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POS Receipt Paper Guide for Navigating Phenol-free Compliance

As regulatory expectations surrounding chemical safety and material transparency continue to evolve, Domtar remains focused on delivering paper solutions that help our partners move forward with confidence. Clarion™ thermal paper is BPA-free, BPS-free, and phenol-freewhile maintaining the performance standards customers expect frostandard thermal paper. 

Understanding the Difference Between “Phenol-Free, “BPA vs. BPS-Free”, and “No Phenols Added”

What does Phenol-free Mean? 

At Domtar, phenolfree means our products are made without detectable phenolic compounds. Because this definition applies broadly, it also means no bisphenols are used, including BPA, BPS, or related substances. 

We verify this through third-party testing that confirms no detectable levels of Bisphenol A (BPA) or Bisphenol S (BPS) in the finished product, using highly sensitive methods with a detection limit of 1 PPB, which is equal to 1 drop of water in an Olympic-sized swimming pool. This approach helps ensure our products meet Domtar’s standards for compliance, quality, and customer confidence. 

What is BPA vs. BPS-free?

“BPAfree” means a product contains no Bisphenol A, while “BPSfree” means it contains no Bisphenol S. Each claim refers only to the specific bisphenol named and does not guarantee the absence of other phenols or bisphenols. 

What are No Phenols Added?

Why the Distinction Matters

As BPA use declined, BPS was widely adopted as a replacement in thermal receipts. Regulatory agencies and advocacy groups have since expanded scrutiny beyond BPA, prompting many organizations to move away from single-chemical claims toward broader phenol-free specifications.  

Understanding these differences helps businesses: 
  • Align on evolving purchasing policies 
  • Reduce the likelihood of rapid product changes 
  • Maintain consistency across multi-state or national operations 

Legislation & Regulatory Overview for U.S. & Canada

Understanding the difference between “Phenol-free,” “BPA/BPS-free,” and “No Phenols Added” is becoming increasingly important as new laws are being introduced to protect consumers from 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 be phenol-free, 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): Classified as a toxic substance under CEPA (2010); 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 receiptspecific 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 WalgreensTarget, and Costco are already transitioning to phenol-free paper to stay ahead of regulation.

  


 

Regulatory Trends: Thermal Receipt Paper and Bisphenols 

Around the world, regulators are taking a closer look at the chemicals used in everyday products, including thermal receipt paper. At the center of this scrutiny are bisphenols, a group of chemicals historically used to create the printed image on receipts. As concerns grow about longterm exposure, governments are moving to restrict or eliminate these substances altogether. 

In the United States, regulation is accelerating at the state level. Washington State now restricts all bisphenols in thermal receipt paper, and California is moving toward similar classwide restrictions through proposed legislation. Other states, including New Jersey, Maine, New York, Minnesota, Vermont, and Connecticut, have enacted or proposed measures that limit BPA, BPS, or related chemicals in receipts. Together, these actions signal a clear direction: what is allowed today may not be permitted tomorrow. 

In Canada, there is no national ban specific to receipt paper, but bisphenols are actively monitored under federal chemical safety programs. Many retailers and brands have already shifted to phenolfree receipts to reduce exposure risks and align with evolving guidance. 

Europe is further ahead. BPA has been effectively removed from thermal receipt paper for several years, and broader regulations now reflect growing concern about the entire bisphenol family, not just one chemical at a time. 

What This Means for Consumers and Businesses 

The regulatory message is increasingly clear: 

  • BPA‑free is no longer adequate if products still contain other bisphenols. 
  • Phenol‑free receipt paper reduces future compliance risk, supply disruptions, and the need for last‑minute changes. 

As rules continue to tighten, moving toward phenolfree thermal paper is widely viewed as a practical, proactive step, and one that mitigates regulatory risk and supports longterm sustainability expectations. 

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A New Generation of Receipt Paper that Makes Compliance Simple

Clarion™ is the first phenol-free thermal receipt paper that looks and performs the same as standard POS paper, that is WMU certified recyclable and made in the USA. 

We created Clarion™ thermal paper to address the need for alternate POS papers due to increasing industry regulations and ENGO activities. Our customers want to make the right choice when it comes to POS papers, but they need to look and work just as well as the ones they’re used to. 

Learn more about Clarion™ »

FAQs

What are the Latest Regulatory Requirements for Phenol-free Thermal POS Paper in the U.S.

Regulatory requirements vary by state, but the national trend is moving toward eliminating all phenol-based developers in thermal paper. Key requirements include: 

California (Prop 65 and proposed AB1604) 

  • Businesses must avoid using thermal paper containing BPA or BPS or apply warning labels as required under Prop 65.  
  • AB1604 (introduced) proposes a full ban on phenol-based thermal paper starting January 2028.  

Washington 

  • Regulation WAC 173337 bans all phenol-based thermal paper beginning January 2026.  

Connecticut 

  • Enacted a ban (SB 210) on BPA receipt paper, extending enforcement to retailers and distributors.  

Domtar takeaway: 
U.S. states are phasing out phenols; distributors and retailers must align procurement with phenol-free solutions to avoid compliance risks. 

What Does “Phenol-free” Mean in the Context of Thermal Receipt Paper?

“Phenol-free” means the thermal coating contains no phenol-based chemical developers, including: 

  • BPA 
  • BPS 
  • All other bisphenol derivatives or phenolic compounds 

Instead, phenol-free papers use alternative formulations with rigorous safety standards. For Domtar Clarion™ thermal paper products, “phenolfree” means phenols are undetectable across the entire formulation and finished product, based on highly sensitive testing (100 ppb detection limit), and not just BPA or BPS replacement. 

How Does BPA-free Differ from BPS-free, and Why Does This Matter for Compliance?

BPA-free

  • Means BPA is not intentionally added, but BPS may still be present, which has similar structure, and regulation concerns.

BPS-free

  • Means BPS is absent, but products may still contain other phenolic developers or BPA unless explicitly removed.

Why This Matters

  • Many businesses misunderstood early “BPA-free” labels, not realizing BPS was being used as a replacement with similar concerns.
  • As regulatory scrutiny expands beyond California and Washington, several states are enforcing, phasing in, or proposing rules that eliminate BPA, BPS and in some cases all phenols. These include thermal paper as well as other sectors such as packaging, food-contact materials, and children’s products making “BPA-free” claims insufficient.

Domtar implication: To stay ahead of evolving regulations, Domtar Clarionthermal papers are phenol-free, not just “BPA-free”.

How Does Clarion™ Thermal Paper Help Businesses Comply with Phenol Regulations?

Clarion thermal paper is engineered to meet modern regulatory requirements by eliminating intentionally added phenolic developers from its formulation. 

Clarion™ technology supports compliance with: 

  • BPA restrictions 
  • BPS restrictions 
  • Emerging phenol regulations 
  • Retailer sustainability standards 

By using a phenol-free formulation, Clarion thermal paper helps retailers align with both current legislation and anticipated regulatory trends. 

Is Clarion™ BPA-free and BPS-free?

Yes. Clarion thermal paper is manufactured without intentionally added BPA or BPS. Its formulation eliminates traditional bisphenol developers entirely. 

This makes Clarion POS thermal paper suitable for businesses operating in jurisdictions with strict bisphenol regulations, as well as those seeking to implement proactive environmental, social, and governance (ESG) initiatives. 

How Does Switching to Clarion™ Reduce Regulatory and Liability Risk?

Using Clarion™ POS thermal paper can help reduce risk by: 

  • Avoiding reliance on restricted substances 
  • Supporting defensible environmental claims 
  • Providing regulatory documentation 
  • Reducing exposure to future bisphenol restrictions 

As legislation increasingly shifts toward broader chemical class restrictions rather than single-substance bans, adopting phenol-free solutions like Clarion™ thermal paper can serve as a long-term compliance strategy. 

How Can I be Assured that Domtar’s Clarion™ Thermal Paper is Phenol-free?

Clarion™ thermal paper is formulated without the use of phenols, including BPA, BPS, and other bisphenols.  

Domtar has implemented rigorous control measures and third-party testing procedures to ensure that Clarion™ thermal paper is phenol free. 

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