On July 30, 2026, the Food Packaging Forum (FPF) submitted comments on the draft revision of Plastics Feeding Bottles — Specification prepared by the Bureau of Indian Standards (BIS). The draft standard establishes requirements for plastic feeding bottles and accessories intended for infant use, including provisions related to materials, chemical migration testing, labeling, and product performance.
Among other measures, the draft removes polycarbonate and polyethersulfone as permitted feeding bottle materials due to concerns regarding bisphenol A (BPA) and bisphenol S (BPS), prohibits BPA in plastic feeding bottles, and establishes migration limits for selected substances.
In its submission, FPF welcomed the efforts of BIS to strengthen protections for infants and to address concerns related to BPA-containing feeding bottles.
However, FPF highlighted several considerations to strengthen the draft’s chemical safety provisions, noting that feeding bottles are used by infants, a population particularly vulnerable to chemical exposures due to their developing physiology and higher food intake relative to body weight.
FPF’s comments focused on five key issues.
First, FPF noted that while the draft addresses BPA and references concerns related to BPA and BPS, the available scientific evidence shows that restricting individual substances may lead to replacement with chemically similar alternatives that present comparable hazards, a phenomenon often referred to as “regrettable substitution.”
Second, FPF highlighted that the draft’s chemical restrictions focus primarily on selected heavy metals, BPA, and di(2-ethylhexyl) phthalate (DEHP). However, scientific evidence shows that plastic food contact materials can contain a much wider range of intentionally added substances, including plasticizers, stabilizers, antioxidants, catalysts, pigments, and processing aids (FPF reported). FPF therefore commented that the BIS may consider evaluating additional groups of substances commonly present in food contact plastics.
Third, FPF drew attention to the relevance of non-intentionally added substances (NIAS), such as impurities, reaction by-products, degradation products, and oligomers that may be present in finished plastic articles and migrate into food despite not being intentionally added.
Fourth, FPF noted that repeated heating, sterilization, cleaning, and long-term use may affect the properties of feeding bottle materials over time. FPF also pointed to emerging scientific concerns regarding the potential release of micro- and nanoplastic particles from plastic feeding bottles during normal use (FPF reported).
Finally, FPF highlighted the need to explicitly consider infant-specific vulnerability when establishing chemical safety requirements and migration limits. There is growing scientific evidence indicating that combined exposure to multiple endocrine-disrupting chemicals can contribute to adverse developmental outcomes, underscoring the importance of considering cumulative and mixture exposures in chemical risk assessment.
To support future updates of the standard, FPF pointed BIS to free and publicly available scientific resources including FPF’s FCCmigex, which compiles experimentally measured migration data for food contact chemicals, and FCCprio, which identifies and prioritizes food contact chemicals of concern based on published hazard information.
References
Bureau of Indian Standards (2026). “PCD 21 (34327) – Plastics Feeding Bottles – Specification.”
Food Packaging Forum (July 30, 2026). “FPF Comments on Draft Indian Standard PCD 21 (34327) – Plastics Feeding Bottles – Specification (Second Revision of IS 14625).” (pdf)
