On October 1, 2020, Germany announced its intention to submit a proposal to restrict the use of bisphenol A (CAS 80-05-7) in the EU along with any “structurally related bisphenols (including derivatives) of similar concern for the environment.” The proposal would restrict the presence of the substance in articles to a maximum of 0.02% by weight for (i) use as an additive, (ii) presence as a residue (also for imported goods), and (iii) for presence in mixtures for non-automated processes. Release rate limits would also be introduced for the substances from articles during their service life to prevent release into the environment and/or direct migration to organisms. Germany writes that the restriction proposal is being suggested as a mechanism to reduce what it has identified as “continuous emission into surface water via wastewater treatment” of bisphenol A, which is recognized within the EU as “an endocrine disruptor for environmental organisms.”
The reasoning for the restriction also explains that “to avoid regrettable substitution of Bisphenol A, especially with regard to drop-in alternatives, it is planned to also address other bisphenols of concern, including derivatives (i.e. those that exhibit similar concern for the environment based on their structural similarity and hazardous properties for the environment).”
The intention was announced to the European Chemicals Agency (ECHA) as the first step within a standard procedure that EU member states can follow to have substances placed on the restriction list (Annex XV) under REACH. Stakeholders are being requested to provide the German authorities with any relevant information on the substances that could be considered during the process. The restriction dossier is set to be developed by Germany over the next year and then submitted to ECHA in October 2021. The proposal will then require opinions from the Committee for Risk Assessment (RAC) and the Committee for Socio-economic Analysis (SEAC).
ECHA (October 1, 2020). “Registry of restriction intentions until outcome: 4,4′-isopropylidenediphenol.”
Chemical Watch (October 8, 2020). “Germany submits intention for broad bisphenol A restriction proposal.”