Commission Regulation (EU) 2024/3190 is now in force. New Q&A guidance published in December 2025 sets out the specifics , including what is and is not covered, how testing works and the deadlines that matter most for food production environments.

Bisphenol A has been used in food contact materials for decades in epoxy coatings, plastic linings, adhesives and printing inks. Commission Regulation (EU) 2024/3190, adopted on 19 December 2024 and in force from 20 January 2025, prohibits its use across a wide range of materials and articles that come into contact with food. The European Commission published 40 questions and answers on 17 December 2025 to help businesses work through the detail.

Whether or not a bakery operation is directly affected will depend on the packaging formats and processing equipment in use. The regulation reaches further than many operators may expect.

What the ban actually covers

The prohibition applies to BPA and its salts, as well as other bisphenols and bisphenol derivatives carrying a harmonised EU hazard classification as carcinogenic, mutagenic, toxic to reproduction (CMR category 1A or 1B), or category 1 endocrine disruptors for human health. In practice, this means the ban applies to: plastics, varnishes and coatings, printing inks, silicones, adhesives, ion-exchange resins and rubber used in food contact applications.

At the point this guidance was published, five additional bisphenols beyond BPA had already been classified under this framework: Bisphenol S (BPS), Bisphenol AF (BPAF), tetrabromobisphenol-A (TBBPA), phenolphthalein and 4,4'-isobutylethylidenediphenol. All are now prohibited from use in the manufacture of food contact materials (FCMs) within scope.

Paper, board and recycled materials

Paper and cardboard are not subject to the ban. However, the exemption does not extend to composite articles. Where paper or board is combined with a regulated material, such as a plastic coating or adhesive, the resulting article falls within scope and a Declaration of Compliance is required.

For bakery packaging that uses coated boards or laminated films, this distinction is operationally significant.

Recycled materials present a separate consideration. Trace amounts of BPA found in recycled plastic as an incidental contaminant, not intentionally added, are exempt from the prohibition. The guidance is clear that this applies only to non-intentionally added residues.

BADGE: still permitted, with conditions

Bisphenol-A diglycidyl ether (BADGE) is a derivative widely used in epoxy coatings and adhesives. It is not banned under this regulation but carries a specific condition: if BADGE is used in the manufacture of an FCM, the finished article must not contain residual BPA. Operators using BADGE must therefore be able to demonstrate, via their supply chain or through testing, that BPA is absent as a residue. The detection limit is set at 1 microgram per kilogram (μg/kg).

Laboratory testing is not mandatory under the regulation but the guidance notes it may be the most practical way to verify compliance when a bisphenol derivative such as BADGE has been used in manufacture. The EU Reference Laboratory for Food Contact Materials is currently finalising an analytical method at Union level for this purpose.

Professional production equipment: a longer runway

For most food contact articles, the primary transition period is 18 months from the date of entry into force, meaning articles compliant with the pre-existing rules could be placed on the market for the first time until 20 July 2026. However, the regulation includes a specific derogation for professional food production equipment: repeat-use articles in this category have a transition period extending to 20 January 2029 — 48 months.

Varnishes and coatings used specifically for packaging fruit, vegetables and processed fish products have a 36-month window, to 20 January 2028. Importantly, once a transition period expires, products already on the market may continue to be sold until stocks are exhausted, but no new non-compliant stock may be placed on the market.

Declarations of Compliance

Every FCM within scope must be accompanied by a Declaration of Compliance (DoC). The regulation specifies the minimum content: the identity and contact details of the operator issuing the declaration, identification of the material or article, the date of declaration and, critically, a statement as to whether or not BPA or other relevant bisphenols or derivatives were used in manufacture. Intermediate materials and final articles alike require this documentation and it must be available for market surveillance checks at all points in the supply chain.

Imports into the EU are subject to the same requirements as domestically produced goods. Importers and distributors carry responsibility for ensuring conformity and holding supporting documentation.

Exemptions: narrow and conditional

There are two permitted uses of BPA under Annex II to the regulation. The first is as a monomer in the manufacture of liquid epoxy resins applied as coatings on self-supporting food contact materials or articles with a capacity greater than 1,000 litres, large-scale tanks and associated pipelines. The second is in polysulfone filtration membrane assemblies, where no viable alternative currently exists. Both are subject to strict migration limits and non-detectable migration thresholds.

Where an operator believes a specific application for another hazardous bisphenol is unavoidable due to the absence of alternatives, Article 6 of the regulation allows for an authorisation procedure via the European Food Safety Authority (EFSA). EFSA is required to publish guidance on the information needed for such applications by 20 January 2027.

Reporting obligations

Business operators using BPA, other hazardous bisphenols, or bisphenol derivatives under an authorised derogation are required to report to the Commission on the status of alternative substances, initially four to five years after authorisation, then at subsequent five-year intervals. This obligation is voluntary for micro, small and medium-sized enterprises.

Key dates at a glance

20 January 2025 — Regulation in force

20 July 2026 — End of 18-month transition for most single-use and repeat-use FCMs

20 January 2028 — End of 36-month transition for BPA-containing varnishes/coatings on fruit, vegetable, and fish packaging

20 January 2029 — End of 48-month transition for professional food production equipment