EU REACH Bisphenol Restriction Proposal: BPA, BPS, BPF and BPAF Compliance Risks for Exporters

Key Takeaways for EU Market Suppliers

• The proposal targets a group of bisphenols, including Bisphenol A (BPA), Bisphenol B (BPB), Bisphenol S (BPS), Bisphenol F (BPF), Bisphenol AF (BPAF) and related salts.

• The regulatory focus is on bisphenols with environmental endocrine-disrupting properties and uses with potential environmental release.

• Sectors likely to face compliance relevance include plastics and PVC compounds, thermal paper, textiles, leather and recycled plastic streams.

• Companies using BPS or BPF as BPA substitutes should reassess these strategies, as the new proposal may bring these alternatives within the same regulatory framework.

• EU food contact material rules are already mandatory under Commission Regulation (EU) 2024/3190 and should be handled separately from the REACH restriction process.

Why the EU Is Moving Toward a Group-Based Bisphenol Restriction

Historically, EU regulation has often addressed bisphenols individually. Germany's renewed 2026 restriction intention represents a more preventive approach: instead of restricting one bisphenol and allowing the market to shift to structurally similar alternatives, regulators are seeking to address a wider group of substances with comparable environmental concerns.

This approach is designed to reduce the risk of "regrettable substitution", where one restricted substance is replaced with another substance that performs a similar function but may pose similar hazards. The German REACH-CLP-Biozid Helpdesk previously stated that the 2022 proposal aimed to reduce environmental emissions from mixtures and articles containing several bisphenols and that other bisphenols of similar concern should be addressed to avoid such substitution.

For exporters, this means bisphenol compliance should not be managed only through a single-substance BPA checklist. Companies should also review structurally similar bisphenol alternatives, substance groups, material applications and downstream uses across their EU supply chains.

Bisphenols Covered by the Current Restriction Intention

The current proposal may also include a mechanism allowing additional bisphenols identified at EU level as environmental endocrine disruptors to be brought into scope without a separate full restriction procedure for each substance. This makes early substance mapping particularly important for companies using bisphenol-based intermediates, additives or polymer systems.

Sectors and Products Likely to Be Affected

Plastics, PVC and Polymer Systems

Manufacturers and converters of plastics should review whether bisphenols are present as monomers, residual monomers, stabilizers, antioxidants, intermediates or components of resin systems. Potentially relevant applications include:

• PVC articles and PVC-based compounds;

• Construction profiles, pipes, cables and coated textiles;

• Polycarbonate materials;

• Epoxy resin systems;

• Plastic additives and processing aids.

Thermal Paper

BPS became a common substitute after the EU restricted BPA in thermal paper. The new group-based approach may reduce the viability of BPS-based substitution strategies and accelerate the transition toward fully bisphenol-free developer systems.

Recycled Plastics and Secondary Material Streams

Recycled plastics may contain legacy bisphenol contamination from previous uses in thermal paper, electrical and electronic equipment, coatings or other consumer and industrial products. Companies using PCR or PIR materials should establish incoming material specifications, supplier declarations and testing plans to manage potential contamination risks.

Textiles and Leather

Textile finishing and leather processing may involve bisphenol derivatives in certain functional treatments, coatings or tanning formulations. If adopted, the restriction could create enforceable requirements for sectors where bisphenol controls have historically been less direct.

Indicative Regulatory Timeline

All dates after dossier submission are indicative. Companies should avoid treating 2028–2030 as a confirmed compliance deadline. A more accurate interpretation is that 2026–2027 is the evidence-gathering and substitution-planning window, while binding REACH obligations will depend on the final Annex XVII amendment.

Separate Immediate Obligation: EU Food Contact Materials

Companies supplying food contact materials or articles to the EU must also address Commission Regulation (EU) 2024/3190, which is separate from the REACH restriction intention. From 20 January 2025, the EU prohibits the use and trade of BPA, its salts and other hazardous bisphenols and hazardous bisphenol derivatives in food contact materials, subject to specific derogations and transition periods.

Key Transition Dates: FCM compliance is an immediate mandatory obligation, not a future REACH planning issue. Companies should have already taken action by now.

Key transition dates include:

• 20 July 2026 — most single-use and repeat-use final food contact articles that complied with the previous rules may no longer be used as professional food production equipment after this date.

• 20 January 2028 — specific single-use final food contact articles and repeat-use professional food production equipment that complied with the previous rules may no longer be first placed on the EU market after this date.

• Additional sell-through or continued market availability periods may apply depending on article type and whether the product is single-use or repeat-use.

For exporters of packaging, coatings, food-processing equipment, adhesives, printing inks, rubbers, silicones, plastics, ion-exchange resins or varnishes, FCM compliance should be treated as an immediate mandatory obligation, not as a future REACH planning issue.

Compliance Actions for Manufacturers, Importers and Exporters

1. Build a Bisphenol Substance Inventory

Identify whether BPA, BPB, BPS, BPF, BPAF or related bisphenols are present in:

• raw materials;

• intermediates;

• additives and processing aids;

• coatings, inks and adhesives;

• polymer systems;

• finished articles;

• recycled material streams.

The inventory should cover both intentionally used substances and potential residual or legacy contamination.

2. Reassess BPA Substitution Strategies

Companies that replaced BPA with BPS, BPF or other structurally similar bisphenols should not assume these alternatives will remain acceptable in the EU market. Substitution plans should prioritize technically suitable alternatives with lower regulatory risk.

3. Strengthen Supplier Declarations and Traceability

EU customers are likely to request more detailed information on bisphenol content before the restriction is finalized. Exporters should prepare updated supplier questionnaires, material declarations, formulation reviews and testing records.

4. Prepare for the 2027 Public Consultation

The 2027 Annex XV dossier consultation may be the most important opportunity for industry to submit evidence. Companies seeking derogations or transition periods should prepare data on:

• technical feasibility of substitution;

• availability and performance of alternatives;

• socio-economic impacts;

• emissions and exposure scenarios;

• recycling and waste-management implications.

5. Handle FCM Compliance Immediately

Food contact material suppliers should review declarations of compliance, update substance inventories, confirm applicable derogations and conduct testing where needed. The FCM rules are already in force and should not be delayed until the REACH restriction process is finalized.

How REACH24H Can Help

REACH24H supports manufacturers, formulators, importers and exporters in assessing bisphenol-related compliance risks under EU chemical and food contact material regulations.

Our services include:

• bisphenol substance screening across formulations, materials and articles;

• REACH restriction impact assessment and compliance roadmapping;

• supply chain data collection and supplier declaration review;

• recycled material risk assessment and testing strategy support;

• monitoring of the Annex XV restriction dossier and ECHA consultation process;

• preparation of technical evidence, derogation justifications and socio-economic analysis support;

• EU food contact material compliance support under Regulation (EU) 2024/3190;

• alternatives assessment and substitution strategy review.

For companies supplying plastics, coatings, textiles, leather, thermal paper, packaging or recycled materials to the EU, early preparation can reduce reformulation pressure, customer disruption and future market-access risks.

Final Thoughts

Germany's 2026 REACH restriction intention signals a broader EU regulatory shift toward group-based management of bisphenols with environmental endocrine-disrupting properties. Although the REACH restriction has not yet been adopted, companies should use the 2026–2027 period to map bisphenol use, reassess substitution strategies and prepare evidence for future consultation.

At the same time, suppliers of EU food contact materials must manage Commission Regulation (EU) 2024/3190 as an immediate, separate obligation. Companies that treat REACH and FCM rules as two connected but distinct compliance workstreams will be better positioned to reduce regulatory disruption and maintain EU market access.

Recommended Reading

• Regulatory Risk Management of EU REACH: A Deep Dive into CLH, SVHC, Authorization, and Restriction

• ECHA Publishes Updated Restriction Proposal for PFAS under REACH

• Updates on Restrictions of Bisphenol A, DecaBDE and PFOA and Two Opinions for Authorisation

• EU REACH Annex XVII Adds DMAC and NEP: New Restrictions and Compliance Strategies

• EU REACH Registration & OR Services

• EU Food Contact Materials Compliance Services

Official References

• ECHA: Registry of Restriction Intentions - Bisphenols

• Regulation (EC) No 1907/2006 concerning REACH

• ECHA: Restrictions under REACH

• ECHA: Substances Restricted under REACH

• Commission Regulation (EU) 2024/3190 on bisphenol A and other bisphenols in food contact materials

• European Commission: Food Contact Materials