The BPA Issue in 2026

1. What has actually changed?

The new EU Regulation 2024/3190 does not ban the presence of BPA itself. It prohibits the intentional use of BPA in the manufacture of materials intended to come into contact with food.
In my opinion, that is the most important sentence regarding this entire issue.

Many customers interpret the new legislation to mean: “ The product must not contain even a trace of BPA.” But that is not exactly what the regulation says.

2. Why is that?

The European Commission itself acknowledges that BPA is practically ubiquitous as a contaminant today.

It can come, for example, from:

• from recycled materials,
• certain raw materials,
• from manufacturing environments,
• laboratory equipment,
• from general environmental contamination.

Therefore, it is not realistic to demand an absolute zero. This is also confirmed by FAQ No. 24.

3. So how is compliance demonstrated?

This is probably the most important piece of information.

Compliance is demonstrated primarily by the fact that:

• BPA was not used in production,
• the binders and other raw materials used are not BPA-based,
• there is appropriate documentation from suppliers,
• the manufacturer complies with Good Manufacturing Practices (GMP).

The European Commission itself states that laboratory analysis is generally not required. The German Association of Paint and Coatings Manufacturers reiterates the same conclusion.

4. When are laboratory tests actually necessary?

Only in specific cases.

For example, if a manufacturer:

• intentionally uses BPA under one of the exceptions,
• uses another bisphenol or its derivative (e.g., BADGE), in which case it must be demonstrated that no BPA residues are formed.

If the manufacturer does not use BPA or its derivatives, this requirement generally does not apply to them.

5. A real-world case from Germany is particularly interesting

A company that manufactures water-based PUR varnish.
According to the suppliers, all raw materials used are BPA-free.

Nevertheless, laboratory analysis showed:
17 µg/kg of BPA.

Another previous test, however, showed:
< 1 µg/kg.

This clearly demonstrates that trace amounts can occur even without the intentional use of BPA.

6. How did the director of the German association respond to this?

His response is very important in the context of understanding the approach to addressing BPA.

Essentially, he says:

If BPA was not intentionally used, then the mere detection of trace amounts of BPA does not affect the product’s compliance with the law.

He further adds:

• he is not aware of any legal limit for such accidental traces,
• the ALARA principle applies,
• and customers often demand something that the law does not actually require.

7. What does ALARA mean?

ALARA stands for:

"As Low As Reasonably Achievable"

In other words:

to reduce any traces of BPA to the lowest level that is reasonably achievable.

8. An Example from France

France has historically taken a stricter national approach.

Nevertheless, even there, according to available information, inspections are not focused on incidental traces of BPA, but primarily on cases where BPA was intentionally used in manufacturing.

9. What this means

If, during paint production:

• raw materials declared by suppliers as BPA-free are used,
• no additional BPA is added,
• and neither BPA nor BPA derivatives are used,

then the declaration should read as follows:

BPA is not intentionally used in the production of HGC paints. Compliance with EU Regulation 2024/3190 is documented by the suppliers of the raw materials used and by good manufacturing practices.

This is precisely the philosophy supported by:

• the European Commission,
• the official FAQ,
• the German Association of Coatings and Printing Inks,
• and the statement by the executive director of the aforementioned organization.

In conclusion:

In light of the issues described, we can issue a statement regarding HGC* inks that, in accordance with the philosophy of EU Regulation 2024/3190, BPA is not intentionally used in the production of HGC, and that compliance is documented through the raw materials used in accordance with European legislation.

* As of July 10, 2026, we do not have this statement for the green pigment WCC 68 (this does not mean that this pigment contains BPA). We are currently addressing the situation, and it is a matter of a few days or a few weeks at most. Until then, we can replace this pigment with a mixture of yellow and blue pigments.