Material Insights · Understanding the Material World

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

ClassificationUN numberKey risks
polymer not classified; residual BPA is reproductive toxicant category 1B and endocrine disruptor (EU)not regulatedPhosgene used in the interfacial route is a war-gas-grade toxicant and drives Seveso classification of plants.

Main rules

WhereRuleEffect
EURegulation (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
EUBPA listed as a substance of very high concern under REACH (2017-2018, indicative)Disclosure duties; restrictions on thermal paper
EUSeveso III for phosgene sitesMajor-hazard controls
USFDA ended BPA use in baby bottles and sippy cups (2012, indicative)Limits on infant products

India

RuleEffect
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BIS quality-control order on polycarbonate (withdrawn 12 Nov 2025)Affects import ease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.