BPA regulations for food contact materials

Bisphenol A (BPA) is widely used in food contact materials. This chemical can be migrated into the body when it is leached into food. With rising concerns about its potential health issues, governments around the world have introduced regulations on its use.

In this article, we will explore how BPA migrates into food, the potential health risks of exposure, and the existing regulations in the EU, UK, US, and China.

What BPA is and its usage in food contact materials

BPA is an industrial chemical used to make polycarbonate (PC) and epoxy resins. It helps to make these chemicals strong, clear, and heat-resistant. Due to its characteristic, BPA is commonly used in many consumer products, including food contact materials.

Food contact materials (FCM) generally refer to any articles intended to come into contact with food, such as food packaging materials, cans, bottles, and food containers. BPA can be found in epoxy resins which are used as a protective lining in metal-based food and beverage cans. It is also found in polycarbonate (PC) which is used to produce food containers such as baby bottles.

How does BPA migrate from FCM to humans and what are the health issues concerned?

BPA can migrate from FCM into the food when they are degraded by heating or exposed to acidic/alkaline substances. Longer contact time will also lead to a higher volume of BPA released into food.

Although there is no consensus on the health effects of BPA, concerns have been raised about the safety of BPA in recent years. Some scientific studies have observed developmental effects in newborn and very young laboratory animals given small amounts of BPA. This has contributed to the concern that human infants may be vulnerable to developmental effects from BPA.

As a precautionary measure, many governments and regulatory bodies around the world have implemented regulations on the use of BPA in food contact materials, particularly for infants and young children.

BPA regulations in FCM

European Union

• REACH
  BPA has been included in the Candidate List of Substances of Very High Concern (SVHC) since 2017 because of its classification as Toxic for reproduction and endocrine-disrupting properties. If the article contains a concentration upper than 0.1% by weight, manufacturers and importers must comply with their SVHC - REACH duties.
  
  
• Regulation (EC) 2018/213
  This regulation is an amendment of Regulation (EU) No 10/2011 to limit the use of BPA in varnishes and coatings intended to come into contact with food, adding new restrictions and specifications as not to be used for the manufacture of polycarbonate drinking cups or bottles which, due to their spill proof characteristics, are intended for infants and young children and change the total specific migration limit to 0.05 mg/kg.

  In addition, the use of BPA in plastic bottles and packaging containing food intended to be used by infants and children younger than 3 years old is prohibited.
  
  

• EN 14372
  EN 14372 is a European standard which specifies safety requirements relating to the materials, construction, performance, packaging and labelling of cutlery and feeding utensils. All products are intended to be used by a child aged up to 36 months.
  One of the chemical requirements is the BPA for polycarbonate and polysulfone containing thermoplastic components of cutlery and feeding utensil are tested. The chemical migration for this type of product shall not exceed 0.03 ug/ml.
  
  
  
• Additional national BPA regulations within EU economies
  
  • Austria
    BPA has been banned in teething rings and pacifiers according to The Food Safety and Consumer Protection Act of Austria (LMSVG).
    
    
  • Belgium
    BPA has been banned in food contact materials for infants and young children according to Act of 4 Sept 2012.
    
    
  • Denmark
    BPA has been prohibited in food contact materials for infants and young children according to Statutory Order No. 822.
    
    
  • France
    BPA has been banned in all food contact materials (except industrial equipment such as pipes and tanks) according to Law No. 2012-1442.
    
    
  • Spain
    BPA has been banned in food packaging according to law 7/2022.
    
    
  • Sweden
    BPA has been banned in coatings and varnishes in food contact materials for infants and young children according to Regulation SFS 2012:991.

United Kingdom

As long as the migration limit is within the regulation, the use of BPA is permitted in food contact materials.
However, it is forbidden in varnishes and coatings intended to be in contact with infant formula, baby foods, and products intended for young children according to Materials and Articles in Contact with Food Regulations 2012 (and its amendments).

United States

Under Federal Laws, BPA has been banned in packaging for powdered and liquid infant formula. Also, it is prohibited in infant feeding bottles and spill-proof cups, including their closures and lids.

Down to the local level, the state regulations vary in scope and strength, and they may be more restrictive than the FDA regulations. For instance, in the state of Connecticut, Maine, and Vermont, BPA is prohibited in reusable food or beverage containers. In New York state, BPA is prohibited in pacifiers and unfilled beverage containers for children under 3 years old.

China

BPA is banned in the production of special food contact materials and products for infants and young children in accordance with GB 9685-2016 standard.

How the Eurofins Toys & Hardlines network of laboratories can help

In the context of food contact materials, it is necessary to test any object that directly contacts food to ensure its safety and to confirm that it does not transfer any of its components into the food beyond the acceptable limit.

Eurofins Toys & Hardlines network of laboratories provides a wide range of food contact materials testing services in accordance with global standards and regulations, assisting you to achieve product compliance.

For more details, please click here to learn more about our Food Contact Materials Testing Service.