Regulation 2024/3190 ushers in a new era for food-contact materials
On 20 January 2025, Regulation (EU) 2024/3190 officially came into force, introducing a sweeping ban on the use of Bisphenol A (BPA) — and other hazardous bisphenols — in materials and articles intended to come into contact with food. This regulation marks a pivotal moment for the packaging industry, especially in the food, pharmaceutical and cosmetic sectors, where MOCA (Materials and Objects in Contact with Food) compliance is often the standard of reference.
With a transition period ending on 20 July 2026, manufacturers and converters must now act quickly to eliminate bisphenol-based substances from their products and transition to compliant alternatives. (Have a look at the Regulation)
A ban covering the full packaging spectrum
This is not a narrow restriction — the new regulation applies broadly to all components of food-contact packaging. It includes:
- Main structural materials, such as polycarbonates, historically used in reusable water bottles, food containers, baby bottles, and kitchen utensils;
- Epoxy resins and inner coatings, used especially in metal packaging — including aluminium tubes, tinplate cans, aerosol containers, bottle caps — to provide a protective barrier between metal and contents;
- Adhesives and multilayer films, essential for flexible packaging formats;
- Printing inks and varnishes, even when applied externally;
- Rubber and silicone parts, often used in closures or gaskets;
- Ion-exchange resins, used in certain filtration or sealing systems.
In other words, every material or component that may come into direct or indirect contact with food is included. The ban is not only focused on BPA: it also includes salts and derivatives of other hazardous bisphenols as classified by ECHA (European Chemical Agency).
An important note to consider: the ban concerns Food contact, therefore Food Packaging is directly involved. However, other sectors must also refer to the same regulations for their products (this is the case for pharmaceuticals and cosmetics) – and it is understandable since these are products that, although not food, are still assimilated by our body. The new legislation therefore affects many companies in different sectors and markets, who are being called upon to review their packaging strategies.
Why the ban? The science behind the regulation
Bisphenol A (BPA) has long been scrutinized for its potential to interfere with hormonal systems. In 2023, the European Food Safety Authority (EFSA) updated its scientific opinion, lowering the tolerable daily intake (TDI) from 4,000 ng/kg to just 0.2 ng/kg body weight — a radical cut prompted by mounting evidence of adverse effects on the immune, reproductive, and metabolic systems.
As a result, BPA is now classified in the EU as a reproductive toxicant and endocrine disruptor (category 1B). But the regulation goes further, stating that bisphenols with similar chemical structures and activities — such as Bisphenol S (BPS) — “have already been confirmed as having properties that are hazardous to human health due to their reproductive toxicity” and therefore “have consequently been subject to harmonised classification and listed as such in accordance with Regulation (EC) No 1272/2008”. Translated: think twice.
Case-by-case exemptions may be requested (especially those involving production issues) but these involve complex procedures and are expected to remain exceptional.
Polycarbonates: high performance, now under pressure
Polycarbonates are among the most affected materials: these plastic packaging classics have long been favored for their durability, transparency, and heat resistance. For decades they have been used to manufacture:
- Reusable water bottles
- Microwave-safe food storage containers
- Dispensing equipment
- Infant feeding bottles (already banned in the EU since 2011)
However, due to their direct derivation from BPA, polycarbonates are now explicitly included in the ban. EFSA’s 2023 opinion highlighted that even minimal migration of BPA from these materials could pose serious health risks, particularly for vulnerable populations like infants and pregnant women.
To stay compliant, manufacturers are shifting toward plastic alternatives or non-plastic options like glass and stainless steel — especially in reusable applications.
Focus on metal packaging: a race to reformulate coatings
Metal packaging is one of the areas most directly impacted. Aluminium tubes, steel cans, bottle caps, and aerosol containers commonly use epoxyphenolic inner coatings containing residual BPA to prevent corrosion and content interaction.
From 20 July 2026, epoxyphenolic coatings containing BPA will no longer be authorized for food-contact applications under EU law.
To remain compliant, manufacturers must rapidly identify and validate alternative coatings that:
- Are free from BPA and its derivatives;
- Maintain adhesion to metal and durability under stress;
- Provide equivalent barrier protection;
- Pass migration tests and meet EFSA safety thresholds.
Many companies are currently investing in BPA-n.i. (non-intentionally added) technologies and performing rigorous lab and industrial testing to secure approvals before the deadline.
Worldwide: a fragmented but shifting landscape
While the EU takes a strong regulatory stance, BPA restrictions vary widely worldwide. Here’s how some key global markets are responding:
🇨🇦 Canada
BPA is banned in baby bottles but still permitted in food packaging. However, public and NGO pressure is increasing. Future restrictions may be introduced.
🇺🇸 United States
The FDA still considers BPA safe for food-contact use, but internal reviews were launched in 2022. Some states (e.g., California, New York) have implemented stricter rules at the local level.
🇬🇧 United Kingdom
BPA is banned in baby bottles and limited in food packaging. However, it remains authorized within certain migration thresholds.
🇯🇵 Japan
The Ministry of Health, Labour and Welfare will implement a Positive List system for synthetic resins starting in June 2025, which aims to align with international safety standards. BPA is under review, and limits are expected to tighten.
🇦🇺 Australia
BPA is restricted in baby products but permitted in food packaging. However, major retailers have voluntarily phased out BPA-containing products due to consumer demand.
🇧🇷 Brazil
ANVISA (National Health Surveillance Agency) banned BPA in baby bottles in 2012 but still allows its use in food-contact materials. No recent regulatory changes have been announced.
Towards a BPA-free packaging industry?
We are entering the Era of BPA n.i; will BPA-free Era be next?
Regulation 2024/3190 sends a clear message: packaging must evolve to prioritize human health and regulatory compliance. This transition, while complex and demanding, offers the opportunity to accelerate innovation, consumer trust, and sustainability goals.
For companies across the packaging value chain, proactive adaptation will be key. The timeline is tight — but with the right strategy, the industry can transform a regulatory challenge into a competitive advantage.
