The European Commission (EC) is preparing a proposed Recommendation focused on the monitoring of bisphenol A (BPA), bisphenol S (BPS), and related compounds in food. The initiative aims to identify sources of unintended bisphenol presence, with the goal of informing future risk management measures.

Under the draft proposal, Member States will be responsible for conducting the monitoring, in active collaboration with food business operators and food contact material (FCM) suppliers. Industry involvement will be critical to ensure comprehensive and accurate data collection.

The scope of the monitoring covers all food categories, with a particular focus on products packaged in recycled FCMs, such as paper and paperboard. The recommended timeframe for monitoring activities is 2025 through 2027.

Investigations into contamination sources will be triggered only when BPA or BPS levels in food are equal to or exceed 0.01 mg/kg (10 µg/kg). Analytical methods used for testing must meet a limit of quantification of 1 µg/kg for both food and FCMs.

According to the draft text, “The monitoring and outcome of the investigations will enable [the Commission] to establish the level of BPA that is to be considered as unavoidable presence from sources that cannot be controlled and that is not related to the intentional use of BPA.”

Important note for industry: This Recommendation is not finalized yet and remains subject to change. Stakeholders should monitor its progress and begin assessing potential implications for compliance, sourcing, and material testing.