Germany submitted a REACH restriction intention to the European Chemicals Agency (ECHA) on 23 April 2026 for bisphenols with environmental endocrine-disrupting properties. The corresponding Annex XV restriction dossier is expected on 12 March 2027, after which the proposal will enter the formal ECHA restriction process, including public consultation and assessment by the Risk Assessment Committee (RAC) and the Committee for Socio-Economic Analysis (SEAC). Current public reporting on the ECHA entry confirms the 23 April 2026 submission date and the expected 12 March 2027 dossier date.
For companies supplying chemicals, mixtures, materials or articles to the EU, the key message is clear: this is not yet a REACH ban, but it signals a broader EU move from substance-by-substance control toward a group-based restriction of bisphenols, including BPA alternatives such as BPS and BPF.
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.
Bisphenols Covered by the Current Restriction Intention
| Substance | EC No. | CAS No. | Compliance Relevance |
|---|---|---|---|
| Bisphenol A (BPA) | 201-245-8 | 80-05-7 | Widely used in polycarbonate plastics, epoxy resins and coatings |
| Bisphenol B (BPB) | 201-025-1 | 77-40-7 | Structurally related bisphenol of regulatory concern |
| Bisphenol S (BPS) | 201-250-5 | 80-09-1 | Common BPA alternative, including in thermal paper |
| Bisphenol F (BPF) | 210-658-2 | 620-92-8 | Used in epoxy resin systems and other applications |
| Bisphenol AF (BPAF) | 216-036-7 | 1478-61-1 | Included with related salts; also relevant in broader PFAS-related discussions |
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
| Milestone | Indicative Timing |
|---|---|
| Restriction intention submitted by Germany | 23 April 2026 |
| Annex XV restriction dossier expected | 12 March 2027 |
| Conformity check | After dossier submission |
| ECHA public consultation | 6-Month consultation after conformity check |
| RAC and SEAC opinion development | Indicative; likely 2027–2029 depending on dossier complexity |
| European Commission decision-making | 2029 or later, subject to ECHA opinions and political process |
| Potential REACH restriction entry into force | Not fixed; to be determined by the final legal text |
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 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.
Not sure where to start? Our regulatory experts are ready to help.
Email: customer@reach24h.com
