EU BPA Rules for Aluminum Beverage Cans: Does the 2028 Transition Apply?

1. What Is the EU BPA Regulation?

Commission Regulation (EU) 2024/3190 restricts the use of bisphenol A, commonly known as BPA, in specified food-contact materials, including varnishes and coatings used on metal packaging.

The regulation must be read together with its subsequent corrections, including Commission Regulation (EU) 2026/250.

For aluminum beverage packaging, the assessment should consider the actual coating systems used on the can body and easy-open end. A general description such as “food-grade aluminum can” does not establish compliance with the applicable BPA requirements.

2. Which Transition Date Applies to Aluminum Beverage Cans?

The general transition under Article 11 for qualifying single-use final food-contact articles ended on July 20, 2026.

A later deadline of January 20, 2028 applies to specific categories. Article 11(2)(b) covers single-use final food-contact articles where a varnish or coating manufactured using BPA has been applied only to the exterior metal surface.

The articles must also satisfy the relevant conditions, including compliance with the previously applicable rules.

The January 2028 deadline is a conditional transition. It is not a blanket extension for all aluminum beverage cans.

3. Why Does the Exterior Coating Matter?

Buyers often focus on the internal lining because it directly contacts the beverage. However, the exterior coating also needs attention.

European Commission guidance explains that exterior coatings can fall within the regulation’s scope where substances may reasonably be expected to transfer to food under normal or foreseeable conditions of use.

When reviewing a proposed can, ask the supplier to identify:

• The internal lining.
• The exterior varnish and coating system.
• The coating system on the easy-open end.
• The sealing compound used on the end.
• The product references covered by the supporting documents.

Do not assume that a statement covering the internal lining also covers the outside of the can or a separately supplied end.

4. Does BPA-NI Mean the Entire Can Is EU Compliant?

BPA-NI generally means that BPA is not intentionally added to the formulation. This description alone is not a complete compliance assessment of the finished packaging.

For example, a can may have a BPA-NI internal lining while its exterior coating uses a different formulation. Similarly, the matching easy-open end may come from another production source and require separate documentation.

A purchase specification should clearly identify which components the BPA-NI statement covers.

Buyers should also distinguish between:

• A statement about the formulation.
• Test results for a particular material or finished article.
• A declaration addressing the applicable legal requirements.

These documents serve different purposes. A formulation statement should not automatically be presented as proof that every component is free of every bisphenol or suitable for every beverage.

5. Is the Deadline Based on Production, Shipment or EU Market Placement?

The transition concerns first placing on the EU market.

A production date, purchase-order date or vessel departure date should not be used alone to establish that this event occurred.

For exports to the EU, the supplier and importer should agree on the relevant market-placement event and the evidence supporting it before scheduling a shipment close to the deadline.

This distinction matters when an order involves several stages:

1. Production of the empty cans and ends.
2. International shipment.
3. Import and first EU market placement.
4. Storage before filling.
5. Filling and sealing.
6. Distribution of the packaged beverage.

These stages should not be treated as interchangeable when applying the transition.

What About Filling After January 20, 2028?

Article 11(3) provides a further 12-month period for filling and sealing qualifying packaging first placed on the market within the applicable transition.

For packaging using the later transition, this period reaches January 20, 2029. The resulting packaged food may then be marketed until stocks are exhausted.

This additional filling period does not extend the first-placement deadline for new empty packaging.

6. What Documents Should Beverage-Can Buyers Request?

Build a document file for the actual can-and-end combination being purchased.

Article 8 and Annex III address declarations of compliance. The table above also includes practical purchasing controls; it is not a verbatim list of mandatory declaration fields.

7. How Should Buyers Plan Their Next Aluminum Can Order?

Before approving production, provide the supplier with the information needed to assess the proposed packaging:

• Destination market.
• Beverage type and relevant composition.
• Can capacity and format.
• Required easy-open end and technical drawing.
• Filling and processing conditions.
• Intended storage conditions and shelf life.
• Expected delivery and filling schedule.

For an ongoing EU product line, allow time to validate any coating change before committing to large inventories.

The customer’s purchasing policy also matters. A beverage brand or retailer may require an earlier change than the regulatory transition permits.

Agree on the complete packaging specification in writing, including both the can body and the matching end.

8. Aluminum Beverage Cans and Easy-Open Ends from ALUCAN

ALUCAN supplies aluminum beverage cans and compatible easy-open ends for beverage brands, breweries, co-packers and packaging distributors.

For projects intended for the EU market, share your beverage application, packaging specifications and delivery requirements. Request the coating specifications and available supporting documentation for the proposed supply before confirming the order.

Learn more about internal coatings for aluminum cans, or contact ALUCAN to discuss your packaging requirements.

Frequently Asked Questions

Official References

1. Commission Regulation (EU) 2024/3190 — current consolidated text
2. Commission Regulation (EU) 2026/250 — corrections to Regulation (EU) 2024/3190
3. European Commission implementation guidance C/2025/6721, read together with the subsequent 2026 correction.

This article provides a dated overview for packaging procurement. It is not a product-specific compliance declaration. Confirm the applicable requirements and the assessment of the actual packaging with the responsible EU operator before relying on a transition.