The Blog

Most companies think bisphenol A is a food packaging problem.

It is not. Not anymore.

Germany has submitted a REACH restriction dossier to ECHA covering BPA and a wider group of bisphenols with similar environmental effects. The regulatory direction has shifted from substance-by-substance management to group-based control.

The question for industry is not whether this affects you.
It is whether you know where bisphenols sit in your products, raw materials and supply chain before the obligation lands.

Sectors Impacted

Bisphenols are not limited to one industry. Exposure is hidden across value chains:

• Polymers and resins — epoxy systems, polycarbonate, engineering plastics
• Coatings and adhesives — including functional coatings in articles
• Electronics and composites — structural and insulation materials
• Thermal applications — heat-resistant linings, paper receipts
• Packaging and food contact — already restricted under Regulation (EU) 2024/3190
• Automotive and construction — sealants, surface treatments, structural bonds
• Consumer articles — toys, textiles, medical devices where bisphenol content may be untracked

If your products or imports contain polymers, resins or functional coatings, the exposure question is worth asking now.

Regulatory Signals and Downstream Obligations

What is already moving — and where it is heading:

• Germany has submitted a REACH restriction dossier targeting BPA and structurally similar bisphenols as a group, pointing toward group-based control under REACH Annex XVII.
• BPA and other hazardous bisphenols are already restricted in food contact materials under Commission Regulation (EU) 2024/3190, in force now.
• A group restriction, if adopted, would extend obligations across the supply chain: supplier declarations, article content screening under REACH Article 33, reformulation requirements and customer notifications.
• Derogation windows may apply to specific uses, but derogation arguments built late rarely succeed.

Regulatory momentum: High. Time for comfortable preparation: narrowing.

How REACHLaw Can Support You

We help you understand what this means for your business — before it becomes urgent.

REACHLaw’s Substance Risk Map translates the bisphenol regulatory signal into a management-ready assessment for your specific products, uses and supply chain.

We cover:

• Current regulatory status and next milestones
• Scope of concern across the bisphenol group
• Business exposure screening across products, articles and raw materials
• Risk ranking by urgency and business relevance
• Priority actions for procurement, R&D, regulatory and product teams

With nearly two decades of experience in REACH restriction and authorisation processes, REACHLaw has prepared more than 50 impact assessments — including socio-economic analyses supporting REACH restriction processes at ECHA level.

Contact us to find out what the bisphenol signal means for your portfolio at sales@reachlaw.fi.