Q.01

Is BPA in till receipts (thermal paper) restricted in the EU and UK, what does the REACH Annex XVII restriction on bisphenol A in thermal paper require, and what did the HSE / UK REACH assessment and ECHA say about BPS and other bisphenol alternatives in thermal paper?

Yes. BPA in till receipts is restricted in both the EU and Great Britain. Thermal paper may not be placed on the market with 0.02% or more BPA by weight, and this has applied since 2 January 2020 [1][2]. BPS, the main replacement, has no thermal-paper restriction in either jurisdiction yet.

  • ECHA and its committees: they warned that replacing BPA with BPS would bring little risk reduction, and ECHA's assessment of regulatory needs lists restriction as the foreseen step for BPS.
  • HSE (2025): it concluded that BPS in thermal paper is unlikely to harm human health. It did find that total BPS emissions may be a risk to the environment.

Approach: I searched REACH Annex XVII and Regulation (EU) 2016/2235, the GB REACH restriction and Candidate lists, HSE's UK REACH technical reports, ECHA's restriction files and regulatory-needs assessments, the EU Candidate List, CLP Annex VI and the GB MCL list. I also checked ECHA's own website for its 2020 thermal paper survey.

1. What the restriction requires (EU Annex XVII entry 66, mirrored in GB)

The legal requirement

  • Wording: "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." [1]
  • Legal act: the entry was added by Commission Regulation (EU) 2016/2235 of 12 December 2016 [3][4].
  • What it covers: placing thermal paper on the market. It is not a ban on making or using BPA generally.

Why it was adopted

  • The French proposal (2014): France identified a risk to workers (mainly cashiers) and consumers handling receipts. The concern was specifically the unborn children of pregnant workers and consumers [5].
  • RAC (the Risk Assessment Committee): it confirmed the risk for workers but found the risk for consumers adequately controlled [6].
  • SEAC (the Socio-Economic Analysis Committee): it judged the restriction "unlikely to be proportionate", but noted favourable distributional and affordability points [7].
  • The Commission's conclusion: handling thermal paper at or above 0.02% BPA poses an unacceptable risk to workers. Restricting what is placed on the market also gives consumers a wider safety margin [8].
  • Timing: application was deferred by 36 months so industry could comply [9].

Watching for BPS as a substitute (recital 13)

  • RAC noted that BPS, the most likely substitute, may have a toxicological profile similar to BPA [10].
  • ECHA was therefore asked to monitor BPS use in thermal paper, so the Commission could decide whether a BPS restriction is needed.

GB: HSE's GB REACH restriction list carries the same entry 66 wording [2]. HSE explains that the restriction became retained EU law before EU exit, so the same limit applies in GB [11].

2. What ECHA said about BPS and other alternatives

ECHA's 2020 market survey (from ECHA's own website, read as a search snippet)

  • ECHA's fourth and final survey found manufacturers had kept switching from BPA to BPS.
  • 187 kilotonnes of BPS-based thermal paper were placed on the EU market in 2019. About 61% (307 kt) of EU thermal paper was projected to be BPS-based by 2022.
  • ECHA stated its committees had said in 2015 that the BPA restriction would reduce risks only if industry chose alternatives other than BPS.

Market figures as cited in later reports

  • HSE's summary of the ECHA report: at the end of 2019, the EU developer market was 29% BPA, 39% BPS and 32% other developers [12].
  • Germany's later dossier: using BPA-based paper "was almost entirely offset" by BPS-based paper, making BPS the most widely used developer in EU history. The projection for 2022 onward was 0 t BPA, 307,000 t BPS and 199,000 t other developers [13].

BPS regulatory status

  • EU Candidate List: BPS was added on 17 January 2023 as toxic for reproduction and as an endocrine disruptor for both human health and the environment [14].
  • EU harmonised classification: Repr. 1B, H360FD, applicable since 23 November 2023 [15].
  • GB MCL list: the same Repr. 1B, H360FD entry has applied since 20 October 2023 [16].
  • GB Candidate List: I found no entry for BPS. BPA is on it (added 12 January 2017) [17].

ECHA's assessment of regulatory needs (bisphenol group, 2021)

  • BPS: restriction is the foreseen regulatory need [18].
  • D-8, a BPS derivative used as a developer: restriction is foreseen [19].
  • TG-SA, another BPS derivative: listed for CoRAP (substance evaluation), also with restriction foreseen [20].

Germany's group restriction proposal (now withdrawn)

  • The October 2022 proposal covered BPA, BPB, BPS, BPF and BPAF, with a 10 ppm limit in mixtures and articles [21].
  • It used thermal paper as its example of drop-in replacement between bisphenols ("BPA has been largely replaced by BPS") [22].
  • ECHA's tracker shows the dossier as withdrawn. No EU BPS restriction for thermal paper is in force in what I searched.

3. What HSE concluded under UK REACH

The report is HSE's technical report "Bisphenols in thermal paper", July 2025. It reviewed 21 candidate developers.

Context

  • HSE estimated that in 2019 GB used about 180 t BPA, 250 t BPS and 200 t other developers in thermal paper [23].
  • It noted stakeholder worries about regrettable substitution (swapping one hazardous chemical for another) [24].

BPS and human health

  • BPS has a hazard profile similar to BPA, including oestrogenic activity at a similar level [25].
  • HSE still judged a health risk from thermal paper unlikely, for three reasons:
    • The original BPA risk to cashiers was marginal (a risk ratio of only 2) [26].
    • BPS is absorbed through the skin less than BPA [27].
    • Self-checkouts and digital receipts mean people handle receipts less [28].

BPS and the environment

  • HSE concluded that total BPS emissions "potentially represent a risk to the environment" [29].
    • Estimated releases to GB rivers are about 1.5 to 75 t a year.
    • River monitoring exceeds the BPS aquatic no-effect level (PNEC) of 0.025 mg/L [30].
  • HSE could not separate how much of this comes from thermal paper versus other sources [31].

Other alternatives

GroupHuman healthEnvironment
Other bisphenols (BPC, DD-70, BPAP, AP-5, BPF, MBHA, BPPH)AP-5 has reproductive effects and possible oestrogenic activity. Health risk judged unlikely because these are used less and receipts are handled less [32]AP-5 screens as potentially PMT/vPvM and PBT/vPvB, i.e. persistent, mobile or bioaccumulative and toxic [33]. The EU is investigating BPF and BPC for endocrine effects; BPF has been detected in English waters [34]
Bisphenol derivatives (TG-SA/TG-SH(H), D-8, BPS-MAE, D-90, BPS-MPE)Health risk "very unlikely" [35]D-8 is under EU endocrine investigation and screens as potentially vPvB/vPvM [36]
Non-bisphenols (Pergafast 201, PHBB, others)Pergafast 201, apparently the most widely used, is unlikely to pose health risks: EU evaluation found no reproductive or endocrine effects and negligible skin uptake [37]Data too limited to conclude. Pergafast 201 and PHBB screen as vPvB for air-breathing organisms [38]

Data gaps HSE flagged

  • Hazard data are scarce for many developers, and several are not registered under EU or UK REACH. That limits regulators' ability to generate data, so uncertainty is expected to remain [39].
  • Manufacturers do not disclose which developers they use [40].

Sources:

Q.02