Israel Tightens Food-Contact Plastic and Rubber Standards Amid Health Concerns

Israel has updated its public health protection orders to restrict bisphenol use in food-contact materials, aligning with EU scientific assessments and enforcing stricter compliance for plastic and rubber products in food contact.

ISRAEL – FOOD-CONTACT MATERIALS

Israel Bans Bisphenols in Food-Contact Plastics and Rubber

Manufacturers and importers must use BPA-free materials to meet new EU-aligned standards.

What changed

Bisphenol use restricted in food-contact plastics and rubber due to health risks.

BPA-free standards required for all products in the food contact supply chain.

EU Regulation (EU) No 10/2011 now applies to plastic materials and articles.

Stricter material safety thresholds adopted under Regulation 2024/3190.

Who it affects

Manufacturers of food-contact plastics and rubber must ensure products are BPA-free.

Importers must only bring in compliant materials that meet the new standards.

Distributors in the food supply chain must handle only approved materials.

Israel — food-contact material standards and bisphenol ban

Regulation Analysis: Israel’s Updated Restrictions on Bisphenol Use in Food-Contact Materials

Israel has aligned its public health protection orders with Commission Regulation (EU) 2024/3190 to restrict the use of bisphenol A (BPA) and other bisphenols in food-contact materials (FCMs). The updated framework introduces a general prohibition on BPA and hazardous bisphenols, with limited exemptions and transitional provisions, while maintaining Israel’s existing partial adoption model for EU FCM regulations.

1. Legal Framework and Scope

Primary Regulation

Public Health Protection (Food) Law, 5775-2015 ("Food Law")^{1, 2}:
- Adopts EU Regulation 10/2011 (plastic FCMs) via Addendum II, Item 16, but only for specific operators:
- Approved importers importing food via the "European route"¹.
- Manufacturers holding a valid production permit or compliance commitment under Section 321(a) of the Food Law¹.
- Marketers sourcing food from the above operators¹.
- Exclusions: Other FCMs (e.g., non-plastic materials) fall under the Standards Law, 1953, enforced by the Ministry of Economy¹.

Adoption of EU 2024/3190

Draft Order (2026): Proposes adopting EU 2024/3190 with partial exemptions, mirroring the scope of EU 10/2011 in Israel^{1, 2}.
- Key changes:
- Repeals EU 2018/213 (prior BPA restrictions)².
- Amends EU 10/2011:
- Deletes entries for BPA (CAS 80-05-7, "2,2-bis(4-hydroxyphenyl)propane") and 4,4-dihydroxydiphenyl sulphone (CAS 80-09-1) from Annex I, Table 1^{1, 2}.
- Adds new substances (e.g., CAS 1094) with migration limits¹.
- Replaces references to EU 10/2011’s Section 6 with EU 2024/3190 for bisphenol regulation¹.

2. Key Requirements

Prohibition and Exemptions

Requirement	Deadline	Authority	Source
General ban on BPA and bisphenols with harmonized hazardous classifications in FCMs.	20 Jan 2025 (EU); 2 Aug 2026 (Israel)	Ministry of Health	^{2, 1}
Exemptions for essential uses (e.g., coatings for metal FCMs) if no migration into food occurs.	2 Aug 2026	Ministry of Health	²
Deletion of BPA (CAS 151) and 4,4-dihydroxydiphenyl sulphone (CAS 154) from EU 10/2011’s positive list.	2 Aug 2026	Ministry of Health	^{1, 2}
Addition of 6 new substances (e.g., CAS 1094) to Annex I, Table 1 of EU 10/2011, with migration limits.	2 Aug 2026	Ministry of Health	¹

Transitional Provisions

Single-use FCMs (e.g., polycarbonate bottles, coated cans):
- Pre-existing stock (manufactured before 20 Jan 2028) may be used until depletion if compliant with prior regulations^{1, 2}.
- Filled and sealed single-use FCMs (e.g., canned fish, fruits/vegetables) may be marketed until 20 Jan 2029 if sealed by 20 Jan 2028¹.
Reusable FCMs (e.g., professional food-production equipment):
- Pre-existing stock may be marketed until 20 Jul 2027¹.
- New stock (professional equipment) may be marketed until 20 Jan 2028 and used until 20 Jan 2029¹.

3. Compliance and Enforcement

Obligations for Operators

Importers/Manufacturers:
- Must ensure FCMs comply with EU 2024/3190 if operating under the European route or holding a production permit¹.
- Testing: Migration limits must be verified by "recognized laboratories" (defined in Section 2 of the Food Law)¹.
Excluded Provisions:
- EU 2024/3190’s Section 5(3) (derogations for non-approved bisphenols) is not adopted in Israel¹.
- Sections 6, 7, and 9(3) (EU-specific approval processes and testing methods) are excluded¹.

Penalties

Non-compliance with FCM regulations under the Food Law may result in:
- Administrative sanctions (e.g., product recalls, fines)¹.
- Criminal penalties (up to 1 year imprisonment or fines under Section 202 of the Food Law)¹.

4. Implementation Timeline

Milestone	Date	Source
EU 2024/3190 enters into force (EU).	20 Jan 2025	²
Israel’s draft order published (proposed adoption of EU 2024/3190).	2026 (expected)	¹
Israel’s adoption effective date (if published in Reshumot by this date).	2 Aug 2026	¹
Deadline for marketing pre-existing single-use FCMs (filled/sealed).	20 Jan 2029	¹

Summary Answer

Israel has updated its food-contact material (FCM) regulations to prohibit bisphenol A (BPA) and hazardous bisphenols, aligning with EU Regulation 2024/3190². The ban applies primarily to importers, approved manufacturers, and marketers under the Public Health Protection (Food) Law, 5775-2015, with transitional periods extending to 20 Jan 2029 for pre-existing stock¹. Key changes include deleting BPA from the positive list in EU 10/2011’s Annex I and adding new substances (e.g., CAS 1094) with migration limits¹. Compliance is enforced by the Ministry of Health, with testing required by recognized laboratories¹. Exemptions are limited to essential uses (e.g., metal coatings) where no migration occurs². The updated framework reflects Israel’s partial adoption model for EU FCM regulations, excluding certain procedural provisions (e.g., EU approval processes)¹.

Sources

↩ WTO SPS notification 26-03913 — Israel https://members.wto.org/crnattachments/2026/SPS/ISR/26_03913_00_e.pdf
↩ WTO SPS notification 26-03912 — Israel https://members.wto.org/crnattachments/2026/SPS/ISR/26_03912_00_e.pdf