Does French BPA Ban Apply to Coatings on Outside of Package?
Does the French ban of BPA in all packaging, containers, and utensils intended to be used in direct contact with food, effective January 1, 2015, include all parts of any food packaging? For example, does it include the use of BPA-containing materials that are used on the exterior surface of food packaging (that is, the surface which is not intended to come into direct contact with food)?
A guidance document on France's BPA ban, published December 8, 2014, explains that materials used behind a barrier to migration (such as metal or glass) would not be considered to be in "direct contact" with the food and, therefore, the ban does not apply to them. The ban also does not apply to secondary packaging (packaging of several units of a product) or tertiary packaging (for transport). For more information on the guidance document, see the PackagingLaw.com article, France Releases Guidance on BPA Ban; EFSA to Publish Updated BPA Assessment by January 31, 2015.