Bisphenols in Thermal Paper

What are Bisphenols?

Bisphenols are a group of industrial chemicals used in thermal paper, such as tickets and receipts, as well as plastics and metal can linings. Bisphenol-A, often referred to as BPA, is now recognised as an Endocrine Disrupting Chemical (EDC), meaning it can interfere with the normal hormone function of people and wildlife[i]. As a result of its widespread use, BPA has been detected in the blood and urine of almost every person tested[ii]. Whilst not all bisphenols have been studied as closely, all share similar chemical characteristics and common replacements of BPA are suspected to result similarly damaging effects[iii].

What’s the Issue?

In 2020, BPA was banned from use in receipts across the UK and EU due to the health risks posed to the unborn children of cashiers[iv]. This was based on the high dermal exposure of cashiers handling till receipts on a regular basis. However, as the restriction only focused one chemical within the bisphenols group, the ban did not protect against ‘regrettable substitution’. This refers to a known harmful chemical being replaced with a similar chemical with similar risks of harm.

A recent survey by the European Chemical Agency (ECHA) estimated that 61% of all thermal paper would contain Bisphenol-S (BPS) as a replacement for BPA[v]. BPS is also a suspected EDC and a reproductive toxicant[vi]. Such health concerns resulted in a ban on BPS from use in receipts in Switzerland[vii]. Another common replacement, Bisphenol-B (BPB), was similarly identified as an EDC by the French authority, ANSES[viii]. Without a group-based approach to chemical legislation, on-going cases of regrettable substitution threaten to keep both people and the environment at risk.

What’s the Solution?

A recent survey demonstrated clear support from leading UK retailers for group-based legislation banning the use of bisphenols in till receipts[ix], and some have voluntary chosen to switch to bisphenol-free alternatives that are readily available[x]. As of December 2021, 14 major UK retailers were using bisphenol-free thermal paper for receipts, with two others phasing in bisphenol-free stock^x. There has also been a marked increase in retailers offering digital or ‘no-receipt’ options to consumers, bringing additional environmental and cost-saving benefits.

Introduction of a chemicals policy can help businesses protect against emerging chemicals of concern, such as bisphenols, as well as futureproofing against new regulations. Opting for a grouping approach to chemical management can also help ensure higher standards of protection, as well as saving time and money on remaining up to date with ever-changing regulations.

UK Updates

Bisphenols and their use in thermal paper were listed as a key priority for the UK REACH Work Programme 2022-23[xi]. Relevant authorities have committed to conduct a Regulatory Management Option Analysis (RMOA) to assess available evidence and review the potential for further restrictions. This comes following evidence of human health concerns, such as reproductive toxicity and endocrine disruption, and environmental concerns, also including endocrine disruption, as well as environmental persistence. No timeline has yet been announced for the RMOA beyond its initiation in 2022-23.

For more information on bisphenols in thermal paper and chemical management, visit the Fidra website at: www.fidra.org.uk

[i] Member State Committee Support Document: 4,4'-isopropylidenediphenol (Bisphenol A; BPA). ECHA, 2017. https://echa.europa.eu/documents/10162/769b2777-19cd-9fff-33c4-54fe6d8290d5

[ii] Concentration of bisphenol A in thermal paper. Mendum, T., Stoler, E., VanBenschoten, H. and Warner, J.C., 2011. Green Chemistry Letters and Reviews, 4 (1), pp.81-86. https://www.tandfonline.com/doi/full/10.1080/17518253.2010.502908

[iii] From BPA to BPZ: a toxic soup? CHEMTrust, 2018. https://www.chemtrust.org/wp-content/uploads/chemtrust-toxicsoup-mar-18.pdf

[iv] Towards safe use and recycling of receipts: case for group-based restriction on bisphenols in thermal paper. Fidra, 2022. https://www.fidra.org.uk/wp-content/uploads/UK-Gov-Bisphenols-Briefing-MAR22.pdf

^[v] Bisphenol S has replaced bisphenol A in thermal paper. ECHA, 2020. https://echa.europa.eu/-/bisphenol-s-has-replaced-bisphenol-a-in-thermal-paper

[vi] 4,4’-sulphonyldiphenol. ECHA, 2022. https://echa.europa.eu/brief-profile/-/briefprofile/100.001.137

[vii] Switzerland bans the use of BPA and BPS in thermal paper. Chemical Watch, 2019. https://chemicalwatch.com/77769/switzerland-bans-the-use-of-bpa-and-bps-in-thermal-paper

^[viii] Evidence for Bisphenol B Endocrine Properties: Scientific and Regulatory Perspectives. Environmental Health Perspectives, 2019. https://ehp.niehs.nih.gov/doi/10.1289/EHP5200

[ix] How UK retailers are tackling chemicals of concern: A case for group-based chemical legislation. Fidra, 2021. https://www.fidra.org.uk/wp-content/uploads/How-UK-Retailers-are-Tackling-Chemicals-of-Concern-Fidra-Report.pdf

[x] Bisphenols and Endocrine Disruptors. Fidra, 2022. https://www.fidra.org.uk/bisphenols/

[xi] UK REACH Work Programme 2022-23. Health and Safety Executive, 2022. https://www.hse.gov.uk/reach/work-programme.htm

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