BPA Ban in Food Packaging

Bisphenol A (BPA) has been one of the most widely discussed chemicals in food packaging for more than a decade. Used primarily in polycarbonate plastics and epoxy-based coatings, BPA has played an important technical role in packaging systems, particularly in the internal coatings of metal cans, reusable food containers and certain food-contact plastics.

The regulatory landscape is now changing significantly. The European Union has introduced a broad restriction on BPA and certain other hazardous bisphenols in food-contact materials, creating important implications not only for European manufacturers but also for food businesses, packaging suppliers and exporters operating in international markets.

For food manufacturers in Africa, including those supplying products to European markets, the development deserves particular attention because packaging compliance is increasingly becoming part of market-access and food-safety management.

What is BPA?

Bisphenol A, commonly abbreviated as BPA, is an industrial chemical used in the manufacture of certain polymers and resins.

In food packaging, two applications have historically been particularly important.

The first is polycarbonate plastic. Polycarbonate is strong, transparent and resistant to impact, making it useful for certain reusable food and beverage containers.

The second is epoxy-based coatings. BPA-derived epoxy resins have been widely used as protective coatings inside metal cans. These coatings help prevent food from directly contacting the metal surface, thereby reducing corrosion and helping preserve product quality.

The presence of BPA in packaging does not necessarily mean that a package contains large quantities of free BPA. The food-safety concern relates primarily to migration: the movement of chemical substances from packaging into the food under particular conditions of use.

Migration can be influenced by factors such as temperature, contact time, food composition, acidity, fat content and the characteristics of the packaging material.

Why has BPA become a regulatory concern?

The concern surrounding BPA is largely associated with its potential biological activity, including effects involving the endocrine system and reproductive health.

The European Food Safety Authority (EFSA) conducted a comprehensive re-evaluation of BPA and published its scientific opinion in 2023. EFSA established a new tolerable daily intake (TDI) of 0.2 nanograms per kilogram of body weight per day, substantially lower than its previous temporary TDI. EFSA concluded that dietary exposure estimates available for its assessment exceeded this new tolerable level and identified BPA exposure as a health concern across age groups.

This scientific assessment became an important basis for subsequent regulatory action in the European Union.

It is important, however, to recognize that regulatory positions are not identical worldwide. For example, the U.S. Food and Drug Administration currently states that its assessment continues to support the safety of BPA for its approved uses in food containers and packaging, while also continuing to evaluate emerging information.

Therefore, saying simply that “BPA is banned everywhere” would be scientifically and legally inaccurate.

The more accurate conclusion is that BPA regulation is becoming increasingly stringent in several major markets, with the European Union taking one of the most significant steps.

What did the European Union ban?

On 19 December 2024, the European Commission adopted Commission Regulation (EU) 2024/3190 concerning BPA and other bisphenols and bisphenol derivatives with harmonised hazardous classifications in certain food-contact materials.

The regulation entered into force in January 2025 and prohibits the use and trade of BPA, its salts and certain hazardous bisphenols and bisphenol derivatives in specified food-contact applications in the EU.

The measure is broader than a simple ban on BPA-containing plastic bottles.

It covers food-contact materials and articles involving materials such as:

• Plastics

• Adhesives

• Rubbers

• Ion-exchange resins

• Printing inks

• Silicones

• Varnishes and coatings

This is particularly important for the canned-food industry because BPA has historically been associated with epoxy coatings used on the internal surfaces of metal cans.

The EU measure also addresses certain other bisphenols and derivatives classified as hazardous, reflecting a broader regulatory concern rather than simply replacing BPA with another chemically similar substance without evaluating its safety.

The transition period matters

The EU did not require every existing food-contact article to disappear immediately.

The regulation established transitional arrangements to give manufacturers time to reformulate materials, validate alternatives and modify production systems. The European Commission initially described an 18-month phase-out period for most products, with limited exceptions where alternatives were not available.

However, the transitional provisions are application-specific. Certain professional food-production equipment and repeat-use articles have longer transition periods.

For example, EU trade guidance indicates that certain compliant products manufactured under the previous rules could continue to be placed on the EU market under specified transitional conditions, including longer periods for some professional food-production equipment.

This distinction is important for manufacturers. “The BPA ban starts in 2025” does not mean that every BPA-related article becomes illegal on exactly the same day.

Companies need to determine which transitional provision applies to their particular packaging or food-contact article.

What does this mean for food manufacturers?

The regulatory change creates a packaging-management issue rather than simply a purchasing issue.

A food manufacturer cannot rely solely on a supplier's statement that a package is “food grade.” Food-contact compliance is application-specific.

A packaging material must be suitable for the intended food, processing conditions and storage conditions.

For example, a packaging material intended for an acidic beverage may require different chemical-resistance characteristics from packaging intended for a dry snack product. Similarly, a package exposed to retort processing presents a different migration scenario from one used only for ambient-temperature storage.

Manufacturers should therefore consider the following areas.

1. Packaging material specifications

Food companies should identify the materials used in every component that comes into contact with food.

This includes more than the obvious container.

The assessment may need to cover:

• Primary packaging

• Internal can coatings

• Plastic components

• Closures

• Gaskets

• Adhesives

• Printing inks where relevant

• Coatings

• Liners

• Seals

• Processing equipment that may contact food

A packaging specification should identify the material composition and applicable food-contact requirements.

2. Supplier documentation

Supplier declarations should become an important part of packaging control.

Depending on the target market and regulatory framework, companies may need documentation demonstrating compliance with applicable food-contact legislation.

For products intended for the EU market, the relevant regulatory framework should be reviewed alongside supporting technical documentation and, where applicable, a Declaration of Compliance.

The European Commission explains that food-contact compliance documentation provides an important link between material safety and the manufacturer's responsibilities under good manufacturing practice.

3. Migration testing

A “BPA-free” claim alone is not an adequate substitute for a technical compliance assessment.

Migration testing can help determine whether substances from packaging migrate into food or food simulants under defined conditions.

The test conditions should represent the intended application.

Important parameters include:

• Food type

• Food simulant

• Temperature

• Contact time

• Surface-area-to-volume ratio

• Intended shelf life

• Processing conditions

• Storage conditions

For packaging engineers and food technologists, this is where packaging compliance connects directly with food chemistry.

4. Alternative coatings and materials

The removal of BPA creates a technical challenge because BPA-based epoxy systems have historically provided useful properties.

A replacement material needs to provide the required combination of:

• Chemical resistance

• Adhesion

• Corrosion protection

• Mechanical stability

• Thermal resistance

• Processing compatibility

• Low migration

• Shelf-life performance

• Regulatory compliance

Replacing BPA with another chemical solely because it carries a “BPA-free” label is therefore not sufficient.

The replacement itself needs to be evaluated.

This is particularly important because the EU regulation also addresses certain other bisphenols and bisphenol derivatives with hazardous classifications.

BPA-free does not automatically mean safer

This is one of the most important points for the food industry.

A packaging manufacturer may advertise a material as “BPA-free,” but the absence of BPA does not automatically demonstrate that the packaging is safe for every intended application.

The correct technical question is:

“Is the packaging material suitable and compliant for its intended food-contact use?”

rather than simply:

“Does it contain BPA?”

A replacement chemical can have its own toxicological, migration or regulatory considerations.

Therefore, packaging substitution should be managed through a structured change-control process.

Implications for canned foods

The canned-food sector is one of the areas where the change can be particularly significant.

Metal cans require internal protection because direct contact between food and metal can contribute to corrosion and potentially affect product quality.

Historically, epoxy-based coatings containing BPA-derived materials have been widely used for this purpose.

Alternative coating technologies therefore need to provide adequate protection while satisfying the applicable food-contact requirements.

For manufacturers of canned vegetables, fruits, fish, meat products, sauces, beverages and other shelf-stable foods, the coating system should be considered part of the food-contact safety assessment.

Changing the coating can also affect other product characteristics, including:

• Corrosion resistance

• Product shelf life

• Organoleptic properties

• Coating adhesion

• Sterilisation or retort performance

• Can integrity

• Compatibility with acidic or high-fat products

Packaging changes should therefore be validated rather than implemented solely on the basis of supplier marketing claims.

What about Tanzania and African food manufacturers?

For African food manufacturers, the EU development is particularly relevant where products are exported or where packaging materials are sourced from international suppliers.

Tanzania already has a dedicated standard covering packaging materials and articles intended for contact with food.

TBS lists TZS 3335:2024, “Packaging materials and articles in contact with food — General requirements,” as a compulsory standard.

Tanzania's food-manufacturing guidance also requires packaging materials to be safe and suitable for food use and to provide appropriate protection against contamination and damage. It further states that packaging materials should not contain toxic contaminants or pose a threat to food safety under specified conditions of storage and use.

This means that packaging safety should not be treated as a purely export-market issue.

Food businesses operating in Tanzania should maintain control over food-contact packaging as part of their broader food-safety and quality-management systems.

At the same time, companies exporting to the European Union must assess the specific EU requirements applicable to their products and packaging. Compliance with a local requirement does not automatically establish compliance with EU legislation.

A practical BPA risk-assessment approach

Food manufacturers can incorporate BPA and other food-contact chemicals into their existing supplier-approval and packaging-risk assessment systems.

A practical process can begin with five stages.

First, create an inventory of all food-contact packaging materials used by the company.

Second, identify which materials contain, may contain or are manufactured using BPA or other regulated bisphenols.

Third, request updated technical documentation from packaging suppliers, including applicable declarations of compliance, specifications and migration-test information.

Fourth, compare the packaging against the regulatory requirements of every market in which the finished product will be sold.

Fifth, where a packaging change is necessary, conduct a documented validation before full-scale implementation.

The validation should consider not only chemical compliance but also packaging performance and product quality.

What should packaging suppliers do?

Packaging manufacturers should not wait until customers begin asking for “BPA-free” packaging.

They should establish a proactive chemical-compliance programme.

This should include a controlled list of substances used in raw materials, coatings, inks, adhesives and other components.

Supplier changes should be subject to formal notification and approval procedures.

Manufacturers should also maintain traceability between:

raw material → packaging material → production batch → customer → finished food product.

This becomes particularly important when regulatory requirements change and companies need to demonstrate that specific packaging batches comply with new requirements.

What should food companies ask their packaging suppliers?

Instead of asking only “Is this packaging BPA-free?”, procurement and quality teams should consider more technical questions:

1. Is BPA intentionally used in the manufacture of the material or any component?

2. Does the material contain BPA-derived substances or regulated bisphenol derivatives?

3. What food-contact regulations and standards does the material comply with?

4. Is a Declaration of Compliance available where required?

5. Are migration-test results available for the intended application?

6. What food types were used in the migration assessment?

7. What temperature and contact-time conditions were evaluated?

8. Has the formulation changed recently?

9. Will the supplier notify the customer before changing raw materials or manufacturing processes?

10. Is the material suitable for the actual processing conditions used by the food manufacturer?

These questions turn packaging procurement from a simple purchasing activity into a controlled food-safety process.

The BPA restrictions represent a significant development in food-contact-material regulation.

For the European market, the issue is no longer simply whether BPA-containing packaging is technically functional. Manufacturers and suppliers must consider whether their materials comply with the new regulatory requirements, whether transitional provisions apply and whether suitable alternatives have been properly validated.

For African food manufacturers, the development should be viewed as both a regulatory issue and a supply-chain issue. Companies exporting to Europe may face direct compliance requirements, while domestic manufacturers can still benefit from strengthening their food-contact-material controls.

Most importantly, replacing BPA should not become a “chemical substitution” exercise in which one substance is removed without assessing its replacement.

The scientifically sound approach is to evaluate the entire food-contact system: material composition, migration potential, intended food, processing conditions, storage conditions, regulatory requirements and documented supplier controls.

Food packaging is part of the food-safety system. As regulatory scrutiny of food-contact chemicals increases, packaging compliance will become an increasingly important responsibility shared by food technologists, quality professionals, packaging engineers, procurement teams, regulators and packaging manufacturers.

For companies operating in global food markets, the direction is clear: packaging safety needs to be managed proactively, scientifically and with full traceability.

Technical note: Regulatory requirements can change, and the applicability of a particular restriction depends on the material, article, food, intended use and target market. Businesses should verify the current legislation and obtain competent regulatory advice before making compliance or market-access decisions.

Sources: European Commission, Commission Regulation (EU) 2024/3190 and EU food-contact-material legislation; EFSA scientific assessment of BPA; U.S. FDA BPA information; Tanzania Bureau of Standards (TBS) food-contact packaging requirements.