interpretation and internal timing are still in line with the corrected text. As this is a correction, the original wording cannot simply be taken for granted.
We advise affected market participants to evaluate the impact of this correction in a timely manner and, where necessary, to adjust their compliance documentation and phase-out planning.
