ECHA’s Committee for Socio-Economic Analysis (SEAC) launched a 60-day public consultation on the draft opinions on BPA and PFOA in September 2015, and will adopt the final opinions in December 2015. Based on RAC’s and SEAC’s opinions, the European Commission (EC) will ultimately decide on the restriction of BPA and PFOA and their inclusion in the Restriction List (Annex XVII) of REACH. The proposed restriction is as follows.

Name & StructureScope and Conditions of Restriction
Bisphenol-A (BPA)   CAS No 80-05-7 EC No 201-245-8 Shall not be placed on the market in thermal paper in concentrations equal to or greater than 0.02% by weight [entry into force + 36 months]
Perfluorooctanoic acid (PFOA)   CAS No 335-67-1 EC No 206-397-9 PFOA salts and PFOA-related substances 1. Shall not be manufactured, used or placed on the market   – as substances, – as constituents of other substances in concentrations equal to or above 20 ppb PFOA and 10000 ppb PFOA-related substances, – in a mixture in concentrations equal to or above 5 ppb PFOA and 1000 ppb PFOA-related substances. 2. Articles or any parts thereof containing one of the substances in concentrations equal to or greater than 2 ppb PFOA and 100 ppb PFOA-related substances shall not be placed on the market. 3. Paragraph 1 and 2 shall apply from (18 months after entry into force). 4. By way of derogation, paragraph 2 shall not apply to the placing on the market of second-hand articles for which an end-use in the European Union being before the restriction becomes effective can be demonstrated. 5. By way of derogation, paragraph 2 shall not apply to the placing on the market of recycled material. 6. By way of derogation, paragraph 1 and 2 shall not apply to – use in Photo imaging processes and products until 2030 – use in semiconductor industry until 2025 – fire fighting foam already in stock until 2030 – medical devices until 2020 – implantable cardiovascular devices until 2030 7. The concept of lead substances shall be applied for enforcement.

Risk Analysis

BPA in plastic baby bottles and other plastic products may affect the development of an infant’s growth, and damage the children’s brain and other organs. It is mainly used for producing polycarbonate, epoxy resin, polysulfone resin, polyphenylene ether resin and other polymer materials. It can be used in the production of plasticizer, flame retardant, antioxidant, pesticide, paint and other fine chemical products.

PFOA is a persistent, toxic, and bioaccumulative substance. Due to these properties it may cause severe and irreversible adverse effects on the environment and human health. PFOA contains fluorine and whole fluorine acid salts, it is mainly used in the surface treatment of household products, convenience food packaging, anti fouling materials, clothing and other consumer goods.