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Industry statement on BPA SVHC identification

Bisphenol A (BPA) identified as Substance of Very High Concern (SVHC) – inclusion in
Candidate List announced for January 2017
The members of the PC/BPA group note the recent Member State Committee agreement to
identify BPA as a Substance of Very High Concern (SVHC) under REACH (European Regulation
concerning Registration, Evaluation, Authorisation and Restriction of Chemicals), based on its
harmonised classification as reprotox 1B. ECHA announced the inclusion of BPA in the
Candidate List for January 2017.
As the harmonised classification of BPA as reprotoxic 1B fulfils the criteria for identification as
SVHC according to article 57(c) of REACH, this development was expected. The justification for
SVHC identification is based on intrinsic properties of the substance, not on use, exposure and
risk.
No direct implications of SVHC identification and/or potential later authorisation
expected for vast majority of BPA-applications
The identification of BPA as SVHC and the inclusion in the Candidate List triggers immediate
communication and documentation obligations for companies under certain conditions. The
overwhelming amount of all BPA produced is converted into polymers and only technically
unavoidable trace levels of unreacted BPA may remain in the polymer matrix, usually far below
the levels that would trigger SVHC-related communication or documentation obligations. More
detailed information can be found here: https://www.echa.europa.eu/candidate-list-obligations.
The SVHC-identification does not imply an immediate ban or restriction of any uses of the
substance, but it could be the first step into its Authorisation under REACH.
Intermediate uses of a substance are exempt from Authorisation under REACH
BPA is predominantly used as an intermediate to manufacture polycarbonate and epoxy resin,
which are mainly polymeric materials. The uses of BPA to manufacture polymers would be
exempt from potential later authorisation under REACH. No direct impact of a potential
authorisation would therefore be expected for polymeric uses of BPA.
Consumer safety of BPA confirmed for food contact applications and beyond
In its recent comprehensive evaluation of consumer safety, the European Food Safety Authority
(EFSA) concluded that current consumer exposure to BPA poses no health risk to any age group.
This is because the exposure via food, but also via a combination of different sources (food, dust,
cosmetics, thermal paper) is far below the newly derived tolerable daily intake (TDI).
REACH respects existing food contact regulation
In the area of food contact applications, the use of BPA is in compliance with the Framework
Regulation for all food contact materials ((EC) No 1935/2004) and permitted by the Regulation on
plastics used as food contact materials ((EU) No 10/2011). Therefore, neither the identification of
BPA as an SVHC nor a potential subsequent authorisation under REACH at a later stage would
affect its approved use in plastics for food contact applications such as polycarbonate.
For further information please contact:
Jasmin Bird
PC/BPA-Group PlasticsEurope
jasmin.bird@plasticseurope.org
www.bisphenol-a-europe.org