BPA in Food Contact Materials: Information for UK businesses on EU BPA requirements and the current position in GB.

Bisphenol A (BPA) is used in the manufacture of some food contact materials (FCMs), including certain plastics and coatings. Its potential health effects have been assessed at UK, EU and international level.

The EU has introduced restrictions on the use of BPA in certain FCMs through Commission Regulation (EU) 2024/3190 (the ‘EU BPA Regulation’). These apply to products placed on the EU market and the Northern Ireland (NI) market under the Windsor Framework. 

In the UK, the Food Standards Agency (FSA) and Food Standards Scotland (FSS) conducted a public consultation on proposals relating to BPA in FCMs and the FSA  published their summary of responses indicating the intention to introduce restrictions on the use of BPA in Great Britain (GB), subject to the appropriate policy and legislative process. 

In parallel the UK Government has announced its intention to pursue a UK‑EU Sanitary and Phytosanitary (SPS) agreement and continues to negotiate with the EU. The Department for Environment, Food and Rural Affairs (Defra) has published information advising businesses, including those that do not currently trade with the EU, to begin considering how potential future changes within scope of the SPS arrangements could affect their operations. Defra has also been clear that the timing and detail of any changes will depend on the outcome of the negotiation.

This guide provides factual information to help UK businesses understand:

• EU BPA requirements where these apply; and
• the current legal position in GB

This guide does not introduce new legal obligations and is not a substitute for the applicable legislation. Businesses should ensure they refer to the relevant legislation where appropriate.

For the purposes of this guide:

• EU legislation applies to EU market and to NI under the Windsor Framework.
• In GB (England, Wales and Scotland), EU BPA restrictions do not currently apply.

Businesses placing relevant products on the EU or NI market must comply with the EU BPA Regulation, including the first key compliance deadline of 20 July 2026.

Separate arrangements apply to certain pre‑packed retail goods moving from GB to NI under the Northern Ireland Retail Movement Scheme (NIRMS). Businesses using these arrangements should refer to relevant UK Government guidance on their application.

For the GB domestic market, EU BPA restrictions do not apply directly. The current legal position remains unchanged unless and until domestic legislation is introduced.

This guide is intended to:

• provide information on EU BPA Regulation where these apply to the EU or NI market, including relevant timelines
• support business awareness and planning in the context of potential future changes in GB

This guide does not set out compliance requirements for the GB domestic market.

The EU BPA Regulation introduces restrictions on the intentional use of BPA and other hazardous bisphenols in certain food contact materials.

These restrictions apply to products placed on the EU market and in Northern Ireland.

The regulation includes transitional arrangements to allow businesses time to adjust.

The EU restrictions prohibit the intentional use of BPA in the manufacture of certain food contact materials and apply at the point at which products are first placed on the EU or Northern Ireland market.

Only compliant materials and articles may therefore be placed on those markets from the applicable dates.

While the restriction relates to the use of BPA in manufacturing processes, it is enforced at the point at which food contact materials are first placed on the market.

First transitional deadline: 20 July 2026

From this date, newly manufactured and imported single‑use and general repeat‑use FCMs placed on the EU or NI market must not contain intentionally added BPA or other hazardous bisphenols, except where specific transitional provisions apply.

Single‑use FCMs containing BPA placed on the market before this deadline may continue to be filled and sealed with food for a limited period. Food packaged during that period may continue to be sold until stocks are exhausted in line with EU BPA Regulation.

Extended deadline: 20 January 2028

An extended transitional period applies to certain specified products, including some single‑use articles and selected repeat‑use professional food production equipment.

Failure to comply with applicable EU requirements may affect the ability to place products on the EU or NI markets.

Early preparation may help businesses that supply the EU or NI market manage supply chain changes. For businesses supplying only the GB domestic market, early preparation may also support longer‑term planning.

This section provides optional considerations to support businesses in understanding and responding to EU BPA requirements, where relevant.

EU requirements concerning BPA apply when food contact materials or packaged food are placed on the EU or NI market. These requirements do not apply directly to the GB domestic market.

Following the BPA consultation and publication of the summary of responses, the FSA indicated an intention to introduce restrictions in GB, subject to the appropriate policy and legislative process.

Early preparation may help businesses manage potential future changes and reduce the risk of disruption where adjustments to product composition or supply chains may be required.

Businesses placing products on the EU or NI market may wish to consider the following:

1. Identify products and markets 

• reviewing products to identify where BPA or related bisphenols may be intentionally used
• distinguishing between products supplied to the EU or NI market and those supplied only in GB

2. Plan for EU and NI compliance (where relevant) 

• considering relevant transitional deadlines under EU BPA Regulation
• reviewing supply chains, manufacturing processes and product portfolios to identify where changes may be required

3. Engage with supply chains 

• engaging with suppliers to understand whether BPA or related substances are intentionally used
• considering availability of alternative materials where required for EU or NI market placement

4. Monitor regulatory developments 

• monitoring updates from the FSA, FSS and relevant UK Government departments
• considering how future legislative developments, including those related to SPS arrangements, may affect longer‑term planning

For the EU and NI markets, businesses placing FCMs must comply with applicable EU food contact materials legislation, including the restrictions on the intentional use of BPA set out under EU BPA Regulation.

For the GB market, businesses must comply with applicable assimilated food contact materials legislation, which sets general requirements for safety, compliance and supporting documentation. The current GB framework does not include equivalent restrictions on the intentional use of BPA.

Across these frameworks, businesses are required to be able to demonstrate compliance with applicable legislation. The approach will depend on the product and manufacturing process.

• compliance may be demonstrated through appropriate means, including documentation, supplier assurances, purity data or testing, where relevant
• testing, where used, should be carried out in line with relevant requirements and guidance
• supporting documentation should be retained while the product is on the market and for an appropriate period afterwards

Under the EU FCMs legislative framework, and its GB assimilated equivalent:

• businesses must be able to demonstrate compliance with applicable requirements
• where relevant, FCMs and articles must be accompanied by a Declaration of Compliance
• supporting documentation must be retained and made available to competent authorities on request

These requirements arise under the wider food contact materials legislative framework. This guide reflects those requirements and does not introduce or expand them.

The European Union has published EU guidance on the implementation of Commission Regulation (EU) 2024/3190 regarding the use of BPA and related substances in materials intended for food contact. The following document may prove helpful: 

EU Note for Guidance on implementation of Commission Regulation (EU) 2024/3190

Defra has published information for businesses on the UK‑EU SPS arrangements: UK‑EU SPS Agreement – information for businesses.

For technical queries, contact FCM-BPA@food.gov.uk. 

For updates, businesses may wish to monitor the FSS/FSA websites.