The European Commission has published the Q&A Guidance supporting Commission Regulation EU 2024/3190, offering practical support on implementing the new EU rules on bisphenol A (BPA) and other hazardous bisphenols in food contact materials. This guidance clarifies how businesses should interpret and apply the regulatory requirements.

Under Regulation EU 2024/3190, the use of BPA and its salts, as well as other bisphenols and bisphenol derivatives with harmonised hazardous classifications, is prohibited in the manufacture of a range of food contact materials, including plastics, varnishes/coatings, inks, adhesives, rubbers, silicones and ion-exchange resins. Limited derogations apply where no suitable alternatives exist and where migration into food must be non-detectable.

The Q&A guidance is structured around key practical questions, clarifying issues such as:

• Which materials fall under the regulation (and which do not, e.g. paper and board).
• Treatment of recycled materials that may contain trace, unintended BPA
• Requirements for Declarations of Compliance and testing to demonstrate conformity.

Regulation 2024/3190 entered into force on 20 January 2025 and includes transitional timelines running through 2026–2029 to allow industry to adapt and phase out BPA-based materials.

This means that manufacturers, suppliers, and importers of materials that come into contact with food must now check whether their products comply with the new requirements, document which bisphenols have been used, and seek alternatives where necessary.

IBE-BVI members can ask  implementation guidance here