BPA, other bisphenols and phthalates in plastics: what the opened rules restrict, and where PFAS fits
Map each grade to the rules for its end use: EU food contact, US food contact or US children's products, and check PFAS separately.
In Short
- EU: BPA prohibited in FCM (2024/3190).
- Eight phthalates capped at 0.1%.
- FDA: no BPA epoxy in formula packs.
The Packaging & Food-Contact Materials Guide
Every roll traced to its film, ink and adhesive lots.
- Which rules apply
- Evidence for the use
- Hold, decide, trace
We ask for your name and email so we can handle this request. The full guide then opens on this site, ready to translate, print or save. Privacy policy. Practical orientation, not legal advice; your quality unit decides which rules apply.
UltimateFree guide
The Packaging & Food-Contact Materials Guide
Every roll traced to its film, ink and adhesive lots.
Restrictions on bisphenols and phthalates come from different laws for different products, so one material can face several rules. This guide reads four of them. Opened: the EUR-Lex consolidated text of Commission Regulation (EU) 2024/3190 dated 23 Feb 2026, which incorporates amending Regulation (EU) 2026/250; and eCFR 21 CFR 175.300(i), 177.1580(d) and 16 CFR 1307.1 to 1307.3, up to date as of 1 Oct 2026. The consolidated text is a documentation tool with no legal effect; the authentic Official Journal versions control. Not opened: the text of 2026/250 itself, Annexes II and III of 2024/3190 in detail, Regulation 10/2011, REACH Annex XVII, EU PFAS proposals and US state laws. PFAS is not covered by these texts. It is orientation, not legal advice. Sources checked 5 Oct 2026.
EU: BPA prohibited in food-contact materials
Regulation 2024/3190 covers BPA and other hazardous bisphenols in seven groups of food contact materials: adhesives, rubbers, ion-exchange resins, plastics, printing inks, silicones, and varnishes and coatings. Article 3(1) prohibits using BPA in their manufacture and placing materials made with it on the EU market, with derogations only for specific applications in Annex II.
Which rule fits this part? (simplified)
- BPA prohibited; hazardous bisphenols restricted.
More on eU: BPA prohibited in food-contact materials
Article 4 says materials made with another bisphenol must not contain residual BPA. Article 5 prohibits hazardous bisphenols other than BPA unless authorised under Article 6 or covered by the conditions in Article 5(3).
EU Transition Dates
In the current consolidated text, Article 11 lets single-use final articles made with BPA under the earlier rules be first placed on the market until 20 July 2026, or until 20 January 2028 for articles preserving fruit, vegetables or fishery products and articles with a BPA coating only on the exterior metal surface; they may be filled and sealed in the following 12 months. Article 12 sets first placing until 20 July 2026 for repeat-use articles and 20 January 2028 for professional food production equipment.
EU 2024/3190 Transition Dates
| Article | Applies to | Date |
|---|---|---|
| 11(1) | Single-use articles made with BPA | 20 Jul 2026 (passed) |
| 11(2) | Fruit, vegetable or fishery packs; exterior coatings | 20 Jan 2028 |
| 12(1) | Repeat-use articles | 20 Jul 2026 (passed) |
| 12(2) | Professional food production equipment | 20 Jan 2028 |
| 12(3) | Repeat-use articles under 12(1) may remain on the market | 20 Jul 2027 |
| 12(3) | Equipment under 12(2) may remain on the market | 20 Jan 2029 |
- 11(1)
- Applies to
- Single-use articles made with BPA
- Date
- 20 Jul 2026 (passed)
- 11(2)
- Applies to
- Fruit, vegetable or fishery packs; exterior coatings
- Date
- 20 Jan 2028
- 12(1)
- Applies to
- Repeat-use articles
- Date
- 20 Jul 2026 (passed)
- 12(2)
- Applies to
- Professional food production equipment
- Date
- 20 Jan 2028
- 12(3)
- Applies to
- Repeat-use articles under 12(1) may remain on the market
- Date
- 20 Jul 2027
- 12(3)
- Applies to
- Equipment under 12(2) may remain on the market
- Date
- 20 Jan 2029
More on eU Transition Dates
Article 12(3) then differs: repeat-use articles under paragraph 1 may remain on the market until 20 July 2027; professional equipment under paragraph 2 until 20 January 2029.
EU Declarations of Compliance
Article 8 requires materials covered by the Regulation, and bisphenols used as starting substances, to carry a written declaration of compliance at all marketing stages other than retail, with the content set in Annex III, which this guide did not read in detail. Supporting documentation must be available and given to authorities on request.
Supplier Declaration Check for Resin Grade PR-77
More on eU Declarations of Compliance
In practice, ask each resin, ink and coating supplier for a declaration that names this Regulation, check it against the grade you buy, and keep it with the material specification and the article you make from it.
US food contact: two abandoned BPA uses
In the US, 21 CFR 175.300(i) says BPA-based epoxy resins may no longer be used as coatings in packaging for powdered and liquid infant formula, because the use was abandoned. 21 CFR 177.1580(d) says polycarbonate resins may no longer be used in baby bottles and sippy cups for the same reason.
More on uS food contact: two abandoned BPA uses
Other uses listed in those sections remain in the regulations. State laws on bisphenols in packaging were not opened. Record which regulation each food-contact grade relies on, so a change in an end use can be checked against it.
US Children's Products: Eight Phthalates
16 CFR 1307.3 prohibits children's toys and child care articles that contain more than 0.1 percent of DEHP, DBP or BBP, and more than 0.1 percent of DINP, DIBP, DPENP, DHEXP or DCHP. The limits apply to any plasticized component part or other component part that may contain phthalates.
More on uS Children's Products: Eight Phthalates
Under 1307.2, a child care article is a product designed or intended to help children aged 3 and younger sleep or feed, or help them suck or teethe. PFAS is outside all four texts; see the TSCA PFAS reporting guide and check EU and state rules separately.
Questions
Is BPA banned in EU food-contact plastics now?
Article 3 of Regulation 2024/3190 prohibits it, with Annex II derogations. The 20 July 2026 first-placing dates have passed. In the current consolidated text, repeat-use articles may remain on the market until 20 July 2027, professional equipment until 20 January 2029, and some 2028 dates remain.
Can we switch to another bisphenol?
Article 4 bars residual BPA in materials made with another bisphenol, and Article 5 prohibits hazardous bisphenols unless authorised or meeting its conditions. Check the substance's classification first.
Which phthalates does CPSC limit?
Eight, each above 0.1 percent: DEHP, DBP, BBP, DINP, DIBP, DPENP, DHEXP and DCHP, in children's toys and child care articles under 16 CFR 1307.3.
Does this guide cover PFAS?
Not in detail. None of the opened texts addresses PFAS; see the TSCA PFAS reporting guide and check EU and state restrictions separately.
Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.
Keep reading
Food-Contact Materials in the EU and US: One Evidence File, Two Systems
EU 10/2011 Plastics Food Contact: Union List, Migration Limits and the Declaration of Compliance
EU Packaging and Packaging Waste Regulation (PPWR) 2025/40 Readiness
FCM Migration Testing Readiness Guide (EU 10/2011 & FDA)
FDA Food-Contact Polymers (21 CFR 177): Clearance Routes, FCNs and Conditions of Use
Recycled Plastics for Food Contact: EU 2022/1616 and FDA's Recycling Guidance