Regulation (EU) 2024/3190 bans bisphenol A (BPA) and other hazardous bisphenols in food contact materials in the EU (FPF reported). These hazardous bisphenols can be authorized for continued use in food contact materials if companies submit additional data for further safety assessment. The European Food Safety Authority (EFSA) is developing data requirements for the safety assessment of hazardous bisphenols and their derivatives, and requested feedback on its draft in a public consultation (PC-1873). The Food Packaging Forum (FPF) submitted comments to the consultation on May 7, 2026.
In its comments, FPF welcomed the draft statement as an important step towards enforcing the ban of hazardous bisphenols and derivatives, expressing support for EFSA’s group-based approach and appreciation that the proposed data requirements go beyond genotoxicity testing. However, FPF also highlighted several issues that could limit the effectiveness of the proposed requirements.
First, the definition used for bisphenols and bisphenol derivatives is narrow and may exclude relevant substances commonly understood as bisphenols (FPF reported on the same issue in the Swiss regulation). Bisphenol M (BPM, CAS 13595-25-0) and bisphenol P (BPP, CAS 2167-51-3) would not fall within the scope of the current definition, despite being suitable for similar uses as BPA and commonly recognized as bisphenols.
Second, FPF highlighted that carcinogens and endocrine disrupting chemicals do not have safety thresholds that can be monitored or enforced; their eligibility for authorization in food contact materials after further testing is therefore questionable.
Third, FPF noted that already authorized bisphenols and derivatives without harmonized hazard classifications would not be subject to the same level of scrutiny as newly authorized substances. This could perpetuate data gaps and undermine the objective of preventing regrettable substitutions within the bisphenol group.
Finally, FPF placed the discussion in the broader context of food contact material regulation, noting that hazardous bisphenols are only one group among many hazardous chemicals authorized for use in food contact materials. FPF therefore called for a precautionary approach and reiterated the need for a comprehensive revision of EU food contact material legislation to better protect human health.
References
EFSA (2026). “Draft statement on data requirements for the safety assessment of hazardous bisphenols other than Bisphenol A (BPA) and their derivatives.” Public consultation PC-1873.
Food Packaging Forum (May 7, 2026). “FPF Comments on ‘Draft statement on data requirements for the safety assessment of hazardous bisphenols other than Bisphenol A (BPA) and their derivatives.’” (pdf)
European Commission (2024). “Commission Regulation (EU) 2024/3190 on the use of bisphenol A and other bisphenols and bisphenol derivatives in food contact materials.”
