SAFEGUARDS | Hardgoods NO. 099/16

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The EU is proposing to restrict Bisphenol A (BPA) in thermal papers under Annex XVII of REACH. The effective date is proposed to be in mid-2019.

On April 21, 2016, the World Trade Organisation (WTO) circulated a notification announcing a draft regulation from the European Union (EU) to restrict bisphenol A (BPA) to less than 0.02% in thermal papers. The draft regulation, attached to WTO document 16-2246 [1], would create a new entry under Annex XVII of REACH.

According to the notification, the regulation is proposed to be adopted in the second half of 2016. The proposed effective date is mid-2019; three years after date of entry into force.

BPA is used as a print developer in thermal papers such as thermal receipt papers. The European Agency’s Committee for Risk Assessment (RAC) noted that bisphenol S (BPS) may have a similar toxicological profile to BPA. The RAC will monitor any substance evaluation decisions on BPS and will take any necessary actions to restrict BPS under REACH.

Highlights of the proposal on BPA in thermal papers are summarised in Table 1.

Table 1: Proposal to restrict BPA under new entry 66 of Annex XVII of REACH 

Substance Scope Requirement Proposed Effective date
BPA Thermal papers < 0.02% (200 mg/kg)

(36 months after date of entry into force)

SGS will follow up and inform interested parties as developments on REACH regulation occur. Our expertise combined with consultancy services and experience in consumer product supply chains provides a central point of contact for global solutions. If you would like to learn more about how SGS can support your REACH compliance activities please visit

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Hing Wo Tsang
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