Polycarbonate: Regulation
Phosgene hazards and the EU's food-contact BPA ban
Phosgene hazards and the EU's food-contact BPA ban What this tab covers How it is regulated and what could disrupt supply: hazard classification, rules in the EU, US and India, anti-dumping duties and other trade measures, and supply-risk notes.Hazards
| Classification | UN number | Key risks |
|---|---|---|
| polymer not classified; residual BPA is reproductive toxicant category 1B and endocrine disruptor (EU) | not regulated | Phosgene used in the interfacial route is a war-gas-grade toxicant and drives Seveso classification of plants. |
Main rules
| Where | Rule | Effect |
|---|---|---|
| EU | Regulation (EU) 2024/3190 banning BPA in food-contact materials, applying from 20 January 2026 with transition periods (indicative) | Ends PC baby bottles, water-cooler bottles and kitchenware in the EU |
| EU | BPA listed as a substance of very high concern under REACH (2017-2018, indicative) | Disclosure duties; restrictions on thermal paper |
| EU | Seveso III for phosgene sites | Major-hazard controls |
| US | FDA ended BPA use in baby bottles and sippy cups (2012, indicative) | Limits on infant products |
India
| Rule | Effect |
|---|---|
| BIS standard for BPA-free infant feeding bottles (IS 14625, indicative) | Limits PC in infant products |
| MSIHC Rules 1989 (phosgene, chlorine) | Major accident hazard controls |
| BIS quality-control order on polycarbonate (withdrawn 12 Nov 2025) | Affects import ease |
Trade measures
- No major PC anti-dumping duty found in sources reached
- BPA anti-dumping petitions in India (BPA tile)
Supply risk
Moderate. China is about 45% of capacity and Covestro and SABIC over 40%. BPA health regulation is a demand risk, not a supply one.