Germany to exclude polycarbonates from forthcoming EU bisphenols restriction

Chemical Watch News

BAuA confirms major use of BPA is outside scope of resubmission

Risk assessment
Electrical & electronics
Textiles & apparel
Aerospace, automotive & engineering
Chemical industry
Built environment
Retail
Bisphenols
EDCs
EU REACH
Restricted use
EU
Federal - Germany

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The German Federal Institute for Occupational Safety and Health (BauA) has confirmed it does not intend to include polycarbonates in its forthcoming proposal for a class-based EU restriction of bisphenols. 

The institute’s confirmation to Chemical Watch News & Insight follows concerns from polycarbonates producers who said that, depending on the limit values, a restriction on bisphenols could lead to higher costs for downstream users due to increased product testing for compliance.

Bisphenol A (BPA) is the dominant bisphenol in global commerce, with most BPA used in the production of polycarbonate, a transparent, tough, lightweight engineering plastic. Key polycarbonate applications include electronic components, construction materials, face shields, signs and display stands.

BAuA notified ECHA on 23 April of its intention to resubmit, by 12 March 2027, a revised-scope version of its 2022 REACH restriction proposal for bisphenols that are a risk because of endocrine disruption in the environment.

The authority withdrew the original proposal in 2023, citing a need to address the scope in response to stakeholder feedback. Since then, it has repeatedly delayed its resubmission plans.

Restriction targets

A 2 September notification on the ECHA website stated that the proposal targets uses associated with significant emission potential, namely:

  • leather tanning and leather articles;
  • textile finishing agents and textile articles;
  • thermal paper; and
  • articles and mixtures made from polyvinyl chloride (PVC).

The five in-scope substances have not changed from the original proposal. They are:

  • BPA;
  • bisphenol B (BPB);
  • bisphenol S (BPS);
  • bisphenol F (BPF); and
  • bisphenol AF (BPAF) and its eight salts.

As before, the proposal will include an option for the European Commission to expand the scope to additional bisphenols identified as endocrine disruptors for the environment at the EU level.

To do this, the Commission would use the comitology process to establish an EU-level agreement before adding bisphenols with environmental endocrine disrupting properties to the proposal, BAuA said.

The proposal will also include conditions to minimise emissions during recycling processes and from the second-hand market.

The Commission looks to further tighten controls on BPA this year, following a proposal to reduce the permitted migration limit in certain toys eightfold.

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