CONSUMER PRODUCTS AND RETAIL E-SSENTIALS

Technical guideline on bisphenol a

july 2018- Relevant for: hardlines, softlines, children's products

What is it?
Bisphenol A (BPA) is a man-made chemical which is used as a building block of hard plastic e.g. polycarbonates (PC). This kind of plastic is used in various consumer products e.g. DVDs, water bottles, baby bottles and tableware, etc. BPA can also be found in epoxy resin as protective coatings for food and beverage cans. In addition, BPA is used as a dye developer in certain thermal paper for tickets or receipts.

Potential hazard:
 BPA is toxic to reproduction and it is a known endocrine disruptor. Human can be exposed to this chemical via migration from food contact materials (FCM). BPA is leached out from thermal paper and exposed via skin contact. Infants are most vulnerable to the hazards from BPA as their food may come from canned concentrated infant formula. It is common that the baby bottles are made of PC plastic which is lightweight and strong. To safeguard human health, BPA is restricted in many countries especially for FCM and toys.

Commonly found in: 
Polycarbonate bottles, epoxy lining in food and beverage cans, food packaging and thermal paper.

Related legislation (non-exhaustive)

• European Union
  • FCM Plastic Regulation (EU) No. 10/2011
    • Specific migration of BPA: Plastic: 0.05 mg/kg;
    • Varnishes or coatings applied to materials and articles: 0.05 mg/kg;
    • No migration from which has specific use for infants and young children.
  • Toy Directive Annex II Appendix C
    • Toys which are intended for children under 36 months and in other toys intended to be placed in the mouth
      • < 0.1 mg/L (current);
      • < 0.04 mg/L (apply from 26 November 2018)
  • REACH Annex XVII
    • Entry 66 – Thermal paper (apply after 2 January 2020)
      • < 0.02% by weight
  • REACH Candidate List: 0.1% by weight
    
    
• USA
  • Federal
    • 21 CFR 175.300
      • BPA is prohibited in coatings in packaging for infant formula
    • 21 CFR 177.1580
      • BPA is prohibited in polycarbonate baby bottles and sippy cups
  • Various States law e.g. Washington, New York
    • BPA is prohibited in baby bottles, cups for children ≤ 3 years old
• Canada
  • Canada Consumer Product Safety Act Schedule 2, Item 15
    • BPA is prohibited in polycarbonate baby bottles

How can TÜV SÜD help?

TÜV SÜD has a dedicated technical solutions team to support you with root cause analysis, problem identification, suggestions for improvement and failure minimisation.

• Training and seminar on understanding the RSL (Restricted Substance List) and MRSL (Manufacturing Restricted Substance List)
• Testing services on raw materials and final products 
• Being part of the Zero Discharge of Hazardous Chemicals (ZDHC) programme, we review the entire value chain of footwear and textiles