Germany proposes three options for restriction of bisphenols

Preceding an upcoming consultation Germany has submitted three options for restriction of bisphenol A and bisphenols of similar concern, which all have endocrine disrupting properties in the environment.

Bisphenol A (BPA) and other bisphenols of similar concern (BoSC) fulfil the criteria for endocrine disruptors in the environment. They are considered as non-threshold substances, since information to derive realistic concentration limits is currently insufficient.

In a pre-publication report prior to the public consultation, Germany has proposed to group BPA together with four other BoSCs to be treated as non-threshold substances for the purposes of risk assessment. The proposed grouping approach covers BPA, BPB, BPS, BPF and BPAF and includes three different options for restriction. 

Proposed restrictions
Option 1 seems to be the most viable option. The purpose is to restrict 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 (i.e. via functioning as a cross-linker) or are used as intermediates in the manufacture of polymers, and for which

  1. contact to aqueous media in any form (i.e. also cleaning) can be excluded during their reasonable and foreseeable use throughout their service life or
  2. the migration limit in the respective mixtures and articles does not exceed 0.04 mg/L over the entire service life.

Options 2 and 3 are comparable to option 1 but differ in concentration limits.

The public consultation is expected to be launched next year.

For more information on bisphenols and endocrine disruptors, please contact:

Helle Buchardt Boyd 
Tel +45 4516 9097