BPA receipts and thermal paper rules in the EU, UK and US

BPA receipts and what EU, UK and US rules say about thermal paper

BPA receipts used bisphenol A as the colour developer that makes print appear when thermal paper is heated. Since 2 January 2020, the EU and Great Britain prohibit placing thermal paper on the market with 0.02% or more BPA by weight (EU regulation, HSE report). The limit is written for thermal paper, so it covers thermal receipts and any other thermal paper placed on the market.

A "BPA-free" roll is not automatically bisphenol-free. ECHA documented manufacturers switching from BPA to bisphenol S (BPS), which later joined the EU Candidate List of substances of very high concern (ECHA survey, BPS listing).

The EU limit on BPA in thermal paper

The rule is entry 66 of REACH Annex XVII. Commission Regulation (EU) 2016/2235 added it on 12 December 2016 for BPA, CAS 80-05-7, EC 201-245-8. The wording states that BPA "shall not be placed on the market in thermal paper in a concentration equal to or greater than 0,02 % by weight after 2 January 2020."

That threshold equals 200 mg/kg. Paper below it meets this BPA restriction. The rule is about placing thermal paper on the market, not a ban on every use of BPA, and not a food limit. EFSA's 2023 tolerable daily intake of 0.2 nanograms per kg body weight per day concerns intake through food.

France's 2014 proposal identified a risk to workers, mainly cashiers handling cash register receipts, and to consumers handling thermal paper, specifically the unborn children of pregnant workers and consumers. RAC confirmed the worker risk and found consumer risk adequately controlled. SEAC judged the restriction "unlikely to be proportionate". The Commission still found paper at or above 0.02% BPA an unacceptable risk to workers, and deferred application for 36 months (Regulation 2016/2235).

BPA in receipts in Great Britain

Great Britain kept the same limit. HSE's July 2025 technical report says thermal paper placed on the GB market must contain less than 0.02% BPA. That is entry 66 of Annex 17 to GB REACH, applying from 2 January 2020. HSE links the GB restriction list from its UK REACH restrictions page.

BPA vs BPS in receipt paper

ECHA's June 2020 survey recorded the switch from BPA to BPS. In 2019, 187 kilotonnes of BPS-based thermal paper were placed on the EU market. HSE's summary of that survey puts the end-2019 developer split at 29% BPA, 39% BPS and 32% other developers.

ECHA expected about 61% of EU thermal paper, 307 kilotonnes, to be BPS-based by 2022. That was a forecast, not a later measurement. The same update recalled a 2015 committee view: the BPA restriction would reduce risks only if firms chose a developer other than BPS.

BPA entered the EU Candidate List on 12 January 2017 for reproductive toxicity. Later updates added endocrine disruption for human health and for the environment (ECHA). BPS, CAS 80-09-1, joined on 17 January 2023 for reproductive toxicity and endocrine disruption for human health and the environment (Candidate List entry). Candidate List status is not a restriction on thermal paper.

Are receipts toxic to handle?

HSE's July 2025 technical report separates the hazard of a developer from the risk of handling receipts. The report is a technical assessment, not a restriction proposal, and its conclusions are without prejudice to future regulatory work. HSE accepts that BPS has a similar hazard profile to BPA, including oestrogenic activity. It still concludes that it seems unlikely BPS in thermal paper will be hazardous to human health. The BPA and BPS Candidate List grounds are reproductive toxicity and endocrine disruption, not carcinogenicity.

HSE describes the original BPA risk to cashiers as marginal, with a risk characterisation ratio of only 2 and no consumer risk identified in that assessment. BPS is absorbed less across skin than BPA. Cashless payments and electronic receipts probably mean people, including cashiers, handle thermal paper less often (HSE).

For the environment, HSE concludes that "total emissions of BPS potentially represent a risk to the environment". Monitoring indicates about 1.5 to 75 tonnes of BPS, from all sources, reach GB rivers each year, and river monitoring exceeds the aquatic PNEC of 0.025 mg/L. That PNEC is an assessment value, not a discharge limit. HSE cannot yet separate thermal paper's share from other sources. Hazard data are scarce for many developers. Manufacturers do not disclose which developers they use (HSE).

BPA-free vs phenol-free thermal paper

A BPA-free label on thermal paper rolls does not say which developer replaced BPA. ECHA's survey is why buyers should ask whether the replacement is BPS.

Phenol-free receipt paper is not a category defined by entry 66. Ask the supplier to name the non-bisphenol developer. HSE names Pergafast 201 as apparently the most widely used non-bisphenol option. An EU substance evaluation found no reproductive or endocrine-disrupting effects and negligible skin uptake. HSE judged it unlikely to create human health risks, and lacked enough information to conclude on environmental risk (HSE report). Ask for the developer name, the CAS number and the evidence that the roll meets the thermal-paper limit that applies. A marketing label is not that evidence.

BPS in thermal paper is not restricted

Germany's new filing is an intention, not an adopted restriction. ECHA Weekly, 27 May 2026 reports an intention submitted on 23 April 2026 for bisphenols with endocrine-disrupting properties for the environment and their salts. It covers BPA, BPS, BPB, BPF, BPAF and BPAF salts, with thermal paper in scope. ECHA expects the restriction proposal by 12 March 2027. That is a proposal date, not the date a limit would start.

Germany's earlier proposal was withdrawn in 2023. As of 6 October 2026, no EU or GB restriction on BPS in thermal paper is in force. Watch the restriction-intentions registry for that intention.

BPA in receipt paper in the US

EPA's thermal-paper alternatives assessment is not a federal ban. Its January 2014 report, corrected on 8 September 2015, assessed BPA and 19 alternatives. None of the functional alternatives had low concern across every human health and environmental endpoint. Inclusion is not an EPA endorsement. Those EPA pages do not set a national limit on BPA in receipt paper. State requirements include:

• Connecticut's Public Act 11-222 prohibits manufacturing, selling or distributing BPA-containing thermal receipt paper. It sets 1 October 2013, or 1 July 2015 if EPA had not identified a safe, commercially available alternative by 30 June 2013.
• Illinois 415 ILCS 5/22.61 bans manufacturing BPA thermal paper for sale in the state from 1 January 2020, and bans its distribution or use for business or banking records, including receipts. Exemptions cover paper made before that date and paper containing recycled material.

RegAffairs AI's answer on BPA in thermal paper cites entry 66, the HSE findings and the BPS Candidate List entry.