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-free, while maintaining the performance standards customers expect from standard thermal paper.
At Domtar, phenol‑free 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.
“BPA‑free” means a product contains no Bisphenol A, while “BPS‑free” 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.
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 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 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
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 long‑term 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 class‑wide 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 phenol‑free 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:
As rules continue to tighten, moving toward phenol‑free thermal paper is widely viewed as a practical, proactive step, and one that mitigates regulatory risk and supports long‑term sustainability expectations.
(Please use your business information only.)
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.
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)
Washington
Connecticut
Domtar takeaway:
U.S. states are phasing out phenols; distributors and retailers must align procurement with phenol-free solutions to avoid compliance risks.
“Phenol-free” means the thermal coating contains no phenol-based chemical developers, including:
Instead, phenol-free papers use alternative formulations with rigorous safety standards. For Domtar Clarion™ thermal paper products, “phenol‑free” 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.
BPA-free
BPS-free
Why This Matters
Domtar implication: To stay ahead of evolving regulations, Domtar Clarion™ thermal papers are phenol-free, not just “BPA-free”.
Clarion™ thermal paper is engineered to meet modern regulatory requirements by eliminating intentionally added phenolic developers from its formulation.
Clarion™ technology supports compliance with:
By using a phenol-free formulation, Clarion™ thermal paper helps retailers align with both current legislation and anticipated regulatory trends.
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.
Using Clarion™ POS thermal paper can help reduce risk by:
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.
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.
