If you import silicone bakeware or kitchen tools into the EU, this regulation just rewrote your compliance checklist. Here's what changed, what to ask your supplier, and how to verify it.
The regulation in one paragraph
On 19 December 2024 the European Commission adopted Commission Regulation (EU) 2024/3190, which prohibits bisphenol A (BPA) in the manufacture of food-contact materials. It entered into force on 20 January 2025 and is not limited to BPA alone — it also covers other bisphenols and bisphenol derivatives with harmonised hazard classification, such as bisphenol S (BPS), which was historically used as a BPA substitute.
The scope is deliberately wide. Article 1(2) lists the material groups it applies to: adhesives, rubbers, ion-exchange resins, plastics, printing inks, silicones, and varnishes and coatings. If your product is a silicone baking mat, a silicone cake mold, or a silicone-coated tool, it is directly in scope.
What the regulation actually requires
- BPA is prohibited as an input — not merely limited. The use of BPA and its salts in the manufacture of the material groups listed above is prohibited for products placed on the EU market. This replaces the previous specific migration limit of 0.05 mg/kg. The few remaining authorisations — for example liquid epoxy coatings applied to vessels with a capacity above 1,000 litres — require that "migration into food shall not be detectable".
- Other bisphenols are restricted too. To close the "substitute problem" (switching from BPA to BPS or BPF), the regulation covers other bisphenols and bisphenol derivatives with harmonised classification. BPS remains authorised in plastic food-contact materials, but only under a specific migration limit of 0.05 mg/kg. A report that screens for BPA alone is no longer sufficient.
- Check which transition period applies to your product. Final articles complying with the previous rules could still be placed on the EU market for 18 months after entry into force — that is, until around July 2026. Specific categories get 36 months — around January 2028: certain varnishes and coatings (including external surfaces of metal packaging, and packaging used to preserve fruit, vegetables and processed fish), and repeat-use articles used in professional food production equipment. Silicone bakeware falls under the standard 18-month window — which has now passed. For silicone bakeware placed on the EU market today, bisphenol testing under Regulation (EU) 2024/3190 is a current requirement, not an upcoming one.
Why this matters if you buy or import
- Old reports are not enough. A test certificate that checks BPA against the pre-2024 limits says nothing about the new rules or about other bisphenols. If your supplier's report predates 20 January 2025, request an updated one.
- Market access is at stake. EU customs and retailers increasingly verify compliance documentation. Products without bisphenol testing under EU 2024/3190 risk delays at the border, retailer delisting, or liability downstream.
- Due diligence is your only defense. As the importer or distributor, the legal burden rests on the product in the market — not on the factory that made it.
What to ask your supplier (a 3-question checklist)
- "Does your food-contact test report cover bisphenols under EU 2024/3190?" — not just BPA, but the bisphenol group the regulation restricts.
- "Which laboratory issued the report, and when?" — accredited labs and reports issued after 20 January 2025 carry the most weight.
- "Does the report cover the exact material in my product?" — a silicone report should state the silicone material and its food-contact test standard (e.g. LFGB, which incorporates EU requirements; for silicone rubber the German BfR Recommendation XV gives the material-specific requirements).
Sources
- EUR-Lex — Commission Regulation (EU) 2024/3190 of 19 December 2024 (official text, incl. scope and transition periods)
- BfR — Recommendations on Food Contact Materials (Recommendation XV for silicone rubber)
Informational only — not legal or compliance advice. Requirements change and differ by market; confirm them with your own laboratory or regulatory adviser before committing to a purchase.
Last reviewed: September 2026.