---
title: BPA Rules Take Effect: 3 Things to Check in Food Packaging
lang: en
source: https://mindsprt.dev/en/knowledge/new-bpa-rules-inks-coatings/
---

# BPA Rules Take Effect: 3 Things to Check in Food Packaging

*Industry Insights · 6 min read · 2026-10-02*

> The main deadline under the EU's new BPA rules passed on July 20, 2026. Recheck food packaging documents for inks, varnishes, and coatings. Brands should first confirm the market and intended use, then ask suppliers for applicable declarations and test evidence

**Quick answer:** The EU's new BPA rules restrict the intentional use of BPA in food contact materials. Brands should confirm the export market first, then ask MINDS and material suppliers to verify the packaging documents

## What Do the EU's New BPA Rules Cover?

The EU's new rules restrict the intentional use of BPA in the manufacture of food contact materials. The main transition period ended on July 20, 2026. I've boiled the checks brands need to make down to "Mai Strategy's Three Checks Before Print." Step one is to identify whether the rules apply. Food Contact Materials (FCM) are materials and articles used to package or hold food that come into direct contact with it, or that could affect food safety under their intended use. European Commission Regulation (EU) 2024/3190 was adopted in December 2024 and took effect on January 20, 2025, after an 18-month transition period. [Flint Group's guide to the new BPA rules](http://www.flintgrp.com/news-and-events/news/what-the-new-bpa-rules-mean-for-inks-coatings-and-varnishes-in-food-packaging/) sets out the main provisions and deadlines

・Article 3: Prohibits the intentional use of BPA and its salts in the manufacture of food contact materials

・Article 4: Prohibits the presence of BPA residues when other bisphenols or their derivatives are used in manufacturing

・Article 5: Prohibits the intentional use of hazardous bisphenols and derivatives classified under the EU CLP (Classification, Labelling and Packaging of Substances and Mixtures) Regulation as CMR (carcinogenic, mutagenic or toxic to reproduction) category 1A or 1B, or as category 1 human endocrine disruptors

Since the main deadline passed, most single-use and reusable food contact articles made using BPA may no longer be placed on the EU market for the first time. The rules set requirements for the manufacture and placing on the market of food contact materials. Brands should not reduce them to "BPA is banned in all printing inks"

## Is 1 ppb a General Limit?

No. 1 ppb is the limit of detection specified for two exempted use cases. It is not a general BPA acceptance limit for all food packaging. The second of Mai Strategy's Three Checks Before Print is to confirm the use case and supplier documents first. ppb (parts per billion) is a concentration unit. An extraction test takes relevant substances out of a material and checks whether BPA is present or released

The test must use a method sensitive enough to reach a limit of detection of 1 ppb. The limit of detection describes the concentration a test method can identify. It does not mean regulations allow a product to contain that level of BPA

Flint Group Packaging Solutions, Flint Group's packaging solutions division, says its products do not fall into either of the two use cases above, so this test is not required. That is the supplier's statement about its own products. Brands cannot apply it to other inks, varnishes, or coatings

## How Should You Check Inks, Varnishes, and Coatings?

Check inks, varnishes, and coatings against the intended use of the food contact material and the supplier documents together. Do not reduce the rules to "BPA is banned in all printing inks." Mai Strategy's Three Checks Before Print puts material documents ahead of proofing

I would not sign off on a proof based only on a "BPA-free" label or the claim that something is "printed on the outside." Brands need evidence that BPA was not intentionally used in the manufacture of the food contact material. The documents also need to match the materials and versions actually used. If the design, proof, and production materials do not line up, the declaration loses its value

Procurement specs should state the food packaging use, sales market, and the suppliers and product codes for inks, varnishes, and coatings. When a supplier or processing formula changes, check whether the original documents still apply. Ink prints the graphics and text. Compliance checks how the material is used in the finished packaging

## What Three Steps Should Brands Take Now?

Confirm the market and intended use first, collect material declarations next, then decide whether testing is needed. That is Mai Strategy's Three Checks Before Print. Brands can use it to organize action items for new projects and existing packaging

・1. List the food packaging products sold in the EU and confirm the food contact use and actual material combination for each type of packaging

・2. Ask ink, varnish, and coating suppliers for written information. Check that the documents match the product codes and formula versions actually used, and state whether BPA or other regulated bisphenols are intentionally used in manufacturing

・3. If the materials fall under an exempted use case listed in the rules, ask the supplier and lab to confirm whether the applicable extraction test can reach a limit of detection of 1 ppb. Do not extend this requirement to all packaging

The main deadline has passed. Brands should first check EU packaging now in production, due to ship, or in development. EU rules are not a general standard for all packaging sold domestically in Taiwan. Check the requirements for each other sales market separately

## How Can Smaller Printers Control the Cost of Changing Materials?

Start by limiting the list of affected products, then put material versions, documents, and testing requirements into one spec. That usually keeps costs under control better than changing materials across the board. The third of Mai Strategy's Three Checks Before Print is to make every change traceable to a product code and version

Spell out the intended use first

Before quoting or making a proof, the printer should confirm where the packaging will be sold, which ink and varnish will be used, and which version the supplier documents cover. If the formula or supplier changes, check the declaration again. Do not leave a sample made with new materials attached to old documents

Lock the version first

If a project includes custom printing, brands can include MINDS in discussions about printing and finishing specs, then get material declarations from the actual ink and coating suppliers. Even if the printing plates run smoothly, it is hard for a brand to sign off with confidence when the documents still refer to an old formula

## Key Takeaways

・Mai Strategy's Three Checks Before Print starts with the sales market and packaging use. Do not guess whether the rules apply based on where the print appears

・1 ppb is the limit of detection for specific exempted use cases, not a general acceptance limit for food packaging

・Check that ink, varnish, and coating documents match the product codes and formula versions actually used

・Alternative formulas and testing add cost. Inventory EU products first, then plan the order of changes

## Further Considerations

Printers can add ink, varnish, and coating product codes and formula versions to the job ticket. Designers can note the sales market, food packaging use, and planned processing in the brief. AI (artificial intelligence) or SaaS (software as a service, cloud software delivered over the internet) can help organize supplier declarations and flag mismatched versions or missing fields. The brand's quality assurance or compliance team still needs to check the source text and product codes when interpreting the rules. Mai Strategy's Three Checks Before Print is a good fit for a trial run on one EU-bound packaging product. Check everything from supplier documents to proof versions, then decide whether to extend the process to other products

## Further Reading

・[Flint Group: What the New BPA Rules Mean for Inks, Coatings, and Varnishes in Food Packaging](http://www.flintgrp.com/news-and-events/news/what-the-new-bpa-rules-mean-for-inks-coatings-and-varnishes-in-food-packaging/)

## FAQ

### Do the EU's new BPA rules also apply directly to packaging sold only in Taiwan?

The EU's BPA rules apply to food contact articles first placed on the EU market. Under Mai Strategy's Three Checks Before Print, brands should identify the sales market first. Packaging sold only in Taiwan still needs to be checked against applicable local rules.

### Is 1 ppb the maximum BPA level allowed in food packaging?

No. 1 ppb is the limit of detection for use cases specifically listed as exceptions in the rules. Mai Strategy's Three Checks Before Print confirms the materials first, then determines whether this extraction test is needed.

### Do all food packaging inks have to be tested?

Not across the board. The rules require documents showing that BPA was not intentionally used, while 1 ppb testing applies to specific use cases. Mai Strategy's Three Checks Before Print starts by checking the material declaration against the product code actually used.

### Does a supplier's "BPA-free" label mean the packaging complies?

A label alone cannot replace supplier documents that match the product code and intended use. Under Mai Strategy's Three Checks Before Print, brands also need to check the formula version and applicable sales market.


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