Overview#
Bisphenol A is a high-volume industrial chemical built into many everyday plastics. It forms the backbone of polycarbonate and of epoxy resins, and it serves as a colour developer in some thermal paper. Concern centres on its biological effects. It is toxic to reproduction and behaves as an endocrine disruptor, interfering with the body's hormone signalling.
Where it's restricted#
Bisphenol A appears on the REACH Candidate List as a substance of very high concern. That status triggers communication and notification duties along the supply chain once a substance is present above the threshold in an article.
Beyond the Candidate List, its use as a developer in thermal paper is restricted under REACH Annex XVII. Receipts and similar paper are the most familiar example. Manufacturers have moved much production to alternative developers in response.
Polycarbonate and epoxy resins are the largest uses of bisphenol A by volume, but the thermal paper restriction is what most people encounter directly through everyday receipts.
Bisphenol A in toys: a limit about to fall#
Toys have their own chemical rules, in Annex II of the Toy Safety Directive 2009/48/EC, and Appendix C to that annex sets specific limit values for toys intended for children under 36 months or for other toys intended to be placed in the mouth. The current bisphenol A entry, set by Commission Directive (EU) 2017/898, reads:
Bisphenol A, migration from toy material (Appendix C today)0,04 mg/lThe entry also says how to test: the migration is to be measured "in accordance with the methods laid down in EN 71-10:2005 and EN 71-11:2005", the general standards for extracting and analysing organic compounds from toy materials.
On 17 September 2026 the Commission published a draft Commission Directive amending Annex II to Directive 2009/48/EC "as regards allergenic fragrances in toys, bisphenol A, phenol and benzisothiazolinone". Feedback is open until 15 October 2026 and adoption is planned for the fourth quarter of 2026. It is a restriction: nothing in it permits anything that is banned today. The draft is not adopted, so the figures below can still change.
Bisphenol A: 0,04 mg/l migration limit, tested to EN 71-10:2005 and EN 71-11:2005. Phenol: 5 mg/l migration in polymeric materials, 10 mg/kg content as a preservative. 1,2-Benzisothiazol-3(2H)-one (BIT): 5 mg/kg content in aqueous toy materials. All three entries bind the test to EN 71-10 and EN 71-11.
Bisphenol A: 0,005 mg/l migration limit. Phenol and BIT keep their figures. All three entries lose the reference to EN 71-10 and EN 71-11, so that the three new dedicated standards from 2025, EN 71-17 (isothiazolinones), EN 71-18 (phenol) and EN 71-19 (bisphenol A), can be assessed and cited in the Official Journal for presumption of conformity.
The reasoning in the draft is worth carrying away, because it explains why an eightfold cut lands on that particular figure. The 0,04 mg/l limit was derived from the European Food Safety Authority's 2015 temporary tolerable daily intake of 4 micrograms per kilogram of body weight, assuming a 10 kg child mouthing 10 cm² of toy for three hours a day and allocating 10 % of the intake to toys. In 2023 EFSA set a new TDI of 0,2 nanograms per kilogram, 20 000 times lower, with the immune system as the most sensitive endpoint. Scaled the same way, the old limit is far too high, and rather than derive a figure that no laboratory could measure, the draft sets the limit at the limit of quantification of EN 71-19:2025, which is 0,005 mg/l: the lowest value the existing test method can actually report.
The same draft does one more thing that has nothing to do with bisphenol A but arrives in the same act. Lilial (2-(4-tert-butylbenzyl)propionaldehyde, CAS 80-54-6), classified as toxic for reproduction category 1B under CLP since 1 March 2022, moves from the list of 72 allergenic fragrances that must be named on the toy above 100 mg/kg to the list of fragrances prohibited in toys, as entry 59. A fragrance formulation that has been compliant because Lilial was declared on the label will not be compliant once it is banned.
Toys are also where the direction of a change is easiest to misread: the cobalt page describes an amendment to the same annex that permitted a substance, and this one restricts. Read the operative article, not the headline, before deciding which you are looking at.
Typical uses#
The chemical turns up in rigid clear plastics, in protective coatings and linings made from epoxy, and as the developer in older thermal paper formulations. Substitution is well underway in several of these areas, though legacy materials remain in circulation.