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A BPA Free EU: What Packaging & Film Manufacturers Need to Do to Meet Upcoming Regulations
Uncover the complexity of the material transition, your key milestones and how to take action
The EU has banned bisphenol A (BPA), a chemical long relied upon in packaging and film applications, forcing the industry to find new materials to replace it. Commission regulation (EU) 2024/3190 took effect in January 2025, and as of July 2026, the 18-month transition period comes to a close — the primary deadline by which single- and repeat-use food contact materials must comply. Read on to uncover the challenges ahead, milestones to meet and where to start.
Material Selection Challenges When Replacing BPA
Replacing BPA is not a simple materials swap. The regulation also bans other hazardous bisphenols — including Bisphenol S (BPS) and Bisphenol AF (BPAF) — specifically to prevent manufacturers from replacing BPA with similarly problematic chemistry, meaning any alternative must clear the same rigorous safety bar.
Beyond regulatory compliance, manufacturers must also maintain the resistance, durability, and mechanical integrity of the final application — and in many cases, adapt their production lines.
 
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“What we're seeing across the industry is that the manufacturers who start their transition early are the ones who gain the most — not just in compliance, but in building stronger, more future-ready supply chains. Our role is to bring the technical know-how and the right supplier partnerships to make that transition as smooth as possible.” |
Key Milestones to Meeting the BPA Ban Timeline
Although many of the dates for the European Commission's BPA ban for food contact applications might appear distant, don't be misled. Reformulating materials, qualifying alternatives, updating supply chains, and meeting compliance documentation requirements all take significant time. Starting early is not just advisable; it's critical.
- 20 July 2026 — Single- and repeat-use food contact applications can no longer be placed on the EU consumer market.
- 20 July 2027 — End of 12-month sell-through period for consumer market BPA based articles placed before July 20, 2026.
- 20 January 2028 — Extended deadline for specific single-use articles and professional food processing equipment.
- 20 January 2029 — End of 12-month sell-through period for professional food processing equipment. The full market will be converted to BPA free materials.
Where to Start With Your BPA Free Material Transition
With the 2026 deadline fast approaching, the time to act is now. Here's where to start:
- Audit all food contact materials in your supply chain for BPA content
- Request Declarations of Compliance from your suppliers — required since January 2025
- Identify which products fall under the July 2026 deadline vs. the extended 2028 timeline
- Evaluate BPA free alternative materials by application and performance requirements
- Run migration testing under relevant food contact conditions to substantiate compliance
- Align with upstream chemistry suppliers on reformulation timelines
- Brief downstream brand customers on your transition plan and timeline
Explore BPA Free Alternatives
No matter where you are in the process, IMCD is here to support you with the technical and regulatory insights you need. Check out our next article to uncover a product that could be your solution to BPA free applications. → Continue to the next article
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