Views: 0 Author: Site Editor Publish Time: 2026-09-01 Origin: Site
EU Regulation (EU) 2024/3190, in force since 20 January 2025, comprehensively bans bisphenol A (BPA) and its salts in food contact varnishes, coatings, plastics, adhesives, rubber, printing inks and silicone, at a 1 μg/kg (1 ppb) detection limit. For sheet metal coating manufacturers and brand owners exporting to the EU, this means one clear action: replace epoxy-based coating systems with waterborne acrylic, pure polyester or fluorocarbon systems (with zirconium pretreatment) before the 20 July 2026 single-use deadline.
If your product is a metal food can, beverage can, air fryer inner pot, rice cooker inner pot, oven interior, coffee machine water tank or food processor bowl, this regulation directly applies to you — and the transition window is closing.
On 31 December 2024, the European Commission published Regulation (EU) 2024/3190, implementing a comprehensive ban on bisphenol A (BPA) in food contact materials. It expands the scope of the previous (EU) 2018/213 — which restricted BPA only in polycarbonate plastics and epoxy resins — to cover all food contact varnishes, coatings, plastics, adhesives, rubber, printing inks and silicone.
The ban applies not only to BPA itself, but to the following substances:
BPA and its salts (including sodium salts)
BPS (Bisphenol S)
BPF (Bisphenol F)
BPAF (Bisphenol AF)
All bisphenol substances classified as CLP Category 1A or 1B CMR (carcinogenic, mutagenic, reproductive toxicant) or ED (endocrine disruptor)
Date | Event | Impact |
|---|---|---|
2024.12.31 | (EU) 2024/3190 published in EU Official Journal | Regulation established |
2025.01.20 | Regulation enters into force | Newly produced FCMs must comply |
2025.12.17 | EU Commission publishes C/2025/6721 implementation guidance | Clarifies 1 μg/kg detection limit, full-chain DoC requirements |
2026.07.20 | Single-use food contact articles deadline | Metal cans, packaging must complete BPA-free transition |
2026.09.02 | GB 4806.10-2025 effective (China) | China tightens BPA migration limit from 0.6 to 0.05 mg/kg |
2028.01.20 | Special single-use articles deadline | Fruit/vegetable/aquatic packaging, BPA-containing outer coatings |
2029.01.20 | Reusable articles inventory clearance | Professional food production equipment final deadline |
In sheet metal coating processes, BPA primarily originates from two sources:
BADGE-type epoxy resin primers — Bisphenol A Diglycidyl Ether (BADGE) is the most commonly used metal primer resin system. Its excellent metal adhesion and corrosion resistance make it the preferred choice for can linings and appliance interior coatings. However, BADGE resins inevitably contain residual BPA monomer, creating the highest migration risk.
Epoxy-polyester hybrid powder coatings — Some powder coatings use epoxy-polyester hybrid systems (with a BPA-containing epoxy component) for outdoor equipment and appliance exterior coating.
Some suppliers claim that using BPF (Bisphenol F) or BPAF (Bisphenol AF) to replace BPA constitutes "BPA-free." This is incorrect. EU 2024/3190 explicitly includes BPF and BPAF in the ban. Under CLP classification, BPF is a Category 1B reproductive toxicant and endocrine disruptor; BPAF is similarly classified. Therefore, using BPF to replace BPA does NOT equal BPA-free and remains non-compliant. When verifying supplier claims, require an explicit declaration of no BPA / BPS / BPF / BPAF.
True BPA-free alternative systems should contain zero bisphenol substances. Three mature alternative pathways exist for sheet metal coating:
Alternative System | Key Characteristics | Best Application | Recommended Pretreatment |
|---|---|---|---|
Waterborne Acrylic | Low VOC, cross-cut adhesion Grade 0, cost-effective | Appliance interiors, general industrial | Zirconium conversion (陶化) |
Pure Polyester Powder | Zero VOC, excellent weatherability, salt spray 1000h+ | Outdoor equipment, lighting, appliance exteriors | Zirconium or chromate |
Fluorocarbon | Superior corrosion resistance, salt spray 2000h+, highest cost | Chemical equipment, marine | Zirconium |
On 2 September 2026, China's national standard GB 4806.10-2025 ("Food Safety National Standard — Food Contact Coatings and Coating Layers") takes effect. This standard tightens the BPA migration limit from 0.6 mg/kg to 0.05 mg/kg — a 12-fold reduction.
While China's limit (0.05 mg/kg = 50 μg/kg) remains 50× less strict than the EU's (1 μg/kg), the direction is clear: China is accelerating convergence with the strictest international standards. Export manufacturers must comply with EU standards; domestic manufacturers should also prepare early, as GB standards will likely tighten further.
Under EU 2024/3190, the procurement party (brand owner/importer) bears primary compliance responsibility and must obtain the following from suppliers:
Declaration of Compliance (DoC) — Must include manufacturer information, coating system description, applicable regulation (EU 2024/3190), test report number, and usage condition restrictions.
CNAS/CMA-accredited laboratory migration test report — Per EN 13130 or GB 31604.5 methods, detection limit ≤1 μg/kg.
Coating supplier's BPA-free declaration — Must explicitly state no BPA/BPS/BPF/BPAF or any CLP 1A/1B bisphenol substances.
Batch consistency proof — Each shipment should include a test summary or consistency declaration.
A: All metal products with food-contact varnishes or coatings are affected, including: metal food cans, beverage cans, air fryer inner pots, rice cooker inner pots, oven interiors, coffee machine water tanks, food processor bowls, etc. Non-food-contact industrial coatings (e.g., equipment enclosures, sheet metal chassis non-food-contact parts) are not covered by this regulation. However, if a product may potentially contact food, we recommend using BPA-free systems throughout.
A: After 20 July 2026, single-use food contact articles (metal cans, packaging) must not contain BPA. After 20 January 2028, special single-use articles (fruit/vegetable/aquatic packaging, BPA-containing outer coatings) must also transition. After 20 January 2029, reusable article inventory (e.g., professional food production equipment) must be cleared. We strongly recommend completing the transition before July 2026 to avoid compliance risk.
A: No. This is a common misconception. EU 2024/3190 explicitly bans BPF, BPAF, BPS and all CLP 1A/1B bisphenol substances — not just BPA. BPF (Bisphenol F) is classified as a CLP Category 1B reproductive toxicant and endocrine disruptor and is explicitly included in the ban. Using BPF to replace BPA and claiming "BPA-free" is non-compliant. True BPA-free products must contain zero bisphenol substances.
A: 1 μg/kg (1 ppb — one part per billion) means BPA migration into food simulant must not exceed 1 microgram per kilogram. This is an extremely low detection limit requiring high-precision instruments. Testing follows EN 13130 series (EU) or GB 31604.5 (China, identical IDT to EN 13130), using HPLC-MS/MS or GC-MS. Only reports from CNAS- or CMA-accredited laboratories are recognized.
A: Five key differences: (1) Migration limit — EU 1 μg/kg vs China 50 μg/kg, EU is 50× stricter; (2) Banned substances — EU bans BPA+BPS+BPF+BPAF+all CLP 1A/1B bisphenols, China restricts BPA only; (3) Test method — EN 13130 and GB 31604.5 are identical (IDT); (4) Enforcement — EU July 2026, China September 2026; (5) Scope — EU covers varnishes/coatings/plastics/adhesives/rubber/inks/silicone, China covers food contact coatings. Export manufacturers should comply with EU standards, which automatically satisfies Chinese requirements.
A: If you can complete the transition before July 2026, start immediately with this 6-step roadmap: (1) Confirm whether your current coating contains BPA (request the coating supplier's MSDS and BPA content declaration); (2) Select an alternative system (waterborne acrylic + zirconium pretreatment recommended for appliance interiors); (3) Run small-batch process validation; (4) Submit finished products to a CNAS lab for migration testing; (5) Issue the DoC; (6) Transition to mass production. DINGPRECISION completed a similar transition for an air fryer client in 30 days — BPA residue dropped from 15–30 mg/kg to non-detectable.
The EU 2024/3190 BPA ban is no longer a future regulation — it is already in force, and the single-use deadline (July 2026) is imminent. Manufacturers that wait risk blocked shipments, customs detentions and compliance liability. The proven path is clear: switch to zero-bisphenol coating systems (waterborne acrylic / pure polyester / fluorocarbon) with zirconium pretreatment, secure a CNAS/CMA migration test report and issue a full-chain DoC.
DINGPRECISION (Dingyi Industrial) is a sheet metal fabrication and surface treatment solutions provider and a BPA-free coating pioneer. With a zirconium pretreatment line, two-spray two-bake coating line, and CNAS/CMA testing capabilities, DINGPRECISION has achieved mass production of BPA-free air fryer inner coatings in a 30-day transition. Full in-house process chain (laser cutting → bending → welding → coating, no outsourcing)
