Understanding the difference between “Phenol-free,” “BPA/BPS-free,” and “No Phenols Added” is becoming increasingly important as new laws are being introduced to regulate bisphenols found in products consumers may come into contact with on a regular basis, like thermal receipt paper.  Here’s a clear overview of the latest regulations in California, Washington, and Canada, which are shaping broader market expectations. These actions often influence future regulations in other regions. 

California Proposition 65 – Bisphenol S (BPS) Warning Requirement 

Effective Date: December 29, 2024
Products containing Bisphenol S (BPS), such as in thermal receipt paper, may require a Proposition 65 warning for sale in California if they result in consumer exposure to BPS.  

The warning must appear before exposure, meaning it must be displayed at the point of sale or through signage. Printing the warning on the receipt itself does not comply.  

This regulation focuses on consumer awareness rather than banning chemicals. 

California Safe Harbor Guidance 

Safe Harbor Levels (OEHHA) 

Under California’s Prop 65 framework, the Office of Environmental Health Hazard Assessment (OEHHA) establishes safe harbor levels, which set exposure thresholds below which no warning is required. These thresholds are based on risk assessments and scientific data, often including animal studies. However, many chemicals, such as BPS, currently have no established safe harbor levels, meaning businesses must provide a warning if exposure is possible. 

Washington State WAC 173337 – Bisphenols Restrictions 

Effective Date: January 1, 2026
Washington has enacted one of the strictest regulations in the U.S., restricting that use of thermal paper that contains any bisphenols, including BPA and BPS. After this date, it became unlawful to manufacture, sell, or distribute such products in Washington.  

This means that all receipt and label papers used in the state must not contain intentionally added bisphenols in 2026, and businesses must be using compliant materials. 

Additionally, Washington clarified that all products manufactured after Jan 1, 2026, and shipped into the state must not have intentionally added bisphenols with a detection level of 200 ppm, and there are no labeling alternatives for noncompliant products.  

Canada – Bisphenol Regulations 

Bisphenols in Canada are regulated under the Canadian Environmental Protection Act, 1999 (CEPA) and assessed through the Chemicals Management Plan (CMP). 

• Bisphenol A (BPA): Restricted in certain uses but not banned in thermal paper. 

• Bisphenol S (BPS) & alternatives: Currently under federal assessment; no nationwide restrictions specific to thermal paper. 

While Canada has not enacted a receipt‑specific restriction on bisphenols in thermal paper, bisphenol A is regulated under the Canadian Environmental Protection Act, and federal authorities continue to assess BPA and its alternatives through mandatory reporting and risk evaluations that may lead to future restrictions. 

Why These Regulations Matter 

• California emphasizes consumer right to know through warning labels. 

• Washington State prohibits the manufacture, sale, and distribution of thermal paper containing intentionally added bisphenols statewide. 

• Many national retailers including Walgreens, Target, and Costco are already transitioning to phenol-free paper to stay ahead of regulation.  

Regulatory Trends: Thermal Receipt Paper and Bisphenols

Across the globe, regulators are taking a closer, more thoughtful look at the chemicals found in everyday products, including thermal receipt paper. Much of this attention is focused on bisphenols, a group of chemicals long used to create printed images on receipts. As awareness grows around potential long-term exposure, governments are increasingly moving to limit or phase out these substances. 

In the United States, momentum is building at the state level. Washington State has already restricted all bisphenols in thermal receipt paper, and California is advancing legislation that would apply similar class wide limits. Other states including New Jersey, Maine, New York, Minnesota, Vermont, and Connecticut, have enacted or proposed measures targeting BPA, BPS, and related chemicals. Taken together, these actions point in one clear direction: regulatory expectations are tightening, and what’s acceptable today may not be tomorrow. 

Canada has not implemented a national ban specific to receipt paper, but bisphenols remain under active review through federal chemical review programs. In response, many retailers and brands have already chosen to transition to phenol free receipts, an intentional step to reduce potential exposure and stay aligned with evolving guidance. 

Europe is further along this path. BPA has been effectively removed from thermal receipt paper for several years, and newer regulations reflect a broader concern about the entire bisphenol family, rather than addressing one chemical at a time. 

What This Means for Consumers and Businesses

The regulatory signal is becoming increasingly clear: 

• BPA-free alone is no longer enough if other bisphenols are still present. 

• Phenol-free receipt paper offers a more future ready solution, helping reduce compliance risk, avoid supply disruptions, and eliminate the need for last minute changes. 

As regulations continue to evolve, moving toward phenol-free thermal paper is widely seen as a practical and proactive choice, one that protects consumers, supports long-term sustainability goals, and provides businesses with greater confidence and stability in a changing regulatory landscape.