SAFEGUARDS | Hardgoods NO. 194/16

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The European Union (EU) has recently implemented measures to regulate bisphenol A (BPA) in thermal paper under Annex XVII of REACH. The new law will become effective on January 2, 2020.

In May 2016, we [1] informed you that the World Trade Organization (WTO) circulated a notification announcing the EU’s proposal to restrict BPA in thermal paper under REACH. 

On December 13, 2016, the EU published Regulation (EU) 2016/2235 [2] to restrict BPA in thermal paper to no more 200 mg/kg. The new law creates a completely new entry 66 to Annex XVII of REACH.

According to the legislation, thermal paper consists of a paper base with at least one coating that changes color when exposed to heat. The coatings on thermal paper may contain BPA. The regulation is based on a dossier submitted by France indicating that workers (primarily cashiers), consumers and their unborn children are at risk of exposure to BPA by handling thermal receipt paper.

It is noted that bisphenol S (BPS) is the most likely substitute for BPA. Although BPS has not been evaluated, it may have a similar toxicological profile to BPA due to their structural similarities. The use of BPS in thermal paper will be monitored and the authorities will take any necessary regulatory actions to restrict BPS under REACH.

Highlights of the new law are summarized in Table 1.

Table 1. Restriction of BPA in thermal paper under new entry 66 to Annex XVII of REACH

Substance (CAS) Scope Requirement Effective date
BPA ( 80-05-7) Thermal paper ≤ 0.02% (200 mg/kg) January 2, 2020

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

For enquiries, please contact:

Hingwo Tsang
Global Hardlines Information and Innovation Manager
Tel: (+852) 2774 7420

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