###### Abstract
In this project, taking evidence from animal data into account and with support from human observational studies, the immune system was identified as most sensitive to BPA exposure. As a result, in 2023, a new TDI of 0.0002 \(\mathrm{\SIUnitSymbolMicro g}\)/kg bw/d was established [17], which is lower than the previous (temporary) TDI of 4 \(\mathrm{\SIUnitSymbolMicro g}\)/kg bw/d by a factor of 20,000. The TDI of 0.0002 \(\mathrm{\SIUnitSymbolMicro g}\)/kg bw/d would translate for a default 60 kg person eating one kilogram of food into a migration limit of 0.012 \(\mathrm{\SIUnitSymbolMicro g}\)/kg in food for intentionally added BPA. In this 2023 opinion, the EFSA concluded that there is a health concern for the consumer from dietary BPA exposure, as the dietary exposure estimates previously determined in 2015 [14] exceeded the new TDI in all population age groups by two to three orders of magnitude. The EFSA opinion of 2023 [17] has been critiqued in the public domain and by national food safety and health protection bodies. The European Medicines Agency (EMA) is not in agreement with the change to the temporary TDI to the currently revised TDI of 0.0002 \(\mathrm{\SIUnitSymbolMicro g}\)/kg bw/d [18]. Also, the Senate Commission on Food Safety (SKLM), which provides scientific advice on food safety issues to the Senate of German Research Foundation (DFG) as well as to federal/state governments and other authorities, published a critical discussion on the HBGV on BPA [19]. The German Bundesinstitut fur Risikobewertung (BfR) commented critically on the outcome of the EFSA opinion and made a re-evaluation of the critical toxicological endpoints identified by the EFSA with the intention to provide an independently derived TDI [20]. The result was a TDI of 0.2 \(\mathrm{\SIUnitSymbolMicro g}\)/kg bw/d, which is higher than the proposed new EFSA TDI of 0.0002 \(\mathrm{\SIUnitSymbolMicro g}\)/kg bw/d by a factor 1000 [17]. The BfR considered their TDI as a health-based guidance value (HBGV) which is protective enough to exclude immunological effects in humans from BPA exposure. The UK Committee on Toxicity of Chemicals in Food, Consumer Products and the Environment (COT) concluded that the endpoint selected and approach applied by the BfR were more scientifically robust and appropriate than those used by the EFSA and agreed to adopt the TDI of 0.2 \(\mathrm{\SIUnitSymbolMicro g}\)/kg bw per day derived by the BfR [21]. For the default consumer adult (60 kg person), the migration limit would then be at 12 \(\mathrm{\SIUnitSymbolMicro g}\)/kg food, thus being in the range of the well-known 10 \(\mathrm{\SIUnitSymbolMicro g}\)/L limit, which is still broadly considered to be an analytically manageable detection limit either for specific migrants such as vinyl chloride monomer or for NIAS [20]. Inresponse to the outcome of the EFSA's BPA re-evaluation, the European Commission quite recently published a draft regulation to ban the use of BPA in FCMs [22]. In this regulation, the European Commission stated that an FCM must not contain BPA or must not release BPA above the detection limit, which is set in Article 9(2)(b) to 1 \(\upmu\)g/kg. It is quite obvious that the new EFSA TDI of 0.0002 \(\upmu\)g/kg bw/d (or 0.012 \(\upmu\)g/kg for an adult person) will present analytical chemists--even the most experienced and best-equipped ones--with unresolvable tasks with regards to measuring BPA levels at such low concentrations in foods. It appears that control of such low exposure thresholds cannot be achieved even by modern instrumental analytical devices. The BfR HBGV, which is higher than the EFSA TDI or the EU Commission threshold limit of 1 \(\upmu\)g/L by a factor 1000, is much more likely to be analytically verifiable in simple food simulants but still expected to be very challenging for measurements of BPA in foods due to their complex composition.