On March 8, 2024, the Food Packaging Forum (FPF) submitted its comments to the European Commission on the initiative to ban the use of bisphenol A (BPA) in food contact materials (FCMs). The initiative follows the European Food Safety Authority’s (EFSA) revised opinion on the safety levels of BPA (FPF reported), and aims to also address the use of other bisphenols in FCMs to avoid regrettable substitution of BPA.  

The following is a shortened version of FPF’s comment. 

FPF supports the proposed regulation, emphasizing that it aligns with the risk assessment conducted by EFSA. Over 100 scientific studies corroborate the migration of BPA from various FCMs, posing risks to human health. 

We commend the EU Commission for its inclusive approach, targeting all bisphenols with current and future harmonized classifications. However, we suggest expediting assessments for all bisphenols lacking harmonized classifications and advocate for a comprehensive group-wide restriction to enhance human health protection. 

Urging swifter action to mitigate health risks associated with BPA exposure, we recommend significant reductions in transition periods and the establishment of clear sunset dates of maximum five years for the prohibition of BPA-containing FCMs. This is supported by the economic burden associated with BPA-related health care costs (FPF reported). 

Sufficiently sensitive analytical methods are lacking to quantify BPA at exceedingly low levels. FPF urges the Commission to develop advanced detection methods. It is important to provide guidance to business operators and Member States on analytical chemistry methods and safe thresholds for BPA migration. 

The proposed regulation omits specific FCMs despite evidence of BPA migration. We advocate for broader coverage to minimize BPA exposure and caution against exemptions for recycled materials such as paper and PET beverage bottles. We value stronger protective measures to uphold public health, particularly within the framework of promoting circularity and minimizing resource usage. 

 

Track other opportunities to contribute to regulations on food contact chemicals and materials on the Food Packaging Forum’s consultations page.

 

References 

Food Packaging Forum (March 8, 2024) “FPF feedback on restrictions on bisphenol A (BPA) and other bisphenols in food contact materials.European Commission. 

European Commission (February 9, 2024) “Food safety – restrictions on bisphenol A (BPA) and other bisphenols in food contact materials. 

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