Regulatory status verified: 22 September 2026. Next scheduled review: January 2027 (SVHC Candidate List update).
Bisphenols are chemicals built from two phenol rings joined by a bridging group, and the best known of them, bisphenol A (BPA), is the monomer of polycarbonate and epoxy resins rather than an additive mixed into them. About 10 million tonnes of BPA were made in 2022, 65 to 70 % of it for polycarbonate, so what actually ends up in the plastic, and what leaves it? Regulation (EU) 2024/3190 has been in force since 20 January 2025, and its main transition ended on 20 July 2026, so BPA-containing food-contact articles may no longer be placed on the EU market except under two narrow Annex II derogations. The US Food and Drug Administration takes the opposite position and still considers BPA safe at the levels found in food. This page works through what a bisphenol is and how it differs from an additive, the six bisphenols that matter in plastics (BPA, BPS, BPF, BPAF, BADGE and TBBPA), how they migrate out of a finished part, what the human exposure and toxicology evidence shows on both sides of the Atlantic, what Regulation (EU) 2024/3190 and the REACH Candidate List now require, and what the rule change means for anyone who formulates or buys plastic.
| Bisphenol | Abbreviation | Role in plastics | Additive or monomer | EU status (September 2026) |
|---|---|---|---|---|
| Bisphenol A | BPA | Monomer of polycarbonate and epoxy resins | Monomer | Banned in food-contact materials (Reg. (EU) 2024/3190); SVHC since 12 Jan 2017 |
| Bisphenol S | BPS | BPA substitute; polyethersulfone monomer; thermal-paper developer | Monomer | Covered by the same food-contact ban; SVHC since 17 Jan 2023 |
| Bisphenol F | BPF | Epoxy resin building block | Monomer | Covered by the food-contact ban |
| Bisphenol AF | BPAF | Fluoroelastomer crosslinker; also a PFAS | Curing agent | SVHC since 4 Feb 2026 |
| BADGE | BADGE | Epoxy resin building block | Monomer | Covered by the food-contact ban |
| Tetrabromobisphenol A | TBBPA | Reactive flame retardant in FR-4 epoxy laminates and polycarbonate; additive flame retardant in ABS | Additive | SVHC since 17 Jan 2023; harmonised Carc. 1B from 1 Sep 2025 |
Additive, monomer and curing agent are the three categories of Regulation (EU) No 10/2011 Articles 3(7) and 3(8). Only TBBPA is an additive in the legal sense.
What Are Bisphenols?#
A bisphenol is a compound with two hydroxyphenyl groups joined by a bridging atom or group, and the bridge is what distinguishes bisphenol A (a propane bridge) from bisphenol S (a sulfonyl bridge) and bisphenol F (a methylene bridge). Bisphenol derivatives such as bisphenol B and BPAF follow the same pattern with a different bridge or ring substitution, and this shared architecture is why regulators legislate them as one substance group rather than one substance at a time. Why does European law treat them as one family rather than one substance at a time? Regulation (EU) 2024/3190 prohibits "hazardous bisphenols" as a group precisely to stop manufacturers moving from a restricted bisphenol to a structurally similar one that carries a similar hazard profile.
Is BPA a plastic additive or a monomer?#
BPA is not a plastic additive: it is a starting substance, one of the two monomers that react to form the polycarbonate chain or the epoxy network, which is why it is chemically bound into the polymer rather than dissolved in it. Regulation (EU) No 10/2011 draws the legal line that answers this question. Article 3(7) defines an additive as a substance intentionally added to achieve a physical or chemical effect during processing or in the final material and intended to be present in that final material, while Article 3(8) covers polymer production aids; monomers and other starting substances sit in a separate legal category entirely, so the substances this reference calls plastic additives are mixed into a finished polymer, not built into it. That distinction changes the answer to the question everyone actually asks, which is whether BPA leaches: bound BPA does not migrate the way an additive does, but residual unreacted monomer can remain in polycarbonate after polymerisation, and it can be released when the polymer hydrolyses. TBBPA is the one exception on this page, because it is used both as a reactive flame retardant, built into the epoxy backbone, and as an unreacted additive flame retardant in ABS housings.
Which plastics contain bisphenols?#
Bisphenols occur in four plastics, listed below.
- Polycarbonate and PC/ABS, where BPA is the monomer.
- Epoxy resins, built from BPA or BPF with epichlorohydrin.
- Polyethersulfone, built from BPS.
- Flame-retarded epoxy laminates and ABS, where tetrabromobisphenol A is used.
Roughly 65 to 70 % of the 10 million tonnes of BPA produced in 2022 went into polycarbonate, the transparent, impact-resistant plastic used in optical media, glazing and reusable containers, while epoxy resins built from BPA, BPF or BADGE and epichlorohydrin serve as structural adhesives, composite matrices and can-lining lacquers. Polycarbonate hydrolyses above 70 °C at high humidity, a reaction that breaks the carbonate linkage and releases BPA, so the additive and stabilizer package that protects it against heat and hydrolysis matters as much as the polymer choice itself; that package is on additives for polycarbonate.
Epoxy can coatings are a coating chemistry rather than a plastic in the sense used on this site, and the topic is handled below the contextual border rather than here. Polyethersulfone built from BPS is used where heat resistance beyond polycarbonate's range is required, and the additive side of epoxy formulation for structural and composite uses is on additives for epoxy resins.
Is BPA a plasticizer or a phthalate?#
BPA is neither a plasticizer nor a phthalate: plasticizers are low-volatility liquids blended into a polymer to soften it, phthalates are esters of ortho-phthalic acid, and BPA is a solid monomer that becomes part of the polymer chain. The three chemistries share only the fact that regulators and toxicologists group them under the same endocrine-disruption concern, not a common structure or function. Plasticizers work by inserting themselves between polymer chains to increase flexibility; BPA instead reacts to form the chain itself, which is the structural reason the "is BPA a plasticizer" question has a firm no as its answer.
The 6 Bisphenols That Matter in Plastics#
Six bisphenols matter in plastics: bisphenol A (BPA), bisphenol S (BPS), bisphenol F (BPF), bisphenol AF (BPAF), the epoxy building block BADGE and the brominated flame retardant tetrabromobisphenol A (TBBPA). Five of them are monomers or curing agents that end up chemically bound into a polymer network, and one, TBBPA, is a genuine additive under Regulation (EU) No 10/2011. The order below follows BPA as the head entity, then its two direct substitutes, then the epoxy building block, then the additive-grade derivative.
| Bisphenol | CAS | EC | Formula / molecular weight | Melting point | Role in plastics |
|---|---|---|---|---|---|
| Bisphenol A (BPA) | 80-05-7 | 201-245-8 | C15H16O2 / 228.29 g/mol | 156-157 °C | Monomer of polycarbonate and epoxy resins |
| Bisphenol S (BPS) | 80-09-1 | 201-250-5 | C12H10O4S / 250.27 g/mol | 240.5 °C | BPA substitute; polyethersulfone monomer; thermal-paper developer |
| Bisphenol F (BPF) | 620-92-8 | 210-658-2 | C13H12O2 / 200.23 g/mol | 162.5 °C | Epoxy resin building block |
| Bisphenol AF (BPAF) | 1478-61-1 | 216-036-7 | C15H10F6O2 / 336.23 g/mol | 159-162 °C | Fluoroelastomer crosslinker |
| BADGE | 1675-54-3 | 216-823-5 | C21H24O4 / 340.4 g/mol | n/a (liquid resin) | Epoxy resin building block |
| Tetrabromobisphenol A (TBBPA) | 79-94-7 | 201-236-9 | C15H12Br4O2 / 543.9 g/mol | 178 °C | Reactive flame retardant (FR-4 epoxy, PC); additive flame retardant (ABS) |
Identity data from PubChem (CIDs 6623, 6626, 12111, 73864, 2286 and 6618). BADGE melting point is given for the pure compound; the commercial resin is a liquid.
BPA: the polycarbonate and epoxy monomer#
Bisphenol A (CAS 80-05-7) is the monomer that gives polycarbonate its transparency and stiffness and that reacts with epichlorohydrin to build epoxy resins, and about 10 million tonnes of it were produced in 2022. Its molecular weight of 228.29 g/mol and melting point of 156 to 157 °C place it as a solid that is polymerised, not blended, into the finished part. Aleksandr Dianin first made the compound in 1891, and Edward Charles Dodds tested it as a synthetic estrogen in the 1930s, decades before it became the industrial monomer it is today. BPA binds the estrogen receptor tens of thousands of times more weakly than estradiol, the body's own hormone, which is the starting point for the toxicological debate covered later on this page. Since 23 November 2023, BPA carries a harmonised classification as toxic for reproduction, category 1B (H360F), under the EU Classification, Labelling and Packaging Regulation, a classification that applies regardless of the food-contact question.
BPS: the substitute that inherited the problem#
Bisphenol S (CAS 80-09-1) replaced BPA in food-contact coatings, consumer receipts and heat-resistant engineering plastics because its sulfonyl bridge melts at 240.5 °C and survives more heat, and the European Chemicals Agency added it to the REACH Candidate List on 17 January 2023 for reproductive toxicity and endocrine-disrupting properties for both human health and the environment. BPS serves three roles: a BPA substitute in food-contact and consumer applications, the monomer for polyethersulfone, and the colour-developer in thermal paper. Registrants have notified GHS classifications that include H360FD, may damage fertility and the unborn child, in 49 % of the classifications recorded in PubChem for the substance; that is a notified classification, not a harmonised one, and it sits alongside three separate Proposition 65 listings in California between 29 December 2023 and 8 December 2025. The Candidate List entry exists for the same reason Regulation (EU) 2024/3190 regulates bisphenols as a group: a substitute that keeps the same two-phenol-ring structure tends to keep the same hazard profile.
BPF and BPAF#
Bisphenol F (CAS 620-92-8) differs from BPA only in its bridge, a single methylene group instead of a propane unit, and it is used to make the lower-viscosity BPF epoxy resins that formulators choose when a thinner, more reactive resin system is needed. Its molecular weight of 200.23 g/mol and melting point of 162.5 °C place it close to BPA in physical behaviour, and it falls under the same EU food-contact prohibition as BPA and BPS. Bisphenol AF (CAS 1478-61-1) carries two trifluoromethyl groups in place of BPA's methyl groups, which makes it a crosslinker for fluoroelastomers and, because of those fluorine atoms, a bisphenol that is also classed as a PFAS. The European Chemicals Agency added BPAF and its salts to the Candidate List on 4 February 2026 for reproductive toxicity, taking the list to 253 entries, and registrants have notified it as H360F, may damage fertility. Fluoroelastomer cure chemistry itself is rubber chemistry and sits outside this reference's scope.
TBBPA, brominated epoxy and BDP: the bisphenols that really are additives#
Only one bisphenol on this page is an additive in the legal sense: tetrabromobisphenol A (CAS 79-94-7), the highest-volume brominated flame retardant, which is reacted into FR-4 circuit-board epoxy and polycarbonate but blended unreacted into ABS housings. TBBPA works by releasing bromine in a fire that traps hydrogen and hydroxyl radicals and interrupts the combustion chain reaction; when it is reacted into an epoxy backbone it is not free to migrate, but the unreacted grade used in ABS is dispersed rather than bound, which is the additive case in the strict legal sense. Its grades, dosage and the full regulatory matrix are on TBBPA (tetrabromobisphenol A).
Two bisphenol-derived flame retardants extend the family, and both belong to the same class as TBBPA, compared on brominated flame retardants: BDP, bisphenol A bis(diphenyl phosphate) (CAS 5945-33-5 for the monomer, 181028-79-5 for the oligomeric commercial product), a halogen-free aryl oligophosphate flame retardant used in PC/ABS and PPE blends, and TBBPA-DBMPE, used at around 15 wt% in polyurethane and soft PVC according to the ECHA plastic additives mapping. Neither derivative is on the Candidate List. The halogen-free aryl phosphate route for PC/ABS is on BDP flame retardant.
TBBPA itself has been an SVHC since 17 January 2023 on carcinogenicity grounds, and its harmonised classification as a category 1B carcinogen (H350) became applicable on 1 September 2025 under the 21st ATP, Delegated Regulation (EU) 2024/197. It also carries an IARC Group 2A classification, a Proposition 65 cancer listing since 27 October 2017, and a US EPA draft TSCA risk evaluation released 12 June 2026 that found unreasonable risk to workers and to the environment, with the final evaluation still pending; a planned addition to RoHS Annex II was dropped in 2024. EU consumption of TBBPA was recorded at 6,200 tonnes in 2004.
How Do Bisphenols Get Out of a Plastic?#
Bisphenols leave a plastic in three ways: unreacted residual monomer diffuses out, the polymer itself hydrolyses and releases its building blocks, and an additive-type bisphenol such as TBBPA migrates because it was never bound to the chain. The first two routes apply to BPA, BPS, BPF, BPAF and BADGE, because all five are monomers or curing agents rather than additives; the third route is specific to TBBPA in its unreacted, additive form. Migration is the concept EU food-contact law actually regulates: Regulation (EU) No 10/2011 sets an overall migration limit of 10 mg/dm2 and a generic specific migration limit of 60 mg/kg, alongside an Article 19 mechanism for assessing non-intentionally added substances such as residual monomer. Regulation (EU) 2024/3190 layers a verification detection limit of 1 µg/kg on top of that framework specifically for the bisphenols it covers.
Migration into food, and what heat does to polycarbonate#
Polycarbonate hydrolyses above 70 °C when humidity is high, and that reaction breaks the polymer chain at the carbonate group and releases bisphenol A, which is why repeated hot washing and hot filling matter more than storage. The rate of hydrolysis depends on temperature, moisture and the polymer's residual catalyst content, so dishwasher cycles and hot-fill processes are the conditions most likely to push residual and hydrolysis-released BPA into contact with food. Regulation (EU) No 10/2011 already governed this pathway through its overall migration limit of 10 mg/dm2 and generic specific migration limit of 60 mg/kg (60 mg/kg also applies to infant food under the same framework), and the diffusion models used to predict additive migration apply to residual monomers in the same way. Regulation (EU) 2024/3190 now adds a verification detection limit of 1 µg/kg specifically for the bisphenols it prohibits, which is the enforcement tool that makes the food-contact ban checkable at the border and at retail.
How much bisphenol is in people#
Antonia Calafat and colleagues at the US Centers for Disease Control detected bisphenol A in the urine of 92.6 % of 2,517 Americans aged six and over in the 2003-2004 NHANES survey, with the highest concentrations found in children, followed by adolescents, then adults (Calafat et al., Environmental Health Perspectives, 2008). The same survey found a related compound, 4-tert-octylphenol, in 57.4 % of participants. Detection in urine measures exposure, not effect; it shows that BPA reaches the general population through diet and other routes, not that any individual detected level causes harm. The European Food Safety Authority separately found that mean and 95th-percentile dietary BPA exposure in all age groups exceeds its current tolerable daily intake by two to three orders of magnitude, which is the exposure side of the toxicology question addressed in the next section.
Are Bisphenols Harmful? What the Evidence Shows#
Bisphenol A carries a harmonised European classification as toxic for reproduction, category 1B, in force since 23 November 2023, yet the US Food and Drug Administration still considers it safe at the levels found in food, and the gap between those two statements is the whole story of this page. Both agencies reviewed a broadly overlapping literature and reached opposite regulatory conclusions, and both positions are presented here with their own numbers rather than reconciled into a single verdict. BPA also sits on the REACH Candidate List for endocrine-disrupting properties for human health and separately for the environment, grounds that were added on 7 July 2017 and 15 January 2018 respectively. Independent of BPA specifically, Martin Wagner and colleagues at the Norwegian University of Science and Technology, in the PlastChem project (2024), documented more than 16,000 chemicals associated with plastics, of which more than 4,200 are of concern, a hazard screen rather than a measured risk. A 2020 consensus statement by Jane Muncke and 32 co-authors notes that most plastic-associated chemicals lack hazard data and that mixtures of them are rarely assessed together, a gap industry bodies counter by pointing out that hazard identification is not the same as measured exposure risk.
Why EFSA cut the BPA tolerable daily intake 20,000-fold#
The European Food Safety Authority's CEP Panel lowered the tolerable daily intake for bisphenol A from a temporary 4 micrograms per kilogram of body weight per day, set in 2015, to 0.2 nanograms per kilogram of body weight per day in 2023, a 20,000-fold reduction (EFSA Journal 2023;21(4):6857). The critical effect behind the new value is an impact on Th17 immune cells observed in mice, and EFSA derived it from a reference point of 8.2 ng/kg bw/day divided by an overall uncertainty factor of 50. A tolerable daily intake is the amount of a substance a person can consume every day over a lifetime without an appreciable health risk, and EFSA's own dietary exposure assessment found that mean and 95th-percentile exposure in every age group it examined exceeds the new 0.2 ng/kg bw/day value by two to three orders of magnitude, the finding that led the Panel to conclude there is a health concern.
Why the US FDA still calls BPA safe in food#
The US Food and Drug Administration states that bisphenol A is safe at the current levels occurring in foods, a position it reached after reviewing more than 300 studies between 2009 and 2013 and running the CLARITY-BPA research programme with the National Toxicology Program. The FDA has not reversed that safety determination since. It did remove the authorisation for polycarbonate baby bottles and sippy cups in July 2012, and for BPA-based epoxy resin in infant formula packaging in July 2013, but both removals were abandonment decisions, made because manufacturers had already stopped using BPA in those specific applications, not findings of new safety concerns; how the underlying 21 CFR clearance system works is explained under FDA food contact rules. A petition asking the FDA to revisit its BPA determination remains pending under docket FDA-2022-F-1108.
Is BPS safer than BPA, or a regrettable substitution?#
The evidence does not support calling bisphenol S safer: it carries the same endocrine-disruption and reproductive-toxicity grounds on the REACH Candidate List as bisphenol A, and California added it to the Proposition 65 list three times between December 2023 and December 2025. Registrants notify BPS with GHS classifications including H360FD in 49 % of recorded PubChem notifications, comparable in kind, though not identical in coverage, to BPA's own harmonised classification, and BPAF is separately notified as H360F. Regulation (EU) 2024/3190 covers hazardous bisphenols as a group precisely to close off this move from one restricted substance to a close structural relative with a similar hazard profile, rather than allowing the ban to be worked around one molecule at a time. The pattern has a name: regrettable substitution.
The EU Bisphenol Ban: Regulation (EU) 2024/3190#
Regulation (EU) 2024/3190 prohibits bisphenol A and other hazardous bisphenols in materials that touch food, it has been in force since 20 January 2025, and since 20 July 2026 articles containing them may no longer be placed on the EU market except under two narrow derogations. The regulation was published in the Official Journal on 31 December 2024 and deletes bisphenol A (FCM 151) and bisphenol S (FCM 154) from Table 1 of the Union list annexed to Regulation (EU) No 10/2011. The declaration, verification and derogation mechanics that follow from the ban are set out under EU bisphenol rules.
| Date | Jurisdiction | Instrument or action | What changed |
|---|---|---|---|
| 12 Jan 2017 | EU | REACH Candidate List | BPA added (SVHC) |
| 27 Oct 2017 | US (California) | Proposition 65 | TBBPA listed as a carcinogen |
| 7 Jul 2017 | EU | CLP harmonised classification | Endocrine-disruption ground added for BPA, human health |
| 15 Jan 2018 | EU | CLP harmonised classification | Endocrine-disruption ground added for BPA, environment |
| 8 Jul 2021 | EU | REACH Candidate List | Bisphenol B added (SVHC) |
| 17 Jan 2023 | EU | REACH Candidate List | BPS and TBBPA added (SVHC) |
| 23 Nov 2023 | EU | CLP Annex VI (ATP18) | BPA harmonised Repr. 1B (H360F) becomes applicable |
| 29 Dec 2023 | US (California) | Proposition 65 | BPS listed, female reproductive toxicity |
| 31 Dec 2024 | EU | Regulation (EU) 2024/3190 | Published in the Official Journal |
| 20 Jan 2025 | EU | Regulation (EU) 2024/3190 | Enters into force |
| 1 Sep 2025 | EU | CLP Annex VI (21st ATP) | TBBPA harmonised Carc. 1B (H350) becomes applicable |
| 8 Dec 2025 | US (California) | Proposition 65 | Third BPS listing, developmental toxicity |
| 12 Dec 2025 | EU | Toy Safety Regulation (EU) 2025/2509 | Published in the Official Journal |
| 1 Jan 2026 | EU | Toy Safety Regulation (EU) 2025/2509 | Enters into force |
| 4 Feb 2026 | EU | REACH Candidate List | BPAF and its salts added (SVHC), list reaches 253 entries |
| 23 Apr 2026 | EU | ECHA registry of intention | Intention registered to restrict endocrine-disrupting bisphenols for the environment (pending) |
| 12 Jun 2026 | US (EPA) | TSCA draft risk evaluation | TBBPA draft published, final pending |
| 20 Jul 2026 | EU | Regulation (EU) 2024/3190 | Main transition ends |
| 20 Jan 2028 | EU | Regulation (EU) 2024/3190 | Extended transitions end |
| 20 Jan 2029 | EU | Regulation (EU) 2024/3190 | Repeat-use articles must be off the market |
| 1 Aug 2030 | EU | Toy Safety Regulation (EU) 2025/2509 | Regulation applies |
Pending items are marked as such and are not obligations.
What the ban covers and which deadline applies to what#
The prohibition covers every material group that touches food, not just plastics: varnishes and coatings, printing inks, adhesives, ion-exchange resins, rubbers and silicones fall under it as well, alongside food-contact plastics. Three deadlines govern when an article had to leave the market:
- Single-use and repeat-use articles could be placed on the market until 20 July 2026.
- Articles used for fruit, vegetable and fishery-product preservation, exterior-only metal coatings and professional food-production equipment had until 20 January 2028.
- Repeat-use articles already on the market must be withdrawn by 20 January 2029, with filling permitted for 12 months after the relevant placing date.
Two Annex II derogations remain available, both conditional on migration not being detectable: BPA as a monomer for polysulfone filtration membrane assemblies, and BPA for liquid epoxy resins applied to self-supporting food-contact articles with a capacity above 1,000 litres. Outside those two narrow cases, FCM 151 and FCM 154 were deleted from the Union list of EU 10/2011, which removes the legal basis for using BPA or BPS in food-contact plastics.
Bisphenols on the Candidate List, in toys and on Proposition 65#
Four bisphenols sit on the REACH Candidate List of substances of very high concern: bisphenol A since 12 January 2017, bisphenol B since 8 July 2021, bisphenol S since 17 January 2023 and bisphenol AF and its salts since 4 February 2026, which took the full Candidate List to 253 entries. Every listed plastic additive is tabulated on SVHC Candidate List.
| Bisphenol | EU food contact | REACH Candidate List | EU harmonised classification | US Proposition 65 | Other |
|---|---|---|---|---|---|
| BPA | Banned (Reg. (EU) 2024/3190) | SVHC since 12 Jan 2017 | Repr. 1B, H360F, applicable 23 Nov 2023 | Female reproductive since 11 May 2015; developmental since 18 Dec 2020 | Toy Safety Regulation Part D; migration limit 0.005 mg/L in toys |
| BPS | Banned (Reg. (EU) 2024/3190) | SVHC since 17 Jan 2023 | No entry in our source library (harmonised) | Female reproductive 29 Dec 2023; male reproductive 3 Jan 2025; developmental 8 Dec 2025 | Notified H360FD in 49 % of PubChem notifications |
| BPF | Banned (Reg. (EU) 2024/3190) | No entry in our source library | No entry in our source library | No entry in our source library | No entry in our source library |
| BPAF | No entry in our source library | SVHC since 4 Feb 2026 | No entry in our source library | No entry in our source library | Notified H360F |
| BADGE | Banned (Reg. (EU) 2024/3190) | No entry in our source library | No entry in our source library | No entry in our source library | No entry in our source library |
| TBBPA | Not covered (not a food-contact use) | SVHC since 17 Jan 2023 | Carc. 1B, H350, applicable 1 Sep 2025 | Cancer listing since 27 Oct 2017 | IARC Group 2A; TSCA draft risk evaluation 12 Jun 2026, final pending |
Status as verified on 22 September 2026. The Candidate List is updated in January and June.
Toys add a fifth, separate instrument to the matrix above. The Toy Safety Regulation (EU) 2025/2509 was published on 12 December 2025, entered into force on 1 January 2026 and applies from 1 August 2030; it prohibits the 10 bisphenols listed in Appendix Part D and sets a BPA migration limit of 0.005 mg/L in polymeric toy materials, while its recital separately names 34 ECHA-identified bisphenols as candidates ECHA may add later. The additive rules for toys are set out on EU Toy Safety Regulation.
The 23 April 2026 registry of intention to restrict endocrine-disrupting bisphenols for the environment remains a registered intention, not yet a proposal or a restriction, and the US EPA's 12 June 2026 TBBPA risk evaluation is a draft with the final evaluation still pending.
What the Bisphenol Rules Change for Plastic Formulators#
For anyone who formulates or buys plastics, the bisphenol rules change four things, and only one of them is about an additive. Food-contact articles that still rely on polycarbonate or a bisphenol-based epoxy are the most exposed, because Regulation (EU) 2024/3190 removes the monomer itself from the market, not a substitutable additive.
- Check whether any food-contact article in the portfolio still uses polycarbonate or a bisphenol-based epoxy resin.
- Re-specify the polymer, not the additive, because the bisphenol is the monomer; copolyesters, polypropylene, PET and glass are the substitute materials used for rigid transparent food-contact articles, and the bottle-grade alternative and its own additive package are on additives for PET resin.
- Re-check the flame-retardant package anywhere TBBPA or a brominated epoxy oligomer is used, against the harmonised carcinogen classification that has applied since 1 September 2025, since that classification is driving substitution towards halogen-free systems.
- Record the substitution in the declaration of compliance, because the verification limit that regulators use to check it is a detection limit of 1 µg/kg.
Formulators should treat this as a polymer-selection problem first and an additive-selection problem second, since only about 6 % of plastic-associated chemicals are regulated internationally and the bisphenol group is one of the few with a hard EU deadline already behind it. The compliant package by application is on additives for food packaging, and every flame retardant named above has a full regulatory matrix in the plastic additives database.
─── CONTEXTUAL BORDER ───
Bisphenols Outside Plastics, and the Questions People Ask#
Most of the public debate about bisphenols is about materials this reference does not cover: till receipts on thermal paper, the epoxy lacquer inside food cans and dental composites are not plastics in the sense used here. Bisphenols are one group among the endocrine disruptors in plastics that this reference tracks, and the full list of chemicals of concern across every group is on toxic plastic additives.
The other large consumer question about plastic chemistry that this reference answers separately is phthalates: health effects, a sibling chemical class with its own migration and regulatory profile.
Thermal paper, can coatings and dental resins#
Bisphenol S is used as a developer in thermal paper, bisphenol A and bisphenol F build the epoxy lacquers that line food cans, and both uses fall under Regulation (EU) 2024/3190 even though neither material is a plastic. Dental composite resins are a separate, medical application built on related chemistry. Washington State's Safer Products for Washington programme restricts bisphenols in can linings and thermal paper from 1 January 2025, a rule that runs alongside, not instead of, the EU's food-contact prohibition.
Do bisphenols come back through recycled plastic?#
Our source library holds no measured bisphenol concentration in recycled plastic, so this page states the mechanism and not a number: polycarbonate and epoxy carry their monomer in the chain, and recycling returns whatever the chain releases. The closest documented analogue is a different chemical group: Helene Wiesinger and colleagues at ETH Zurich found regulated chemicals above 0.1 wt% in 16 % of 151 new PVC floorings sampled on the Swiss market in 2024, mainly lead and DEHP, not bisphenols. That finding cannot be transferred to bisphenols without its own measurement; the documented cases for legacy chemicals in recycled plastic are on legacy additives in recycled plastic.
Is BPA-free plastic safe?#
"BPA-free" has no legal definition in the EU or the US: it means that bisphenol A was not intentionally used, not that the article contains no bisphenol and not that the substitute is better characterised. The most common substitute, BPS, carries comparable notified hazard classifications to BPA itself, and the common replacement materials for rigid transparent articles are copolyesters, polypropylene, PET and glass rather than another bisphenol. What actually replaces BPA, and whether it is safer, is worked through on BPA-free plastic.
Is BPA harmful to touch?#
The skin-contact question is about till receipts rather than plastics: bisphenols in a moulded plastic article are either bound into the polymer or present as traces, and our source library holds no dermal-transfer figure for a plastic surface. Population-wide biomonitoring shows widespread BPA exposure without attributing it to any single route, including skin contact.
Which countries and US states have restricted BPA?#
The European Union has the broadest restriction: bisphenol A is prohibited in food-contact materials under Regulation (EU) 2024/3190. California lists BPA under Proposition 65 for female reproductive toxicity since 11 May 2015 and for developmental toxicity since 18 December 2020, and Washington State restricts bisphenols in can linings and thermal paper from 1 January 2025 under its Safer Products programme. There is no federal US ban on BPA; this reference verifies restrictions for the EU, California and Washington only, and this list should not be read as a complete global count.