BPA-Free Coating Migration: Mid-2026 Status for EU Food Cans

Regulation (EU) 2024/3190 on the use of bisphenol A and other bisphenols in food contact materials entered into force on 20 January 2025. The regulation’s transitional periods are layered, with the first major deadline — 20 July 2026 — applying to single-use food contact articles in general, and an extended deadline of 20 January 2028 applying to packaging for fruits, vegetables and fishery products and to applications carrying BPA-based coatings. Q4 2026 customer audits will already treat bisphenol documentation as a standard supplier-disclosure question — irrespective of which specific transitional gate a given format falls under.

This is not another regulatory overview. EFSA’s bisphenol portal and the European Commission’s food contact materials pages cover that ground. This article is a procurement and QA status check: where European food producers actually stand on coating migration, which formats and supplier types still carry documented or undocumented exposure, and what supplier-level audit framework to apply before Q3 closes.

It is written for the people who will personally answer to a Q4 customer audit, a QA finding, or a coating-related non-conformance: QA managers, R&D and packaging development leads, procurement, and the food-safety leadership setting supplier policy.

What 2024/3190 actually changes

The earlier framework — Regulation (EU) 2018/213 — applied a specific migration limit of 0.05 mg/kg for BPA in varnishes and coatings, reduced the BPA migration limit in plastics from the previous 0.6 mg/kg to 0.05 mg/kg, and required zero migration for materials intended for infant food. Regulation 2018/213 has been repealed by 2024/3190.

Regulation (EU) 2024/3190 makes three substantive changes.

It prohibits the use of bisphenol A in the manufacture of specified food contact materials, including plastics, varnishes and coatings, printing inks, adhesives, ion-exchange resins, silicones and rubbers. The prohibition is a manufacturing ban, not a migration-limit tightening.

It extends the prohibition to other hazardous bisphenols and bisphenol derivatives, using a hazard-based approach by reference to Annex VI Part 3 of the CLP Regulation (EC) No 1272/2008 — rather than enumerating specific compounds such as BPS, BPF or BPAF by name in 2024/3190 itself. The practical effect is to close the “regrettable substitution” gap that surfaced during the 2018–2024 period: any drop-in bisphenol replacement that carries a hazardous classification under CLP is captured.

It sets layered transitional periods running through 2026–2029. The principal gates are:

20 July 2026 (18 months from entry into force) — single-use food contact articles in general, manufactured or placed on the market under the previous rules, may continue to be placed on the market.
20 January 2028 (36 months) — extended transitional period for packaging intended for fruits, vegetables and fishery products, and for applications carrying BPA-based coatings (industry guidance on the exact scope of “with BPA-based coatings” is still settling).
20 January 2029 (49 months) — repeat-use articles first placed on the market under the previous rules.

A 12-month use-up provision allows single-use final articles already placed on the market under the transitional rules to be filled with food and sealed during the year following the expiry of the applicable transitional period, with the resulting packaged food sold until stocks are exhausted.

The practical implication for procurement and QA: every supplier providing can coatings, finished cans, or coated substrate should be able to document by Q3 2026 which coating system is in use, which transitional gate applies, and where the format sits in the migration roadmap. Documentation referencing only BPA migration limits under the 2018/213 framework is no longer the current standard, even where a longer transition still legally applies.

What the European can-coating industry actually did

For the major European can manufacturers — Crown, Silgan, Ardagh, CANPACK, Trivium — bisphenol migration is not a 2026 conversation. Most large producers had moved to BPA-NI (non-intentionally added) coatings as the production norm for European food applications well in advance of the regulatory tightening, with the migration broadly complete several years before 2024/3190. Their documentation has been refreshed across multiple cycles, and their alternative coating systems have been in volume production for several years.

The migration was technically achievable through several established alternative chemistries:

Polyester-based coatings. The most common BPA-NI replacement in European can production. Suitable for the majority of canned vegetable, fruit, soup, ready-meal and pet food applications. Mature supplier ecosystem (Valspar/Sherwin-Williams, PPG, AkzoNobel, Henkel — though product lines and ownerships shift). Compatible with standard line speeds and retort conditions for most product categories.

Acrylic coatings. Used selectively, often where polyester carries trade-off in adhesion or flexibility. Established in beverage-can interior applications, deployed in selected food applications.

Modified epoxy coatings without bisphenol monomers. Engineered to retain the performance characteristics of traditional BPA-based epoxy without using bisphenol monomers in the formulation. Suitable for the more demanding applications — high-acid foods, retort-intensive products, long shelf-life requirements.

Oleoresin-based coatings. Older chemistry, returning in selected applications. Niche but technically established for specific product categories.

Water-based coating systems. Growing share, partly driven by VOC regulation as well as bisphenol concerns.

The technical alternatives are mature. The procurement and QA question is not whether suitable coatings exist — they do. The question is whether your specific supplier set has documented migration across the full SKU range you actually purchase.

Where the gaps are in mid-2026

The fact that an extended transitional period applies to certain BPA-coated applications until 20 January 2028 does not mean that procurement and QA can wait. Customer audits, retailer compliance frameworks and private-label specification reviews are already treating the 2024/3190 bisphenol scope as the current standard. The supplier-disclosure gaps that surface in Q4 2026 audits will be the basis for supplier-status decisions taken months before the regulatory deadline.

Five categories of exposure to look for in a supplier review this quarter.

Legacy substrate stock

Pre-coated tinplate or aluminum substrate held in warehouse from procurement decisions made under the 2018/213 framework. Most major converters managed inventory roll-over by 2024–2025, but smaller converters or specialty producers may hold pre-coated stock with documentation predating the wider bisphenol scope. The question is not whether the legacy stock exists somewhere — it does — but whether your supplier is drawing from it for your SKUs.

Niche and specialty formats

Low-volume custom can sizes, specialty EOE patterns, regional traditional packaging formats. Smaller volume runs are economically harder to qualify with new coating systems, and migration timelines have sometimes lagged for these formats. Procurement teams running a portfolio of mainstream and niche SKUs should expect the niche end of the portfolio to carry the higher residual exposure.

Smaller regional co-packers and converters

Major European can manufacturers are well-documented. Smaller regional converters serving private-label production may have completed coating migration on the mainstream substrate while documentation lags on specialty applications. The QA conversation is direct: what is the current coating system, by SKU, with the manufacturer’s declaration dated within the last twelve months.

Non-EU substrate flows

Where coated substrate is sourced from non-EU mills (Turkey, India, China, South Korea, Vietnam), the regulatory regime governing the coating production differs. Substrate may comply with the manufacturing-country standards but require additional documentation to demonstrate compliance with 2024/3190 for placing on the EU market. This is the gap most likely to surface in Q4 customer audits.

Documentation specificity gaps

Many supplier declarations in circulation reference BPA compliance under the 2018/213 framework but do not address the broader hazardous-bisphenol scope captured by 2024/3190 through the CLP hazard classification reference. A QA audit in late 2026 will treat a BPA-only declaration as inadequate, even where the underlying coating is in fact free of intentionally added bisphenols. The documentation needs to match the current regulatory scope, not the predecessor scope — including a statement that the coating system carries no bisphenols or bisphenol derivatives classified as hazardous under the CLP Regulation.

What good documentation looks like in 2026

A complete coating compliance documentation package, from any supplier of cans, EOE, bottom ends or coated tinplate substrate, contains:

A current Declaration of Conformity citing both Regulation (EC) No 1935/2004 (the framework regulation), Regulation (EU) 2024/3190 (the current bisphenols regime), and where applicable Regulation (EU) No 10/2011 (plastic materials by analogy for the internal coating system).
Declaration of compliance with Good Manufacturing Practice under Regulation (EC) No 2023/2006.
Per-format coating system specification — naming the coating system in use for the specific can format, EOE format and substrate combination purchased.
Migration testing summary referencing EN 1186 / EN 13130 methodologies, with the test date, the food simulants used, and the conditions of use applied. Test data should explicitly cover the bisphenol scope of 2024/3190, not only BPA.
An explicit bisphenol-scope statement — confirming the coating system is free of intentionally added BPA and of bisphenols or bisphenol derivatives classified as hazardous under CLP Regulation (EC) No 1272/2008, with the rationale for the alternative chemistry chosen.
Documentation of substrate origin — where the coated substrate was manufactured, by which mill, and under which national regulatory regime, with cross-mapping to 2024/3190 compliance for non-EU substrate flows.
Specific applications scope — for which food categories (acidic, fatty, aqueous, retort, ambient, frozen) the coating system has been qualified.
The applicable transitional gate — which 2024/3190 transitional period applies to the format supplied (20 July 2026, 20 January 2028, or 20 January 2029), and the supplier’s migration roadmap to the post-transition coating system.

A pack that meets this standard makes the QA and procurement work of Q3 materially easier, and demonstrably reduces the time a Q4 customer audit takes to clear.

Seven questions to ask every coated-substrate supplier before 30 September

If QA and procurement write one supplier email this quarter on coating compliance, this is its content.

What is the specific coating system currently in use for the can / EOE / tinplate format we purchase? Manufacturer, product reference, chemistry family.
Can you provide the current Declaration of Conformity citing Regulation (EU) 2024/3190 (not only the 2018/213 predecessor), dated within the last twelve months?
Which 2024/3190 transitional period applies to the format we buy — 20 July 2026, 20 January 2028, or 20 January 2029 — and what is the migration roadmap to the post-transition coating system?
Does the declaration explicitly cover the broader hazardous-bisphenol scope of 2024/3190 through the CLP Regulation hazard reference, or only BPA?
What migration testing data supports the declaration, with test dates, food simulants used, and conditions of use applied?
For substrate manufactured outside the EU, what additional documentation demonstrates 2024/3190 compliance for placing on the EU market?
For specialty or low-volume formats in our portfolio, has the same coating system documentation been completed as for the mainstream formats, and is any legacy BPA-containing stock currently being drawn against our SKUs?

Suppliers who answer all seven in writing, with current documentation, are operating to a mature standard. Suppliers who answer four or five with documentation and the rest with credible remediation timelines are workable but flagged. Suppliers who deflect, delay or respond only with marketing material are the supplier-risk concentration this exercise was designed to surface.

Cross-references: PPWR, CBAM, CSRD

The supplier-disclosure exercise that satisfies bisphenol compliance documentation overlaps meaningfully with three other supplier-data demands hitting procurement in the same window.

PPWR (Regulation (EU) 2025/40), applying from 12 August 2026, requires substrate-level supplier disclosure on recyclability, recycled content, and overall packaging compliance. The same per-format supplier conversation handles both bisphenol and PPWR documentation in one pass.
CBAM cost-passthrough transparency, in effect since 1 January 2026, requires substrate-origin disclosure — which is also the data point you need for non-EU substrate bisphenol-regime mapping.
CSRD reporting (for in-scope companies) requires supplier-level data on materials and chemicals, which overlaps with the bisphenol scope disclosure.

A procurement and QA team that runs a single, structured supplier disclosure exercise this quarter — covering format, substrate origin, coating system, bisphenol scope, recyclability, recycled content and CBAM cost component — gets the documentation foundation for the next twelve months of audits in one supplier conversation, rather than four separate ones.

Action plan for Q3 — what should be in motion this month

Weeks 1–2 (early to mid-June): Inventory all SKUs by metal-packaging format, substrate and coating system. Identify which suppliers carry which documentation versions, and the date of the current declarations.

Weeks 3–4 (mid-to-late June): Send a structured documentation request to every supplier currently in use — covering the seven questions above, plus the parallel PPWR and CBAM questions where the supplier is the same — using a single common template, with a response deadline of 24 July.

Weeks 5–8 (July): Map the responses against the obligation areas. Categorise gaps. Escalate silent or partial responses to the supplier’s commercial lead with a 14-day deadline. For the highest-exposure SKUs (non-EU substrate, niche formats, smaller co-packers), begin second-source sampling against EU-substrate suppliers with current 2024/3190 documentation.

Weeks 9–12 (August): Consolidate documentation per SKU. Brief the customer-facing team — sales, key-account, customer service — on what is documented and what is in remediation, so external audit questions are answered consistently.

Weeks 13+ (September onward): Q4 audit preparation, with the bisphenol documentation already in the file rather than chased reactively in October–November.

The 20 July 2026 transitional gate is the first audit checkpoint that matters in practice, but it is not the only one. For formats subject to the extended transition to 20 January 2028, the documentation effort run this quarter buys the visibility to manage the longer migration timeline deliberately, rather than under deadline pressure in 2027.

What this does not cover — and where the conversation goes next

The bisphenol regulatory regime is not the only food-contact-materials policy line item moving through 2026–2028. The broader food contact materials review under the framework regulation continues. The CSRD’s chemical disclosure expectations are tightening for in-scope reporters. National-level enforcement priorities are diverging across EU member states.

A procurement and QA team that builds a clean coating compliance framework now positions itself well for those adjacent conversations. The supplier-disclosure discipline that handles 2024/3190 applies equally to whatever the next round of food contact materials regulation brings.

Mid-2026 is the window. By end-Q3, every metal-packaging supplier in the portfolio should either have current 2024/3190 documentation on file — covering the broader bisphenol scope through the CLP hazard reference, and the applicable transitional gate — or a credible written remediation date, or a documented second-source qualification in progress. By end-Q4, customer audits will treat these as routine compliance checks rather than emerging supplier risks, regardless of which specific transitional deadline a given format faces.

Sources and primary references

This article is general procurement and QA guidance. It is not legal advice. Specific compliance decisions should be reviewed with food contact materials and regulatory advisors familiar with your product categories, member state enforcement context, and supplier specifics.