1. Introduction
Bisphenols are a group of chemicals that have a similar structure, typically featuring two hydroxyphenyl functional groups. Some are used in polycarbonate plastics or epoxy resins to prevent metal corrosion of cans and maintain food freshness. However, studies have increasingly shown that bisphenol A, bisphenol S and other commonly used bisphenols can migrate from food contact materials into food and cause a variety of health problems even at low exposure levels. Because of this, civil society organizations and government regulators have taken an increasing interest in reducing the use of this chemical group.
The following article outlines the commonly used bisphenols in food contact materials (FCMs), known health concerns from bisphenols as a group and certain well-studied bisphenols individually, plus how governments around the world are incorporating this information into regulation on FCMs.
2. About bisphenols
Bisphenols are a group of chemicals used to manufacture polycarbonate plastic, epoxy resins, and other products including thermal paper since the 1960s. They are, for example, commonly used in steel and aluminum can coatings to prevent corrosion and extend food freshness.
Exposure to bisphenols begins early in life. Bisphenols have been measured in utero, in human breastmilk, polycarbonate baby bottles, and sippy cups (FPF reported). Bisphenol A (BPA, CAS 80-05-7) is the most widely known and studied example of this chemical group but other bisphenols commonly used and measured in food contact articles include bisphenol S (BPS, CAS 80-09-1), bisphenol F (BPF, CAS 620-92-8) and bisphenol AF (CAS 1478-61-1).
There is growing consensus among the endocrine (i.e., hormone) research community of the negative effects exposure to BPA can have on the body even at low doses (FPF reported). A study published in September 2020 that evaluated 20 years’ worth of BPA research, including results from the US FDA’s CLARITY-BPA study, argues that there is “overwhelming evidence of harm” to human health from exposure to BPA (FPF reported).[1]
Bisphenols other than BPA have similar effects on the human body and the environment including deteriorating semen quality (FPF reported) and increasing the chance of developing cancer (FPF reported) including breast cancer (FPF reported).[2] Country-specific initiatives and regulations of BPA-replacing bisphenols have led to the increased identification and recognition of these adverse hazards.
Examples include the EU classification of BPS as a human reproductive toxicant (FPF reported), the French Agency for Food, Environmental and Occupational Health & Safety (ANSES) found that bisphenol B (BPB; CAS 77-40-7) is an endocrine disruptor (FPF reported), and the Swedish Institute of Environmental Medicine concluded that bisphenol AF (BPAF, CAS 1478-61-1) shows endocrine disrupting properties (FPF reported).
Civil society organizations have been pushing for stricter controls of BPA and other bisphenols (FPF reported) over concerns of regrettable substitution.
If the trajectory continues, the allowable uses of bisphenols will likely become increasingly strict, if not phased out completely. Unfortunately, bisphenols are difficult to directly replace in some applications such as can coatings (FPF reported).
3. Bisphenol A
Bisphenol A (BPA, CAS 80-05-7), the most widely known of the bisphenols, is primarily used as a starting substance for polycarbonate plastics and epoxy resins. BPA was first synthesized in 1891 and already found to exhibit estrogenic activity in the 1930s.[3][4] It is this potential to interfere with the human hormone system that underlies many of the concerns around BPA.
In food contact materials, polycarbonate is used to manufacture refillable containers, water dispensers, and electronic kitchen appliances. Epoxy resins are used as coatings in lids of glass containers and in the linings of food and drink cans. BPA is also used to coat thermal paper such as receipts and labels (FPF reported, also here) though this use was phased out in Europe in 2020 (FPF reported). BPA has been measured migrating from FCMs purchased from markets across Europe, the US, China, Nigeria, and elsewhere (FCCmigex).
BPA has been detected in humans in large biomonitoring studies in the European Union, United States, California, Canada, and Korea (FCChumon).
A derivative of BPA is bisphenol A diglycidel ether (BADGE, CAS 1675-54-3). BADGE is used in epoxy resins in the coatings that line some cans for food and drinks. When BADGE breaks down, BPA can be released, or BADGE itself has also been measured migrating into food (FPF reported). It too is a suspected endocrine disruptor[5][6][7] and has chemical derivatives.[8] Tetrabromobisphenol A (TBBPA, CAS 79-94-7) is another related chemical that can be used in polycarbonate plastic and in epoxy resins. It is on the EU Candidate list of SVHCs due to be carcinogenic and is suspected of being endocrine disrupting as well as persistent, bioaccumulative, and toxic (a PBT).[9]
One of the first concerns that entered the public consciousness was the use of BPA in baby bottles and cans of baby formula. Already in 1997, the US Food and Drug Administration found BPA that had migrated from the can in 12 of 14 samples of infant formula.[10]
Between 2008 and 2012, many countries began to regulate BPA in some or all food contact articles (FCAs) for babies and young children including Canada, the United States, Sweden, France, Belgium, the EU, and China. Many of these countries and others have since passed further limitations on the use of BPA in some or all FCAs and FCMs.
Studies are increasingly demonstrating effects of BPA on human behavior and the reproductive system at even small exposures (FPF reported).
BPA regulation in the European Union
In 2015, the European Food Safety Authority (EFSA) reported that diet is the major contributor to BPA exposure.[11]
Due to the growing evidence that low exposures cause health effects, in 2023 EFSA lowered the tolerable daily intake (TDI) value of BPA to 0.2 ng per kg body weight per day — 20,000 times less than it had previously been. According to EFSA, TDI represents the amount of a chemical that can be “ingested daily over a lifetime without appreciable risk.” In the 2023 risk assessment report, EFSA concluded that “there is a health concern from dietary BPA exposure” because “dietary exposures in all age groups exceeded the TDI by two to three orders of magnitude.”
Over the last decade, multiple branches of the EU government have become increasingly concerned about bisphenols in consumer products and have begun taking action. BPA is listed as a substance of very high concern (SVHC) in the EU due to being toxic for reproduction, and an endocrine disruptor for humans and the environment (FPF reported). Bisphenol B is also listed in the EU on the candidate list of SVHCs due to endocrine disrupting properties for human health and the environment. In April 2022, the European Chemicals Agency (ECHA) recommended that 34 bisphenols be classified as SVHCs (FPF reported).
In October 2022, Germany submitted a restriction proposal for BPA, bisphenols B, S, F, and AF, and their derivatives to a maximum concentration of 0.02% by weight for all articles made or imported into the EU (FPF reported, also here) due to endocrine disrupting properties for the environment.[12] Germany has since rescinded their proposal. The restriction was withdrawn in August 2023, to the consternation of some members of the scientific community (FPF reported). Germany removed the proposal in order to consider information gained through stakeholder submissions and plans to resubmit a new proposal at some point in the future but there are no details about what the new restriction proposal will cover or when it will come.
However, on June 12, 2024, the EU Expert Committee approved a proposal from the European Commission to ban BPA in FCMs (FPF reported). The Commission adopted the ban in 2024. It affects BPA in packaging such as can coatings, as well as reusable plastic bottles and kitchenware. Other bisphenols with harmonized CLP classifications as carcinogenic, mutagenic, or reprotoxic (CMR) 1a or 1b, or endocrine disrupting 1 are included in the ban except in specific applications. This includes bisphenol S (BPS, CAS 80-09-1) and bisphenol AF (BPAF, CAS 1478-61-1).
BPA regulation in the US
In 2010, the US Environmental Protection Agency (EPA) added BPA to its list of chemicals of concern. The US Food and Drug Administration (FDA) banned the use of BPA in infant formula packaging three years later but did not say the ban was for safety reasons. Instead, BPA was restricted to formalize the fact that industry had “abandoned” the use of BPA (FPF reported).
In 2018, the FDA published results from the CLARITY-BPA study carried out within the US to address disagreement surrounding the use of traditional endpoints of toxicity and modern hypothesis-driven, disease-relevant outcomes in previously studied animals.[13] It was meant to assess the potential health effects of long-term exposure to BPA.
The FDA concluded that “‘BPA did not elicit clear, biologically plausible, adverse effects …’ at levels even remotely close to typical consumer exposure levels” (FPF reported). However at the time there was push back from other researchers in the chemical exposure field claiming that the regulatory guidelines used to assess food additives and food-packaging related chemicals were devised in the 1970s and “have fallen behind the scientific knowledge” (FPF reported).
In the United States, civil society organizations are pushing the FDA to review the levels of BPA and other bisphenols allowed into food contact materials (FPF reported).
Following pressure from consumer groups (FPF reported), FDA undertook a review of the safety of BPA in FCMs in 2022 (FPF reported). The review was originally supposed to be concluded by October 2022 but as of this writing (November 2024) there has not been an update.[14]
Already in 2016, the state of California added BPA to Proposition 65 which requires manufacturers to put warnings on products containing BPA.[15] At least 12 other US states have restricted the use of BPA in some way, mostly in food-contact materials for young children[16] (FPF reported, also here) but some have also prohibited BPA in all reusable food contact articles.[17]
BPA regulation elsewhere
Australia and New Zealand
Australia and New Zealand have no official regulatory or safety limits of BPA[18]. In 2010 Australia instituted a voluntary phase out of BPA from polycarbonate baby bottles.[19] According to Food Standards Australia & New Zealand, industry groups have largely voluntarily phased out the use of BPA in polycarbonate plastic baby bottles and other products.
Canada
Canada in 2008 was the first country to complete a national comprehensive assessment of exposure to BPA.[20] Following the assessment, Health Canada announced that BPA will be deemed a “dangerous substance.”
China
Chinese Food Contact Materials Testing Standards for plastic resins, additives, and paints and coatings limits BPA to 0.6 mg/kg.
Japan
In the late 1990s the Japanese canning industry set a self-imposed BPA migration limit of ten parts per billion (food cans) and five parts per billion (drink cans) into food simulants. Many manufacturers switched to “BPA reduced cans” or changed the lining to one made with PET film.[21] A study in 2013 found Japanese products had lower levels of BPA than those imported into the country (FPF reported). Japan Food Sanitation Law 370 requires that in polycarbonate plastics have a specific migration limit of 2.5 μg/mL, BPA content limit is 500 μg/g.
Mercosur (Argentina, Bolivia, Brazil, Paraguay, and Uruguay)
Effective April 2022, the South American trade bloc Mercosur banned the use of BPA in baby bottles and other food contact articles designed for children and lowered the specific migration limit to 0.05 mg/kg for all other food contact articles.[22]
South Korea
The South Korean Ministry of Food and Drug Safety (MFDS) banned BPA in food contact materials intended for infants and young children effective January 2020 (FPF reported). The country’s Standards and Specifications for Utensils, Containers and Packaging for Food Products (2011) require BPA in polycarbonate, epoxy resin, polyaryl sulfone, polyarylate and organic coated metal products be limited to 0.6 mg/kg.
Switzerland
In June 2025, the Swiss Federal Food Safety and Veterinary Office (FSVO) updated the Ordinance on Food Contact Materials and Articles, aligning Swiss law more closely with European Union standards (FPF reported). A key element of the revision is a ban on the use of bisphenol A (BPA, CAS 80-05-7) and other hazardous bisphenols and their derivatives in coatings and varnishes used on food contact materials, except for large industrial containers (over 1,000 liters). To verify the absence of BPA, an extraction method with a detection limit of at least 1 μg/kg must be used.
Taiwan
BPA is banned from all polycarbonate FCMs.
4. Bisphenol S
Bisphenol S (BPS, CAS 80-09-1) is one bisphenol sometimes used to replace BPA in can coating applications and thermal papers.[23][24] It is connected to multiple adverse health outcomes, may be as harmful as BPA (FPF reported), and is found to migrate from food packaging (FPF reported). In January 2023, ECHA added BPS to its Candidate List of SVHCs for being toxic for reproduction and an endocrine disruptor for both humans and the environment (FPF reported). The switch from BPA to BPS is sometimes used as an example of regrettable substitution.
BPS metabolite levels in human urine are positively correlated with risk of cardiovascular disease. Scientists from University of Guelph report both BPS and BPA can decrease systolic blood pressure in mice, as well as rates of heart contraction and relaxation, within minutes of exposure – with BPS found to be more potent than BPA (FPF reported). Others have shown that BPS can induce adipogenesis (fat generation, FPF reported) and impair fertility (FPF reported)
BPS has been measured migrating from store-bought food packaging into food in Canada, China, and Poland (FPF reported, also here). Research published in 2023 on chemical migration of BPS and other substances from food packaging and labels assessed 140 food packaging samples from supermarkets in Montreal, Canada, and the US (FPF reported). BPS was detected in 29 out of 40 thermal price labels, 6 out of 29 nonprice labels, and 11 out of 39 plain films with concentrations up to 193 mg/cm² in the labels. Meanwhile, BPA was not found in any of the 140 samples. According to the Food Packaging Forum’s database on migrating and extractable food contact chemicals (FCCmigex), BPS has been measured in migrates and extracts from plastic, paper and board, metal, and multimaterial based food contact articles.
BPS regulation
BPS is included in the 2024 European Union ban on certain bisphenols in FCMs (FPF reported). It is also included in Switzerland’s bisphenol ban (FPF reported).
5. Other bisphenols
Due to the evidence of harm caused by BPA and the surrounding consumer outcry and increasing regulation, many manufacturers have switched to using structurally similar chemicals such as bisphenol S, or bisphenol F to replace BPA in both plastics and coatings. However, those chemicals too are now coming under scrutiny and greater regulation (FPF reported, also here).
According to FCCmigex, BPF is the third most measured bisphenol in migrates and extracts from food contact materials. Some of the studies investigating health effects of BPS have found that BPF induces similar changes (FPF reported, also here).
Other less well-studied bisphenols measured from FCMs include BPC, BPG, and BPZ (FPF reported).
In 2020, the German Environment Agency (UBA) tested 44 potential BPA replacements and found that 33 may have endocrine disrupting properties (FPF reported). As of July 2025, there are few restrictions on bisphenols other than BPA outside of the EU.
The Swiss ban, enacted in 2025, includes hazardous bisphenols and their derivatives but the definition is limited to structures where the phenol groups are connected by a single atom. This excludes substances like bisphenol M (CAS 13595-25-0) and bisphenol P (CAS 2167-51-3), which feature a benzene ring in the bridging unit. Notably, bisphenol M is under assessment by ECHA for being an endocrine disruptor, raising concerns about its continued use in food contact materials. Because these compounds fall outside the current structural definition, they are not regulated under the revised ordinance – creating a significant regulatory gap that may permit continued use of harmful bisphenols.
6. References
[1] Vom Saal, Frederick S.; Vandenberg, Laura N. (March 2021). “Update on the Health Effects of Bisphenol A: Overwhelming Evidence of Harm.” Endocrinology. DOI: 10.1210/endocr/bqaa171
[2] Parkinson, LV; Geueke, B; Muncke, J. (2024). “Potential mammary carcinogens used in food contact articles: Implications for policy, enforcement, and prevention.” Frontiers in Toxicology. DOI: 10.3389/ftox.2024.1440331
[3] Dodds EC, and Lawson W. (1938). “Molecular structure in relation to oestrogenic activity. Compounds without a phenanthrene nucleus.” Proceedings of the Royal Society London.
[4] Dodds EC, and Lawson W. (1936). “Synthetic oestrogenic agents without the phenanthrene nucleus.” Nature.
[5] Wang, Dongqi; Zhao, Haoduo; Fei, Xunchang; Synder, Shane Allen; Fang, Mingliang; Liu, Min (October 2021). “A comprehensive review on the analytical method, occurrence, transformation and toxicity of a reactive pollutant: BADGE”. Environment International. DOI: 10.1016/j.envint.2021.106701
[6] Rauter, Walfried; Gerald Dickinger, Rudolf Zihlarz and Josef Lintschinger. (1999) “Determination of Bisphenol A diglycidyl ether (BADGE) and its hydrolysis products in canned oily foods from the Austrian market”, Z. Lebensm. Unters. Forsch. A
[7] UBA (March 16, 2016). “Leitlinie zur hygienischen Beurteilung von organischen Beschichtungen im Kontakt mit Trinkwasser (Beschichtungsleitlinie)” [Guideline for public health evaluation of organic chemical coatings in contact with drinking water (coating guideline)] (PDF). www.umweltbundesamt.de (in German).
[8] Berdasco, Nancy Anne M.; Waechter, John M. (August 17, 2012). “Epoxy Compounds: Aromatic Diglycidyl Ethers, Polyglycidyl Ethers, Glycidyl Esters, and Miscellaneous Epoxy Compounds.” Patty’s Toxicology. DOI: 10.1002/0471435139.tox083.pub2
[9] ECHA “Substance Info Card: BPA”
[10] J. E. Biles; T. P. McNeal; T. H. Begley (December 15, 2997). “Determination of Bisphenol A Migrating from Epoxy Can Coatings to Infant Formula Liquid Concentrates.” J. Agric. Food Chem. DOI: 10.1021/jf970518v
[11] EFSA (January 21, 2015). “Scientific Opinion on the risks to public health related to the presence of bisphenol A (BPA) in foodstuffs.”
[12] ECHA (2022). “Germany proposes a restriction on bisphenol a and other bisphenols with endocrine disrupting properties for the environment.” (pdf)
[13] American Chemistry Council (2018). “The FDA CLARITY study.”
[14] US Food and Drug Administration (2023). “Bisphenol A (BPA).”
[15] State of California. “Proposition 65: BPA.”
[16] De Meyer, Martijn; David Feber; Felix Grünewald; Oskar Lingqvist; Daniel Nordigården; Emily Roeper. (July 22, 2022). “Navigating regulatory uncertainty in packaging: A new wave of chemical-substance regulations.” McKinsey
[17] Consumer Reports (August 14, 2012). “State laws on BPA.”
[18] New Zealand Food Safety Authority. “Bisphenol A – information sheet.”
[19] Food Standards Australia, New Zealand. “Bisphenol A.”
[20] Health Canada. “Bisphenol A (BPA).”
[21] Kawamura, Yoko. (2013). “Bisphenol A in Japanese canned foods.” (pdf)
[22] Keller & Heckman. (October 29, 2021). “Mercosur publishes three food contact related resolutions.” Packaging Law
[23] Viñas P, Campillo N, Martínez-Castillo N, Hernández-Córdoba M (May 2010). “Comparison of two derivatization-based methods for solid-phase microextraction-gas chromatography-mass spectrometric determination of bisphenol A, bisphenol S and bisphenol migrated from food cans.” Analytical and Bioanalytical Chemistry. DOI: 10.1007/s00216-010-3464-7.
[24] Xu, Ziyun; Tian, L; Goodyer, CG; Hales, BF; and Bayen, S. (2023). “Food Thermal Labels are a Source of Dietary Exposure to Bisphenol S and Other Color Developers.” Environmental Science and Technology. DOI: 10.1021/acs.est.2c09390
