In 2026, global regulations on food contact materials are entering a critical window of concentrated enforcement. For the empty can manufacturing industry, major regulations being implemented or advanced in both the European Union and the United States are imposing unprecedented compliance requirements on core segments such as can interior coatings, exterior varnishes, sealants, and printing inks. From the bisphenol A (BPA) ban to per- and polyfluoroalkyl substance (PFAS) limits, and from the regulatory logic of “intentional addition” to “presence triggers restriction,” can manufacturers are facing not a single technological upgrade but a comprehensive transformation covering raw materials, production processes, supply chain management, and compliance documentation.
I. EU BPA Ban: July 20, 2026, Is the Key Deadline
On December 31, 2024, the European Commission officially adopted Regulation (EU) 2024/3190, which systematically restricts the use of BPA and other bisphenols with certain hazardous classifications in food contact materials. The regulation entered into force on January 20, 2025.
Scope of application: BPA and its salts are prohibited in the manufacture of food contact plastics, varnishes and coatings, printing inks, adhesives, ion exchange resins, silicones, and rubbers. This covers can interior coatings, exterior varnishes, and printing inks widely used in the empty can industry.
Transition periods: Single-use finished food contact articles manufactured with BPA may be placed on the market until July 20, 2026. Packaging for preserving fruit, vegetables (except juices), and fishery products, as well as single-use articles with BPA‑containing coatings applied only on the exterior metal surface, may be placed on the market until January 20, 2028. In addition, articles that are first placed on the market within the transition period may continue to be used for filling and sealing food for 12 months after the transition period ends.
Residue requirement: When using other bisphenols as substitutes, the migration of BPA must be non‑detectable, with a detection limit of 1 μg/kg (1 ppb). From the respective deadlines, a declaration of compliance (DoC) is required at all stages of the supply chain.
Industry impact: Most single‑use empty cans must complete BPA substitution by July 20, 2026; products for fruit, vegetables, and fishery products, as well as those with coatings only on the exterior metal surface, benefit from an additional 18‑month transition period until January 20, 2028.
II. EU PFAS Limits: Effective August 12, 2026
The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) was published on January 22, 2025, and will fully apply from August 12, 2026.
Limit values: For food contact packaging, any individual PFAS substance (non‑polymer, targeted analysis) shall not exceed 25 ppb; the sum of all PFAS substances (non‑polymer, targeted analysis) shall not exceed 250 ppb; and the total fluorine content from polymeric PFAS shall not exceed 50 ppm.
Core principle: These limits apply to all PFAS, whether intentionally added or unintentionally present. There is no inventory depletion transition period — after August 12, 2026, no food contact packaging exceeding these limits may be placed on the EU market.
Industry impact: Coatings, sealants, and printing inks used on metal cans may contain PFAS. Since the restriction targets actual presence rather than intent, companies must verify compliance through testing, not merely rely on supplier declarations of “non‑intentional use.”
III. US FDA: Increasing Oversight and Major Legislative Changes on the Horizon
FCN list updates: In February 2026, the FDA added 15 substances to the effective Food Contact Substance (FCS) notification list in a single batch. The latest effective FCS notification list was published as of May 31, 2026.
Submission system upgrade: The FDA has introduced an AI‑assisted preliminary review module in the eSubmitter electronic submission system to automatically check format consistency and data completeness; non‑compliant submissions will be rejected.
Overseas facility inspections: In 2026, the FDA has significantly increased the frequency and depth of remote video inspections for foreign food contact material manufacturers.
Legislative developments: On June 9, 2026, the U.S. Senate introduced the “No Toxic Chemicals in Food Packaging Act of 2026″ (S.4724), with a companion bill (H.R.9231) introduced in the House on the same day. The bill would amend the Federal Food, Drug, and Cosmetic Act to automatically deem as unsafe for food contact use substances including phthalates, PFAS, bisphenol A, B, S, F, AF and related compounds, as well as acrylamide, benzene, formaldehyde, ethylene oxide, and dozens of other substances. It also requires that the assessment of substitute substances consider impacts on vulnerable populations (including infants, children, pregnant women, the elderly, and workers). If enacted, the provisions would take effect two years after the date of enactment. The bill is currently in the legislative process, having been referred to the Senate Committee on Health, Education, Labor, and Pensions.
IV. Compliance Recommendations for the Empty Can Industry
Identify product categories and deadlines: Most single‑use cans must complete BPA substitution by July 20, 2026; products for fruit, vegetables, and fishery products, as well as those with exterior‑only coatings, have until January 20, 2028; PFAS limits apply fully from August 12, 2026.
Establish supply‑chain traceability and compliance documentation: Ensure that all stages from raw material suppliers to importers can provide declarations of compliance, and that upstream suppliers supply adequate material evidence.
Rely on testing, not just declarations: For BPA substitutes, ensure that BPA migration is non‑detectable (1 μg/kg); for PFAS, verify actual concentrations through testing, as non‑intentional use claims alone are insufficient.
Accelerate alternative material validation: Switching to BPA‑free coatings requires re‑validation of adhesion, corrosion resistance, and food safety migration performance; early initiation is strongly advised.
2026 is set to be a pivotal year for regulatory compliance in the empty can industry. The EU BPA ban enters its critical enforcement phase on July 20, and PFAS limits take effect on August 12; meanwhile, U.S. legislative developments signal a convergence with EU regulatory directions. For can manufacturers serving both the European and American markets, “dual compliance” has become a tangible reality. Early planning and systematic responses will be key to gaining a competitive edge in this wave of regulatory upgrades.
Post time: Jul-15-2026