EU Bisphenol A Food-Contact Ban, Deadline by Deadline

The headline date for the EU's bisphenol A rule in food contact materials is 20 July 2026. The Official Journal text sets four, and the one that applies to a can, a bottle or a piece of kitchen equipment depends on what it is and when it was first placed on the market. The first deadline, 20 July 2026, has already passed. The next is 20 July 2027. After that come 20 January 2028 and 20 January 2029.

The ban in five facts

20 July 2026 The last day most single-use and repeat-use articles made with BPA could be first placed on the EU market, under Articles 11(1) and 12(1) of Regulation (EU) 2024/3190. Source: Regulation (EU) 2024/3190, as corrected by Regulation (EU) 2026/250

Four dates, not one 20 July 2026, 20 July 2027, 20 January 2028 and 20 January 2029. Which applies depends on the article type and when it was first placed on the market. Source: Articles 11 and 12 of Regulation (EU) 2024/3190, as corrected

12 months to fill and seal Single-use articles first placed in time may be filled and sealed for 12 months after their period ends. The packaged food may be sold until stocks are exhausted. Source: Article 11(3); Commission Note for Guidance C/2025/6721

Final articles, not coatings The dates apply to the final food contact article, such as a coated can. The Commission's guidance says coatings and resins have no sell-through provision. Source: Commission Note for Guidance C/2025/6721, Q33

3,859 tonnes in October to December 2025 Against 14,330 a year earlier. Most of the 2025 fall in BPA imports by seven EU member states sits in this one quarter. The data cannot say why. Source: Eurostat Comext; Phontix AI calculation

As of 26 October 2026. Evidence base: the Official Journal text of Regulation (EU) 2024/3190 and Regulation (EU) 2026/250, read in full; the Commission's Note for Guidance on the Regulation (C/2025/6721, 17 December 2025), read on the transitional provisions and on intermediate materials; Eurostat Comext import data.

Regulation (EU) 2024/3190 prohibits BPA in the food contact materials and articles it covers: adhesives, rubbers, ion-exchange resins, plastics, printing inks, silicones, varnishes and coatings. A correcting regulation, (EU) 2026/250 of 2 February 2026, then changed some of the wording and gave Article 12(3) two end dates where the original had one. Summaries written before February 2026 can therefore be wrong on repeat-use articles.

For a coatings, resin or polycarbonate buyer in Europe, the practical question is which clock the final article is on, and what that leaves for the supplier upstream.

What the two regulations say

Regulation (EU) 2024/3190 is dated 19 December 2024 and was published in the Official Journal on 31 December 2024. The text says it enters into force on the twentieth day after publication. That works out to 20 January 2025 (DERIVED; the text does not print the date).

• Scope (Article 1(2)). Adhesives, rubbers, ion-exchange resins, plastics, printing inks, silicones, varnishes and coatings.
• The prohibition (Article 3(1)). BPA may not be used in the manufacture of, or be placed on the Union market in, the food contact materials and articles in scope.
• Derogations (Article 3(2) and Annex II). A specific application can be allowed if it is listed in Annex II.
• Other bisphenols (Articles 4 and 5). A material made with another bisphenol must not contain residual BPA, and other hazardous bisphenols are dealt with separately.
• Annex II entry 151 (CAS 80-05-7). Two uses. First, varnishes and coatings, with BPA as a monomer or starting substance for liquid epoxy resins on self-supporting food contact materials or articles with a capacity greater than 1,000 litres. Second, plastics, with BPA as a monomer for polysulfone filtration membrane assemblies. For both, migration must not be detectable, and final articles must be cleaned and flushed before first contact with food.

Regulation (EU) 2026/250 is dated 2 February 2026 and was published on 3 February 2026. It also enters into force on the twentieth day after publication, which is 23 February 2026 (DERIVED; the consolidated version of 2024/3190 carries that date). It corrects 2024/3190 as follows.

• It deletes "and its salts" from Article 3, and Article 3(2) now refers to placing on the Union market.
• Article 9(2)(c) now refers to residual BPA.
• Article 11 now says "first placed on the market" where it said "placed on the market".
• Article 12(3) now has two dates. Repeat-use articles first placed under Article 12(1) may remain on the market until 20 July 2027. Those first placed under Article 12(2) may remain until 20 January 2029. The original text had a single date, 20 January 2029, for both.
• Annex III point 3 is reworded, and Recital 18 now says 36 months.

What we did not read: EFSA material and the other Annex II entries. We read the Commission's Note for Guidance only on the transitional provisions (Articles 11 and 12) and on intermediate materials.

The four deadlines, and who each one applies to

The dates below are taken from Articles 11 and 12 as corrected by 2026/250. The fill-and-seal rule in Article 11(3) gives single-use articles 12 months after their applicable period ends. Food packaged in that window may be sold until stocks are exhausted. The Commission's guidance reads Article 11(3) the same way.

The dates apply to the final food contact article, for example a coated can. The Commission's guidance (Note for Guidance C/2025/6721, 17 December 2025) says intermediate materials such as coatings and resins have no sell-through provision, so a coatings supplier needs to finish well before its customer's date.

Who gets the longer clock (Article 11(2) and 12(2)). Single-use articles qualify for the 20 January 2028 date only if they are for (a)(i) fruit or vegetables, excluding the products in Annex I of Directive 2001/112/EC, (a)(ii) fishery products, or (b) articles whose BPA varnish or coating is only on the exterior metal surface. Repeat-use articles qualify only if they are professional food production equipment.

Two things that are easy to get wrong.

1. The 2029 date is not a general repeat-use date. After 2026/250 it applies only to professional equipment first placed under Article 12(2). Other repeat-use articles are on the July 2027 clock.
2. The dates 20 July 2027 and 20 January 2029 are the ends of fill-and-seal and remain-on-market periods. They are not dates on which first placing is still allowed.

The derogation in Annex II entry 151 is separate from all four dates. It is a standing exception for two narrow uses, not a transition period.

What the customs record shows for BPA

We pulled EU imports of bisphenol A (Eurostat Comext) for seven importing member states (Germany, the Netherlands, Belgium, Italy, Spain, France and Poland) from a list of ten origins, by month, and kept importer-origin-month rows of at least 20 tonnes. Only four origins had rows of that size: South Korea, Taiwan, China and Thailand. The unit value is import value divided by tonnes. It is a CIF average across grades and is lagged. It is not a price and not a landed cost.

(OBSERVED for value and tonnes; unit values are DERIVED arithmetic. The 2026 column covers January to July only and is shown for reference. We do not compute a change for it, because the window is shorter than a full year.)

Calendar 2025 against calendar 2024, the same twelve months each.

• Tonnes kept fell about 18%, from 66,486 to 54,547.
• The weighted unit value fell about 17%, from EUR 1,428 to EUR 1,189 a tonne.
• South Korea's share of kept tonnes fell from about 93% to about 83%. Taiwan's tonnes rose from 3,324 to 7,815.

The fall sits in one quarter. The quarterly totals show where the 2025 drop came from.

Tonnes in January to September 2025 were 50,687, about 3% below the same months of 2024 (52,156). Almost all of the annual fall is in October to December 2025: 3,859 tonnes against 14,330 a year earlier. Tonnes came back in 2026. Unit values fell through 2025 and were close to EUR 1,000 in the first half of 2026. The data cannot say why the October to December 2025 quarter was so low.

What this does and does not show. It shows that BPA imported by the seven member states from the origins we pulled was lower in volume and cheaper per tonne in 2025 than in 2024, with most of the volume fall in one quarter. It does not show why. The Regulation restricts BPA in food contact uses, and BPA also has uses outside food contact, which we have not quantified.

Nothing in this pull separates the two, and we found no filing or company statement linking the 2025 fall to the Regulation (GAP, as of 26 October 2026). Intra-EU BPA production and trade are also not in an import count, and the other twenty member states are not in this pull.

Imports of the input phenol are covered in our note on India's phenol anti-dumping case, and phenol and acetone together in our essay on one price problem. They are not repeated here.

What to check this quarter

This is a reading of the regulation text, not legal advice. Confirm the position for your own products with counsel or your regulatory team.

• Can and closure coating makers. Work out for each can line whether it falls under Article 11(1) or 11(2). If it is under 11(1), first placing ended on 20 July 2026, and filling and sealing must finish by 20 July 2027. If it is under 11(2), the dates are 20 January 2028 and 20 January 2029. A can with BPA coating only on the exterior metal surface is on the longer clock, and so is a single-use can for fruit, vegetables or fishery products. An interior BPA lacquer on a can for other foods is not.
• Polycarbonate converters. Repeat-use polycarbonate articles first placed under Article 12(1) may remain on the market only until 20 July 2027. Only professional food production equipment under Article 12(2) has the 2029 date.
• Epoxy formulators. Annex II entry 151 is narrow: liquid epoxy on self-supporting articles above 1,000 litres, and polysulfone filtration membranes, both with no detectable migration and a cleaning and flushing step. We read entry 151 only; other Annex II entries were not checked for epoxy uses. For the epoxy resin trade in India, see our note on India's epoxy resin duty.
• Everyone. Ask suppliers for a written statement of BPA and residual BPA content, and keep records of the date each product was first placed on the market, because every deadline above turns on that date. Do not rely on summaries written before 23 February 2026 for Article 12(3).

Frequently asked questions

Related reading

• India's Epoxy Resin Duty Is In Force. The Import Record Shows What Changed.
• India's Phenol Anti-Dumping Case Names Seven Origins. The Import Record Shows Which Ones Matter.
• Phenol and Acetone Are One Price Problem

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Methodology and sources

Scope is Europe only. Regulatory dates come from the Official Journal text of Regulation (EU) 2024/3190 and Regulation (EU) 2026/250, read in full, and from the Commission's Note for Guidance, read on the transitional provisions and on intermediate materials. Dates marked as derived are the Article 11(3) fill-and-seal dates, counted by adding 12 months to the end of the applicable period.

Customs figures come from Eurostat Comext, bisphenol A imports by seven member states (Germany, the Netherlands, Belgium, Italy, Spain, France and Poland) from a list of ten origins, by month. Importer-origin-month rows under 20 tonnes are excluded, and the 20 tonne threshold has not been sensitivity-tested. Unit values are import value divided by tonnes, a CIF average across grades, lagged; they are not prices and not landed costs.

This is a reading of the regulation text and a customs record, not legal advice and not investment advice. Confirm the position for your own products with counsel or your regulatory team. Read how we treat customs data in our methodology.

Sources

1. Commission Regulation (EU) 2024/3190 of 19 December 2024, Official Journal, 31 December 2024
2. Commission Regulation (EU) 2026/250 of 2 February 2026, Official Journal, 3 February 2026
3. Commission Note for Guidance on the implementation of Regulation (EU) 2024/3190, C/2025/6721, 17 December 2025
4. Eurostat Comext, dataset DS-045409, bisphenol A imports