Possible further restrictions on the use of Bisphenols
Following a proposal prepared by the German authorities to restrict the use of Bisphenol A (BPA) and other bisphenols, on 6th April 2022, ECHA and member states assessed a group of 148 Bisphenols and recommended restrictions on over 30 bisphenols due to their potential hormonal and reprotoxic effects.
The application of Bisphenols is varied across many industry sectors. They have important functions in the transport industry, the textile and paper industry and in toys and sports equipment manufacturing and more. Furthermore, BPA plays an important role in the production of polymers and plastics, and Bisphenol S is a key component in the manufacture of many syntans used in leather processing.
The hazards of Bisphenols are well known, they are endocrine disruptors, meaning they interfere with the hormonal system in humans and the environment. Additionally, they may cause damage to fertility, and they have been linked to skin allergies.
Many countries in the EU, Asia and Americas already have legislation restricting the use of BPA in infant products such as plastic bottles. The EU also restricts its use in thermal paper under entry 66 of Annex XVII. Along with Bisphenol B and 2,2-bis(4'-hydroxyphenyl)-4-methylpentane, BPA is also listed as a Substance of Very High Concern (SVHC) under REACH.
These restrictions were put into place to motivate industry to find safer alternatives, but as is often the case, it has led to regrettable substitutions. In some cases, industry has avoided the restricted chemicals and used structurally similar substances with similar chemical properties, but unfortunately, similar toxicological profiles. To avoid these regrettable substitutions, restrictions on groups of chemicals are often more suitable.
As the current restrictions are deemed inadequate, a broader restriction has been proposed, which would restrict 4,4’-isopropylidenediphenol (BPA) and Bisphenols of similar concern for the environment.
The proposed restriction applies to the placing on the market of mixtures and articles where concentration is equal to or greater than 10 ppm (0.001 % by weight).
The first condition shall not apply to mixtures and articles where the Bisphenols in the scope of the restriction are either covalently bound to any type of matrix (e.g. via functioning as a cross-linker) or are used as intermediates in the manufacture of polymers, and for which
- contact to aqueous media in any form can be excluded during their reasonable and foreseeable use throughout their service life or
- the migration limit in the respective mixtures and articles does not exceed 0.04 mg/L over the entire service life.
There will be an intermediate limit of 500 ppm for leather, for 5 years after the regulation comes into force.
The regulation is expected to be in force by June 2024, its therefore important to consider whether these chemicals are a cause for concern within your supply chain.
How can BLC help?
- REACH SVHC testing and screening service – testing for the presence of substances included in the latest published SHVC list, including BPA.
- Testing for Bisphenols including BPA, BPF, BPS, BPAF, BPB and BPD.
Contact us my email [email protected] or phone +44 (0) 1604 67999.
22 May 2023