New Contaminant Limits & BPA Ban: Your Blueprint for Compliance

The landscape of UK food safety is continually evolving, particularly in its alignment with EU standards under the UK-EU Sanitary and Phytosanitary (SPS) Agreement. A significant development requires immediate attention from all UK food and feed businesses: the introduction of new EU-aligned contaminant limits and a complete prohibition on bisphenol A (BPA) in food contact materials. These changes, formally updated on 25 June 2026, are not merely administrative; they demand a proactive and thorough review of your products, processes, and entire supply chain to ensure ongoing compliance. The UK government has made it clear that certain accommodations to EU law are necessary to uphold the SPS agreement, meaning these regulations will directly impact your operations. This blueprint outlines the practical steps you need to take now to prepare for these crucial updates.

What's Changing and Why It Matters for Your Business

The core of these forthcoming changes lies in establishing new, additional, and revised maximum levels for a range of contaminants in various foodstuffs. These stricter limits are designed to further protect public health and ensure a high standard of food safety across the board. For UK businesses, this means a rigorous re-evaluation of current practices and ingredients.

Specifically, EU Regulation 2023/915 introduces updated maximum levels for a number of hazardous substances, including:

• Per- and polyfluoroalkyl substances (PFAS): Often referred to as 'forever chemicals', these are a group of man-made chemicals found in various products, including some food packaging and processing equipment. New stringent limits will apply to their presence in certain foods.
• Heavy metals: Stricter maximum levels for heavy metals such as lead and cadmium will be enforced across a broader range of food products. These metals can accumulate in the body and pose significant health risks.
• Mycotoxins: Naturally occurring toxins produced by certain moulds, mycotoxins like aflatoxins and ochratoxin A will see revised limits, particularly in cereals, nuts, and dried fruits.
• Plant toxins: Specific plant toxins, which can naturally occur in certain botanical ingredients, will also be subject to new maximum levels.

Beyond contaminant levels, a critical change is the prohibition of bisphenol A (BPA). EU Regulation 2024/3190 explicitly bans the use of BPA and its salts in all food contact materials. BPA has historically been used in the manufacture of plastics and resins for food packaging, such as linings of food cans and reusable plastic containers. This prohibition necessitates that businesses begin reformulating products or altering their processes to eliminate BPA, ensuring all packaging and equipment that comes into contact with food is compliant. The deadline for full compliance with these updated rules is 25 June 2026, though further detailed guidance, including any exceptions and transition periods, is anticipated in summer and autumn 2026 from the UK government.

Your Blueprint for Action: Steps to Compliance This Week

1. Review Your Supply Chains Thoroughly: Begin by mapping out your entire supply chain, from raw ingredient sourcing to final product packaging. Identify all suppliers and the specific materials they provide. This includes not just food ingredients but also any food contact materials like packaging, containers, and processing equipment. Understand where potential contaminants or BPA might enter your system. For complex supply chains, consider engaging with a food safety consultant to help streamline this process. For more information on assessing risks, you might find our guide on [risk assessment](/risk-assessment) useful.
2. Conduct a Comprehensive Ingredient and Packaging Audit: Systematically audit all raw materials, ingredients, and food contact materials currently used in your operations. Cross-reference them against the list of regulated contaminants (PFAS, heavy metals, mycotoxins, plant toxins) and, crucially, check for the presence of BPA. Request technical specifications and declarations of conformity from all suppliers.
3. Engage Proactively with Your Suppliers: Contact all your suppliers immediately. Request written assurances and updated technical specifications confirming their compliance with EU Regulation 2023/915 (for contaminants) and EU Regulation 2024/3190 (for BPA prohibition). Ask about their plans for reformulating products or changing manufacturing processes to meet these new standards. Document all correspondence and commitments.
4. Update Your HACCP System and Risk Assessments: Your existing HACCP plan and associated risk assessments must be updated to incorporate these new contaminant limits and the BPA prohibition. Identify new Critical Control Points (CCPs) or Operational Prerequisite Programmes (OPRPs) required to monitor and control these risks. This might involve new testing protocols or supplier verification checks. If you need help with this, consider our [HACCP Level 3 course](/courses/haccp-level-3) or download our [HACCP template for restaurants](/free-guides/haccp-template-restaurants).
5. Plan for Product Reformulation and Process Adjustments: For any products identified as containing BPA in their food contact materials, or ingredients that exceed new contaminant limits, begin planning for reformulation or process changes. This could involve sourcing alternative packaging materials, changing ingredient suppliers, or modifying your manufacturing methods. Start trials and validation now to ensure a smooth transition by the deadline.
6. Train Your Team on the New Requirements: Educate all relevant staff members – from procurement and production to quality control and management – about these new regulations. Ensure they understand the implications for their specific roles and the importance of compliance. Training should cover how to identify non-compliant materials, new handling procedures, and updated record-keeping requirements.
7. Establish Robust Documentation and Traceability Systems: Maintain meticulous records of all supplier communications, product audits, risk assessment updates, reformulation efforts, and staff training. Your traceability system must be capable of tracking all ingredients and food contact materials back to their source, demonstrating due diligence and compliance with the new regulations. This will be crucial during any EHO inspection.
8. Stay Informed and Monitor Official Guidance: The UK government has indicated that further detailed guidance, including any exceptions and transition periods, is expected in summer and autumn 2026. Regularly check official government and FSA websites for updates. Kitchen Tonic will also provide timely summaries and practical advice as new information becomes available. Ensure your business is subscribed to relevant industry newsletters and alerts.

What Good Looks Like: Your Compliance Checklist

• All food contact materials are verified as BPA-free.
• Raw materials and ingredients are confirmed to be within new maximum contaminant levels (PFAS, heavy metals, mycotoxins, plant toxins).
• Supplier agreements include explicit declarations of compliance with EU Regulations 2023/915 and 2024/3190.
• Your HACCP plan and risk assessments are updated to reflect new contaminant and BPA risks.
• Staff are trained and aware of the new regulations and their responsibilities.
• Robust documentation exists for all compliance efforts, supplier communications, and product changes.
• You have a clear strategy for continuous monitoring and adapting to future regulatory updates.

Frequently Asked Questions

Why do UK businesses need to comply with EU regulations?

The UK-EU Sanitary and Phytosanitary (SPS) Agreement necessitates alignment on certain food safety standards to facilitate trade and ensure public health protection. The UK government has confirmed that some accommodations to EU law are required to uphold this agreement, meaning these EU regulations will effectively apply to UK food and feed businesses.

What if my current suppliers cannot meet the new BPA-free requirements?

You must actively seek alternative suppliers for food contact materials that can provide BPA-free options. This may involve researching new packaging solutions or working with existing suppliers to find compliant alternatives. Begin this process now to avoid supply chain disruptions closer to the 25 June 2026 deadline.

How can I ensure my products don't exceed the new contaminant limits?

This requires a multi-faceted approach: rigorous supplier verification, requesting analytical certificates for raw materials, and potentially implementing your own in-house or third-party laboratory testing protocols for high-risk ingredients. Updating your HACCP system to specifically address these contaminants is also crucial. Consider expert [food safety consulting](/services/consulting) for tailored advice.