Consequences of the ban on the intentional use of bisphenol A in food contact materials announced by DG Santé
In July 2023, at a stakeholder webinar, the EU’s Directorate-General for Health and Food Safety (DG Sante) announced a ban on the intentional use of bisphenol A (BPA) and potentially several other bisphenols. This ban is due to come into force at the beginning of 2024, with a transition period of 18 months. This ban should have an impact on the metal packaging sector, particularly through varnishes and coatings containing the targeted bisphenols.
In France, the intentional use of BPA has been banned since 1 December 2015. The ban prompted research and development of alternatives to epoxy-phenolic coatings containing BPA. Food contact material (FCM) manufacturers have made huge efforts to develop alternative coatings. However, the chemistry of new coatings applied to the internal surfaces of metal FCMs is poorly documented. As a result, the potential hazard of chemicals migrating into foodstuffs is also unknown.
The lack of knowledge about these new types of coating, which have a shorter research history, tends to make compliance with the regulations more complex, particularly where NIAS (non-intentionally added substances) are concerned. Until now, regulations have focused mainly on the control of intentionally added substances (IAS), but the safety of FCMs in the form of final articles is becoming increasingly important. More attention is now required for controlling the risks associated with NIAS (impurities, neoformed substances, contaminants, etc.).
A new risk assessment approach for MCDA
The collaborative work of over 20 scientists, which was published on 26 September 2023, has highlighted the need for a new conceptual approach to go beyond current risk assessment procedures for FCMs.
The authors propose to evaluate real-life mixtures, migrating (or extractable) from final articles in contact with food. This proposition includes all knowns (IAS) and unknowns (NIAS). If the result of the toxicological assessment of the mixture is positive, modern analytical techniques should be applied to elucidate it’s chemical composition, including the NIAS, in order to identify the substances responsible for the toxicity as a whole.