On July 1, 2026, the Food Packaging Forum (FPF) submitted comments to ECHA’s call for evidence on occupational exposure limits (OELs) for selected bisphenols, specifically bisphenol S (BPS, CAS 80-09-1), bisphenol F (BPF, CAS 620-92-8), and bisphenol AF (BPAF, CAS 1478-61-1).
In its submission, FPF welcomed the initiative as an important step for protecting workers from hazardous bisphenols. At the same time, FPF emphasized that real-world exposure typically occurs to mixtures rather than individual substances, and that current regulatory approaches may not adequately address cumulative or synergistic effects. The selected substances represent only a small fraction of the many bisphenols and other chemicals to which people are exposed.These combined exposures are thus worth considering when setting OELs, rather than assessing substances in isolation.
FPF also submitted exposure-relevant evidence from three of its databases: FCCdb, FCCmigex and FCChumon. Overall, 179 bisphenols and derivatives have been identified as food contact chemicals (FCCs), 134 are listed for use in the production of food contact materials (FCMs), 74 have been detected in food contact materials, and 43 have been detected in human samples. All three target bisphenols – BPS, BPF, and BPAF – are listed for use in the production of FCMs, detected in FCMs, and detected in human samples, indicating ongoing exposure for both workers and the general population. Thirty-seven studies have investigated their presence in FCMs, where they were primarily found in plastics, metal coatings, paper & board, and multi-materials.
Additionally, FPF encouraged ECHA to take recent scientific evidence on human exposure and potential health impacts of bisphenols into account. FPF highlighted the systematic evidence map on bisphenol exposure from 2026 (FPF reported), the umbrella review of epidemiological evidence (FPF reported) and its follow-up in the PlasticHealthAware dashboard, and an in-vitro study investigating the biological activity profiles of bisphenols (FPF reported).
References
ECHA (April 1, 2026). “Occupational exposure limits – Call for comments and evidence on bisphenols.”
Food Packaging Forum (July 1, 2026). “FPF Comments on ‘Occupational exposure limits – Call for comments and evidence on bisphenols’” ECHA. (pdf)
Mulders Y., et al. (2025). “Global Observatory on Planetary Health: PlasticHealthAware (Version 1.0).” Boston College, Boston.
