EU bisphenol restriction (2024/3190) and recertifying high-temperature food-contact materials
What makes this restriction awkward is that it is not one material being replaced. Many assumed polycarbonate was the only problem, but BPA-based PSU and BPS-based PESU also require recertification for food contact. In other words the three materials that have been standard for high-temperature food contact are all affected at once. In March 2026 BASF responded by releasing a PPSU portfolio made without BPS or BPA, complete with datasheets, material certificates and food-contact approvals.
What has been banned
Regulation textThe use of BPA and its salts is banned in the manufacture of food-contact plastics, varnishes and coatings, printing inks, adhesives, ion-exchange resins, silicones and rubbers.
Beyond BPA, the use of other bisphenols and bisphenol derivatives with harmonised classification for certain hazards is also banned. Bisphenol S (BPS) falls within this, which is why PESU is affected.
Which materials are affected
BASF announcement| Material | Feedstock | Food-contact impact |
|---|---|---|
| PC · polycarbonate | BPA-based | In scope — named in the regulation |
| PSU · polysulfone (Ultrason® S) | BPA-based | In scope — named in the regulation |
| PESU · polyethersulfone (Ultrason® E) | BPS-based | Affected — recertification required |
| PPSU · polyphenylsulfone (Ultrason® P) | No BPA or BPS | Answer material |
BASF states that the bisphenols defined in Regulation 2024/3190 are not used in the manufacture of Ultrason® P (PPSU), and that the portfolio complies with the regulation.
There are exemptions — drinking water and filtration membranes
Regulation textThe regulation covers food-contact materials and articles only and does not apply to drinking-water applications. Water purifier components and similar parts may therefore continue in PSU and PESU, judged against drinking-water standards such as NSF/ANSI 61.
Polysulfone is also granted an exemption for filtration membrane assemblies used with food. That exemption comes with conditions, including migration limits.
Applications that are not food contact, such as medical devices and dental instruments, fall outside this restriction entirely. Both PSU and PPSU remain candidates there.
By when must the change be made — the main deadline has already passed
Regulation textThe regulation was adopted on 19 December 2024 and entered into force on 20 January 2025, with transitional measures set out by article type in Art. 11 and 12. The widest of them — the main 18-month transition period — closed on 20 July 2026. From that date most single-use and reusable food-contact articles manufactured using BPA may no longer be placed on the EU market for the first time.
Two categories retain an extension. Single-use articles using BPA varnishes and coatings for packaging that preserves fruit, vegetables and processed fish products, and reusable articles forming part of professional food processing equipment, may be placed on the market until 20 January 2028; the latter may remain on the market until 20 January 2029. Articles placed on the market within a transition period may be sold until stocks are exhausted, and single-use articles may be filled and sealed for 12 months after the applicable period expires.
In 2026 amending Regulation (EU) 2026/250 clarified the transitional provisions and tidied the wording of Art. 3 so that BPA in salt form is unambiguously covered. Cite the consolidated text rather than the original publication.
So the position is not “there is still time” but “the deadline has passed and only narrow categories remain”. Recertification requires material selection, trial shots, service validation and document collection, which in practice takes months. If you are still making European food-contact parts in a BPA-based material, your route to market may already be closed.
The cost of switching may be lower than expected
BASF announcementBASF states that existing injection moulds for PESU can continue to be used. If you are already moulding food-contact parts in PESU, a material-only switch without retooling is worth evaluating.
Processing conditions and shrinkage differences still need verification, and food-contact approval documents must be obtained afresh for the new material.
The answer material — PPSU
The only sulfone made without BPA or BPS. Heat resistance far above PC, with notched impact effectively on par with it.
PPSU · 폴리페닐설폰
No bisphenolBASF Ultrason® P 3010
The only sulfone made without BPA or BPS, and therefore the family that answers EU food-contact regulation. Notched impact strength of 70 kJ/m² puts it on par with PC (75).
BASF Ultrason® P 3010 Property detail →Frequently asked questions
Food-contact recertification — from material to documents
Tell us your current material, product category and target market, and we will map the conversion route and the certification documents you need. Evaluation samples are availablf charge.
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This document is technical guidance based on the published regulation text and manufacturer announcements, and is not legal advice. Confirm scope and transition periods against your own product category; the regulation text and the interpretation of the competent authority govern.
Tritan™ and Eastar™ are trademarks of Eastman Chemical Company, INFINO® of Lotte Chemical, and Ultrason® of BASF SE. Competitor product names are used solely for factual identification and comparison, and do not imply affiliation or endorsement.