Food Contact Applications : BPA and BADGE Proposed Restriction

Glass Fibre Europe’s member answered to the public consultation on the proposed Commission Regulation on the use of bisphenol A (BPA) and other bisphenols and their derivatives with harmonised classification for specific hazardous properties in certain materials and articles intended to come into contact with food, amending Regulation (EU) No 10/2011, amending Regulation (EC) No 1895/2005 and repealing Regulation (EU) 2018/213.

Glass Fibre Europe wants to bring to the attention of the Commission the specific case of Continuous Filaments Glass Fibre (CFGF) products used as reinforcement of plastic in the manufacture of Glass Fibre Reinforced Plastic (GFRP) materials and articles. Such CFGF products are used in a large variety of end use GFRP applications, some of which are intended for food contact (e.g. food processing equipment) as well as for drinking water contact applications in the public water distribution networks (e.g. pipes, tanks, ladders in water towers, pumps).

The current proposal will disproportionately impact food contact applications and prohibit de facto GFRP materials used currently in drinking water contact applications in compliance with Member States regulations. Detailed explanations are available in the document below.

Glass Fibre Europe solicits the attention of the Commission for considering the use of BPA as precursor of BADGE-based epoxy film formers used in the formulation of sizing applied to CFGF products used in reinforced plastic intended for food contact applications as eligible for a derogation to the prohibition of the use of BPA in FCM. Provided such a derogation is considered justified, to be effective, it would require to be covered in the proposed amendment of Regulation 1895/2005.