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Comment 13526
New (Unresolved)
51i29r3 - Bisphenols and PFAS - Straw Ballot and Description.pdf (Revision 0)
Approval of 51i29r3 - Bisphenols and PFAS - Straw Ballot and Description.pdf
Comment Submitted by
Danielle M. Escolas
2025-08-04 22:12:58

Requiring no intentionally added bisphenols does not align with current FDA requrirements (https://www.fda.gov/food/food-packaging-other-substances-come-contact-food-information-consumers/bisphenol-bpa-use-food-contact-application) and as such would present the same complications as the original langugage for PFAS did in regard to use of 21 CFR compliance statements for food zone, indirect contact surfaces. 

Submitter Proposed Solution

Make Bisphenol free an optional requirement with permitted labeling since the FDA currently allows BPA to be used in food equipment. This allows manufacturers to choose to comply with more stringent requirements without being in conflict with the FDAs position.