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On June 2, 2025, The Swiss Federal Office for Food Safety and Veterinary Affairs (BLV) announced a significant amendment to its Ordinance on Materials and Articles Intended to Come into Contact with Foodstuffs (FCM Ordinance). Effective July 1, 2025, this revision prohibits the use of Bisphenol A (BPA) and other hazardous bisphenols and bisphenol derivatives in the manufacturing of varnishes and coatings for food contact materials.
The revised Swiss FCM Ordinance explicitly bans the use of BPA (CAS No. 80-05-7) and its salts in varnishes and coatings for food contact materials.
Furthermore, it extends this prohibition to other hazardous bisphenols and bisphenol derivatives that are classified as mutagenic (categories 1A or 1B), carcinogenic, toxic for reproduction, or endocrine disruptors affecting human health of category 1(CMRED substances). Commonly used bisphenols such as bisphenol S (BPS,CAS No.80-09-1)are classified as Repr 1B under CLP Regulation, which is also included under the prohibition scope.
The new regulation also mandates that varnishes and coatings made with other bisphenols or bisphenol derivatives must not contain residues of BPA. To ensure compliance, an extraction method with a detection limit of 1 µg/kg is required to verify the absence of BPA and other hazardous bisphenols or bisphenol derivatives.
While the general prohibition is strict, the ordinance does allow for limited exceptions. For instance, BPA may still be used as a monomer or starting material in the production of liquid epoxy resins applied to self-supporting articles with a capacity exceeding 1000 liters, provided that no migration into food is detectable (with a detection limit of 1 µg/kg food). This exception is primarily for large industrial containers where direct food contact is minimal or controlled.
Additionally, the ordinance requires a declaration of conformity for varnishes and coatings, which must include a list of all bisphenols or bisphenol derivatives used in the manufacturing of the food contact material.
Background
Bisphenols are a group of industrial chemical compounds primarily used in the production of plastics and epoxy resins. Bisphenol A (BPA) is perhaps the most well-known, widely used since the 1950s in various consumer products, including food and beverage containers.
However, concerns have grown over the years regarding the potential health effects of BPA, which is classified as an endocrine-disrupting chemical. linked to reproductive issues, developmental problems, and increased risks of chronic diseases.
Globally, regulatory bodies have taken action. The EU has significantly reduced the tolerable daily intake of BPA and adopted Commission Regulation (EU) 2024/3190 to bann its use in certain food contact materials, including coatings on metal cans, reusable plastic drinking bottles, and other items intended to come into contact with food or drink. In the US, while the FDA maintains BPA is safe at current levels, several states like California, New York have banned it in specific products, particularly those for infants and young children.
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