BPA restriction proposal and EFSA opinion
REACH restriction of bisphenols
On the 7th of October 2022, the German Federal Environmental Protection Agency in cooperation with the German Federal Institute of Occupational Safety and Health submitted a proposal to restrict uses of bisphenols of which some are key raw materials for epoxy resins, and of bisphenol-containing articles and mixtures that lead to releases of bisphenols to the environment.
On the 21st of August 2023, the German authorities have withdrawn their proposal to restrict bisphenols that have endocrine disrupting properties to the environment from the opinion-making process by ECHA’s scientific committees.
Epoxy Europe positively notes the decision of the German authorities to withdraw the BPA restriction proposal. They plan to rework it and take into consideration the numerous stakeholder comments. Epoxy Europe stays committed in supporting the authorities and ECHA committees in drafting a proportionate restriction measure which equally honors the needs of all stakeholders and supports achieving the European Green Deal objectives.
EFSA opinion on BPA
Epoxy Europe does not support the evaluation methodology employed by EFSA to derive a new Tolerable Daily Intake (TDI) value for Bisphenol A (BPA) and therefore the resulting derived TDI. As such, Epoxy Europe suggests pausing any legally binding implementation until more evidence on the relevance of this TDI for the given regulation is provided.
Revision of food contact materials directive on BPA
The European Directorate for Health and Food safety, DG Sante, detailed in a webinar on the 18th of July 2023 its plans to withdraw BPA from the positive list of the Food Contact Material (FCM) Regulation 10/2011 EU (also referred to as “Plastics Regulation”). The ministry states that, as a conclusion from of the publication of the EFSA Opinion EU, the authorisation of BPA as a monomer in FCM plastic is no longer justified, and a new, lower SML is not practical.
According to DG Sante main targeted applications are (besides polycarbonate) epoxy resins for coatings to line food and drinking cans, metal lids and caps and some large-scale storage tanks, but also inks, adhesives or rummer should be affected. The main impact is expected for plastics, varnishes and coatings.
Unintentional presence of BPA as well as well as articles already on the market (e.g. existing food processing equipment or cans already in commerce) should not be affected. A fixed transition period of 18 months is foreseen for the (first) placing on the market of affected FCM from the date of entry into force. Monitoring and reporting requirements are intended to supplement the ban on intentional use.
METHODS FOR BPA AND BPF MEASUREMENT
These standard operating procedures (SOP) developed by Solvias describe quantitative test methods for the determination of Bisphenol-A (BPA) in liquid (1) and solid (2) epoxy resins by liquid chromatography-mass spectometry (LC/MS). The specific mass of Bisphenol A is measured in the selected ion monitoring mode (SIM -mode).
Method 1: SOP C52.S1593_02 ; method used to determine Bisphenol-A in different BPA-epoxy resins (liquid).
Method 2: CSOP-0724_01 ; method for the determination of Bisphenol-A (BPA) in solid epoxy resins by LC/MS.
Method 3: SOP ; method for the determination of Bisphenol-F (BPF) in liquid epoxy resins
Other epoxy building blocks
BPA RESTRICTION PROPOSAL