REACH Compliance for Thermal Paper: EU 2025 Update

REACH Regulation (EU) 2016/2235 restricts Bisphenol A (BPA) in thermal paper to a maximum concentration of 0.02% by weight. This restriction has been in force since January 2020 and applies to all thermal paper placed on the EU market, regardless of origin.

The restriction was introduced following an opinion from the European Chemicals Agency (ECHA) that BPA in thermal paper poses a risk to workers who handle receipts frequently, particularly cashiers and retail workers. The restriction applies to the finished thermal paper product, not just the raw materials.

Importers and distributors placing thermal paper on the EU market are responsible for ensuring compliance with this restriction. Enforcement is carried out by national market surveillance authorities, and non-compliant products can be subject to market withdrawal and financial penalties.

Bisphenol S (BPS) is the most widely used BPA substitute in thermal paper. While BPS is not currently restricted under REACH, it is under active evaluation by ECHA following concerns raised by several EU member states.

Germany, France, Denmark, and Sweden have submitted dossiers to ECHA proposing BPS for inclusion on the SVHC (Substances of Very High Concern) candidate list. If BPS is listed as an SVHC, suppliers would be required to notify customers when BPS is present above 0.1% in articles, and additional restrictions could follow.

Distributors sourcing 'BPA-free' thermal paper should clarify whether the alternative developer is BPS-free. Products using BPS may face regulatory restrictions in the near future, requiring supply chain changes.

REACH Article 33 requires suppliers to notify customers when articles contain SVHC substances above 0.1% by weight. For thermal paper, this means suppliers must proactively communicate the presence of any SVHC substances in their products.

Distributors should request annual SVHC statements from all thermal paper suppliers, confirming that no SVHC substances are present above the 0.1% threshold. These statements should be updated whenever the SVHC candidate list is updated (typically twice per year).

The SVHC candidate list currently contains over 200 substances. While most are not relevant to thermal paper, the list is regularly updated and distributors should not assume that a product that was compliant last year remains compliant today.

To demonstrate REACH compliance for thermal paper products, distributors should maintain: a BPA-free declaration confirming BPA content below 0.02%, an SVHC statement confirming no SVHC substances above 0.1%, third-party test reports from accredited laboratories, and a Safety Data Sheet (SDS) for the thermal paper product.

These documents should be available on request from market surveillance authorities and should be reviewed and updated annually. Distributors who cannot produce compliance documentation on request may face enforcement action.

For products sold in France, additional documentation confirming compliance with the Grenelle II food contact requirements may be required for products used in food service environments.