National Organic Standards Board

Handling Subcommittee

Bisphenol A (BPA) in Packaging Discussion Document

February 21, 2017

I. INTRODUCTION

The National Organic Standards Board (NOSB) initiated a work agenda item for evaluating packaging 

materials in 2013. At this time, the Handling Subcommittee (HS) has decided to proceed with a 

discussion document to collect input from organic stakeholders on this issue while an independent 

technical report is in process. 

Bisphenol A (BPA) is a chemical widely used in manufacturing polycarbonate plastics and epoxy resins 

used in many industries, including the lining of cans for food. Releases of BPA to the environment 

exceed 1 million pounds per year (EPA, 2010). It is a known endocrine disruptor, and several studies and 

biomonitoring programs demonstrate that BPA leaches out of the linings of cans used for food and that 

human populations are widely exposed (EPA, 2010). For example, BPA was frequently detected in 

participants in U.S. CDC and California biomonitoring programs (CDC; State of California 2017a) and 

studies worldwide (Vandenberg LN et al., 2010). Several studies indicate that food contact materials are 

a primary source of BPA exposure in humans (Carwile et al., 2011; Rudel et al. 2011). For example, in 

2011, researchers at the Harvard School of Public Health determined that volunteers who ate a single 

serving of canned soup a day for five days had ten times the amount of BPA in their bodies as when they 

ate fresh soup daily (Carwile et al., 2011). Several studies suggest BPA may be harmful to human health 

at low exposure levels (Sowlat et al., 2016, Rochester JR, 2013, Ejaredar M, 2016) and it is listed as a 

chemical known to be a reproductive toxicant under the California Safe Drinking Water and Toxic 

Enforcement Act (State of California 2015).

BPA is currently allowed for use in cans and other packaging containing organic food. In the interest of 

organic integrity for processed foods, the NOSB is reviewing concerns about BPA in the same way that 

other synthetic materials that come into contact with organic food are evaluated. 

While some organic processors have found alternatives to BPA in their products, the NOSB does not 

have information on how much BPA is still used in organics and whether alternative packaging materials 

are widely used. The NOSB would also like to know more about what alternatives to BPA are being used

and if any of the alternative materials might raise human health concerns. The Handling Subcommittee 

and most organic consumers agree that organic food should be produced in a manner that minimizes 

exposure to toxic materials in any form. Therefore, this discussion document will alert stakeholders to 

this issue and begin information gathering to determine whether changes are needed in the regulations 

to ensure harmful substances do not come into contact with organic food.

II. BACKGROUND

In December 2013 a request was submitted by the NOSB Handling Subcommittee to the National 

Organic Program to add the issue of BPA in packaging to the NOSB work agenda. In November 2014 the 

NOP issued a Memorandum to the NOSB, titled “Packaging substances used in organic food handling”, 

in which the NOP acknowledged the request and that there were recent studies that raised concern 

about BPA and similar packaging substances. They suggest: 

"That NOSB start with a discussion paper that provides a review of current literature, evaluation 

of current uses in the organic market, availability and suitability of alternatives, and impact of 

removal of these packaging substances on the organic trade." 

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The memorandum was accompanied by a letter from Senator Dianne Feinstein that supports a ban on 

BPA.

Additionally, several public comments addressing plastics and BPA were submitted in 2015 and 2016. 

These comments raised human health and environmental concerns about the use of plastic packaging 

for organic foods, and many specifically focused on BPA. 

A request for a Technical Report (TR) was submitted in August 2015. The following specific issues were 

posed to the writers of the TR:

• "There is much criticism by both sides of the BPA safety debate over the validity of various 

research methods, from what breed of rats are used to human cell studies in vitro vs. animal 

studies. There are also collusion, conflict of interest, and bias contentions in some research 

efforts. Please examine these objectively using the citations below and others, and give an 

evaluation of which research is the most valid.

• Evaluate the conclusion from the paper by Yang cited above that they can identify existing 

compounds, additives, or processing agents that have no detectable estrogenic activity and have 

similar costs. What are these alternatives?

• Review recent research on some of the BPA alternatives in use, such as Tritan (containing 

triphenyl phosphate or TPP), Bisphenol S (BPS) and Bisphenol F (BPF) and any others. Some 

citations are below.

What is the status of BPA in other countries? How widespread are bans on BPA and are any of 

the alternatives banned as well? What evidence was used in making those determinations?"

The NOP contracted for the TR in January 2016 with the Agricultural Analytics Division of the USDA 

AMS. The TR was provided to the NOSB on October 19, 2016. In December of 2016 the HS

determined that the report was technically insufficient according to the criteria in the NOSB PPM. In 

response, NOP issued another statement of work to externally contract this work and OMRI 

received the award for BPA. The OMRI report is currently in development.

III. RELEVANT AREAS OF THE RULE

§205.272 Commingling and contact with prohibited substance prevention practice standard.

(a) The handler of an organic handling operation must implement measures necessary to prevent 

the commingling of organic and nonorganic products and protect organic products from contact with 

prohibited substances.

(b) The following are prohibited for use in the handling of any organically produced agricultural 

product or ingredient labeled in accordance with subpart D of this part:

(1) Packaging materials, and storage containers, or bins that contain a synthetic fungicide, 

preservative, or fumigant;

(2) The use or reuse of any bag or container that has been in contact with any substance in such a 

manner as to compromise the organic integrity of any organically produced product or ingredient placed 

in those containers, unless such reusable bag or container has been thoroughly cleaned and poses no 

risk of contact of the organically produced product or ingredient with the substance used.

IV. DISCUSSION

In this discussion the NOSB Handling Subcommittee is seeking information from the industry on several 

points, including whether BPA should be prohibited and how widespread BPA is used in organic foods. 

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The HS would also like to collect information on the factors that affect the choice of alternatives and 

what those alternatives are. This information will be considered along with the final TR when it is 

publically available. 

A. Should BPA be prohibited?

A concise summary of the situation regarding BPA is described in the Environmental Protection Agency 

BPA Action Plan (EPA, 2010).

"Because BPA is a reproductive, developmental, and systemic toxicant in animal studies and is 

weakly estrogenic, there are questions about its potential impact particularly on children’s 

health and the environment. Studies employing standardized toxicity tests used globally for 

regulatory decision-making indicate that the levels of BPA in humans and the environment are 

below levels of potential concern for adverse effects. However, results of some recent studies 

using novel low-dose approaches and examining different endpoints describe subtle effects in 

laboratory animals at very low concentrations. Some of these low-dose studies are potentially of 

concern for the environment because the concentration levels identified with effects are similar 

to some current environmental levels to which sensitive aquatic organisms may be exposed.

Regulatory authorities around the world reviewing these low-dose studies have generally 

concluded that they are insufficient for use in risk assessment because of a variety of flaws in 

some of the study designs, scientific uncertainty concerning the relevance to health of the 

reported effects, and the inability of other researchers to reproduce the effects in standardized 

studies. However, since the low-dose studies do raise questions and concerns, some authorities 

have taken action to protect sensitive populations, particularly infants and young children."

The latest review from the Food and Drug Administration, published in June 2014 (FDA, 2014), reviewed 

all the literature since the previous review in 2008:

"The conclusion of this report is that an adequate margin of safety exists for BPA at current 

levels of exposure from food contact uses." 

FDA also note that there is significant uncertainty associated with extrapolating safety data obtained 

from rodents and non-mammalian chordates to primates (including humans) because there is a 

decreased capacity of non-primates to metabolize BPA and there have been large variability in study 

results. 

On the other hand, scientific articles are being published regularly that show that low doses of BPA may 

be more harmful than higher doses, and that these troubling results are resulting from well conducted 

research (Johns et al. 2016, Kinch et al. 2015, Science Daily). 

For example, human epidemiological studies have shown associations between BPA and a number of 

adverse outcomes on child behavior, metabolic disorders, and fertility, among other outcomes. 

Additionally, in 2015 BPA was listed as a chemical known to the state of California to cause reproductive 

toxicity (Rochester 2013, Johns et al. 2016, Sowlat et al. 2016, Ejaredar et al. 2016, State of California 

2015). 

There are also concerns about two of the main alternatives to BPA: BPS and BPF. For example, BPS and 

BPF share similar chemical structures with BPA and may have estrogenic activity and act by similar 

mechanisms (Hashimoto et al. 2001, Rochester and Bolden 2015, Chen 2002, Kinch et al. 2015).

Individual epidemiologic studies are observational and therefore cannot show causation. However, 

human studies are most relevant to inform our understanding of human health risks, and a growing 

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literature suggests that BPA may adversely impact human health, potentially at environmentally 

relevant levels. Finally, as described above, there is evidence of widespread human exposure with food 

packaging materials as a primary exposure source.

In summary, as evidence of negative effects on health builds and organic consumers raise concerns 

about their food choices, evaluation of BPA and similar chemicals by the NOSB is warranted. 

B. How much BPA is in use in organic food?

Many, but not all, organic brands have removed BPA from food contact materials 

(http://www.ewg.org/research/bpa-canned-food). Also, very few companies label their cans as not 

having BPA so it is hard for consumers to make informed decisions from food labels. A report from the 

Environmental Working Group provides some information on BPA substitutes used in canned food

(EWG, 2015). However, there does not appear to be any independent testing to verify that cans are 

BPA free. The state of California is developing a database of canned products containing BPA (State of 

California 2017b), but this data set has not been evaluated in relation to organic products. In summary, 

more information is needed before the NOSB can make a decision.

C. What alternative materials and practices are being used by organic processors and what factors are 

prohibiting more products from using alternatives?

• There are can coatings that do not contain epoxy resins, such as those with polyester.

• Baked organic coatings have been used in cans, including oleoresinous, epoxy-amine, and acrylic 

enamel coatings. Oleoresinous coatings are made from vegetable oil and resin (Deshpande 

1995).

• Glass jars are a good alternative although there may still be BPA used in the sealing ring under 

the lid.

• More BPA migrates from the can lining into the food at higher temperatures and over longer 

time sitting on the shelf. So processing at lower temperatures and not storing canned goods for 

long periods will lessen exposure. BPA leaching can also be minimized by increasing the curing 

time for coatings that contain it. It is not possible for consumers to find out if the curing of the 

cans for any individual brand was done correctly (Rossi et al. 1970, Lambert et al. 1998). 

• Polyethylene and polypropylene packaging can be used instead of BPA cans. These are likely to 

have less estrogenic activity (Yang et al. 2011). Bioplastics from starch materials, cellulose 

materials, polylactic acid (Polyester, PLA), polyhydroxy acid (polyester, PHA) that are not only 

BPA free, but have melting points above 200o

C, good moisture barrier characteristics and good 

compostability and biodegradability properties are now in development (Siracusa et al., 2008)

The bioplastics may be combined with nanoscale fillers such as layered silicate nanoclays, e.g. 

montmorillonite and kaolinite which may also have a role in effective and environmentally 

friendly food packaging (Rhim et al, 2013). Bioplastics may be problematic for organic food 

producers because they are often sourced from genetically modified corn. Currently there are 

no restrictions on these products. 

V. REQUEST FOR PUBLIC COMMENT

The NOSB is requesting public comment from both companies who no longer use BPA in packaging, and 

from those who still think it is necessary. From the former group we would like to hear what is being 

used instead, and how well it is working. From the latter we would like to know what, if anything, has 

been tried and rejected, and why. Also, we would like to know reasons why it is still important for 

specific product categories to allow BPA in packaging. Specific questions include:

A. Should BPA be prohibited?

B. How widespread is the use of BPA in organic canned foods utilizing metal cans? 

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C. How widespread is the use of BPA in lids or other materials in contact with canned organic food 

in glass jars?

D. Is BPA present in any other packaging or processing materials that are in contact with organic 

food?

E. The California Office of Environmental Health Hazard Assessment has compiled a database of 

canned foods with BPA in metal can liners or jar lids: https://www.p65warnings.ca.gov/bpalist

Is this database complete and have any members of the organic community examined this data 

to determine the prevalence of organic brands using BPA? 

F. Are there specific product categories where BPA should be allowed if some uses, such as BPA in 

linings for canned foods, are prohibited?

G. What alternatives materials and practices have been chosen by organic processors and how well 

are they working? 

H. Have any alternative materials been tried and rejected? If so, why?

I. What factors are prohibiting more products from using alternatives?

J. What are the human health and/or environmental concerns of BPA alternatives, such as BPS and 

BPF? 

The NOSB welcomes comments on the use of BPA in food packaging. Please see 

https://www.ams.usda.gov/event/nosb-spring-2017-meeting-denver-co for information on how to 

submit written or oral comments for the Spring 2017 meeting.

Vote in Handling Subcommittee 

Motion to accept the BPA discussion document 

Motion by: Scott Rice

Seconded by: Lisa de Lima

Yes: 6 No: 0 Abstain: 0 Absent: 2 Recuse: 0

References

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Approved by Lisa de Lima, Subcommittee Chair, to transmit to NOSB, January 17, 2017

NOSB APRIL 2017 proposals and discussion documents 53/137