- Improving REACH registration and authorisation
- Exploring the universe of registered substances
- Moving away from BPA in thermal paper
- Investing in good registration data is an investment in safety
- Get to know ECHA’s Submission portal for poison centre notifications
- Assessing endocrine disrupting properties for biocides
- Controlling exposure to harmful chemicals at work
- Which pieces of EU legislation apply to your substances?
- Stopping products sidestepping enforcement through rebranding
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Article related to: REACH
Moving away from BPA in thermal paper
Credit card slips, cash register receipts, tickets and product labels are often made from thermal paper coated with a substance that reacts with a dye precursor to form a colour when exposed to heat. A substance commonly used for this is bisphenol A (BPA). In January 2020, the European Commission’s restriction of BPA in thermal paper comes into effect. We look at what is being done to find sustainable and safe replacements for this use of the substance.
Classified in the EU as a substance that may damage fertility, cause serious eye damage, may cause an allergic skin reaction and may cause respiratory irritation, bisphenol A has also been identified as an endocrine disruptor for human health and as toxic for aquatic life. Following France’s 2014 restriction proposal, which indicated a risk for workers, the Commission decided in 2016 to restrict BPA in thermal paper in concentrations of 0.02 % or more by weight. The restriction takes effect on 2 January 2020 and will be key in motivating industry to move to alternatives to BPA in thermal paper products.
To help industry make a sound and sustainable switch, the Belgian health and economic public authorities, with ECHA’s support, hosted a workshop in March 2019 on alternatives for BPA in thermal paper. The workshop focused on the alternatives available, whether there are any suspected issues related to their safety and the challenges for the supply chain in adopting them. Discussions with stakeholders showed that the higher cost of alternatives to BPA is the main barrier to their adoption. As such, without regulating the use of the most problematic alternatives, the largest share of the market is expected to switch to the cheapest alternatives.
From BPA to other developers
ECHA’s latest report on the thermal paper market indicates that approximately half of the thermal paper consumed in the EU in 2018 used BPA and that the share of other developers was increasing. For European-produced thermal paper, one-sixth contained bisphenol S (BPS) and one-third contained other developers. For imported thermal paper, the share of other developers was slightly higher.
BPS is currently listed in ECHA’s Community rolling action plan (CoRAP), which indicates the substances of potential concern that are to be evaluated by different Member States over a period of three years. Belgium is evaluating BPS for its suspected endocrine-disrupting and carcinogenic, mutagenic and reprotoxic properties. Belgium has also notified ECHA of its intention to submit a proposal to harmonise the classification and labelling of BPS for reprotoxicity.
There is no final outcome for the substance evaluation and classification at this stage as the regulatory work is ongoing. However, since BPS is structurally similar to BPA, it may have similar toxic effects and the fact that it is a high production volume chemical has also raised concerns.
Alternative developers are available such as Pergafast® 201 and D8. Belgium has also indicated its plan to evaluate them for suspected endocrine-disrupting properties. This makes it challenging for companies to make a coordinated assessment about substance safety and decide on replacement strategies for their products.
Beyond developers and even paper
Companies can also look for solutions to the BPA substitution challenge through other means: there are technologies and innovations on the market that could remove the need for bisphenols, phenols or non-phenolic substances when developing thermal paper.
For example, new types of printer paper, which react physically to heat rather than through a chemical reaction, are becoming available. Some uses of thermal paper could also be replaced with electronic or digital means of documenting purchases. Together, the use of such technologies could contribute to reducing the exposure of cashiers to harmful chemicals, as they would no longer be handling thermal paper, while also bringing environmental benefits by reducing the amount of paper being used.
Yet, electronic and digital alternatives may carry concerns related to data protection or energy use for data storage. Adopting digital solutions might be time consuming and expensive, and even those retailers who can afford to have the technology at hand may face difficulties in convincing their customers to share their contact details over the counter. In some countries, there is also a legal obligation for shopkeepers to issue printed receipts and for consumers to be able to produce them on demand. Also, electronic alternatives would not be suitable for some other types of thermal papers such as labels.
A retailer’s point of view
Being close to consumers, retailers play a crucial role in encouraging the supply chain to move towards sustainability. Malene Teller Blume, Quality Manager at Coop Danmark A/S, represents a company that has successfully moved away from using BPA in their thermal paper and some other products.
|Malene Teller Blume. |
Image: Malene Teller Blume.
|"We believe that the future for Coop Danmark is to move away from chemical solutions and pursue electronic ones."|
Discussions on BPA started in Coop in 2011, after the Danish Environmental Protection Agency reported that up to 80 per cent of cash register receipts were made of thermal paper.
“At that point, the report indicated that there were no immediate health risks for consumers or workers related to handling cash register receipts. Based on that information, we initially decided against seeking BPA-free solutions due to the high costs involved,” Ms Teller Blume says.
However, following France's proposal to restrict BPA in thermal paper, ECHA’s Committee for Risk Assessment found that BPA exposure could constitute a particular health risk for cashiers. At that point, the Danish Environmental Protection Agency encouraged Coop to search for a safer substitute for BPA. By December 2015, BPA had been phased out in till receipts and labels in all of Coop Danmark’s shops.
“Our mindset was to use the currently available information to adhere to the precautionary principle as much as possible and give the best level of protection for our workers and our customers. At an early stage, we began dialogue with scientists, authorities and NGOs and read reports on how other bisphenols had similar properties and would not be safer alternatives. We knew we needed to look beyond bisphenols,” Ms Teller Blume says.
With that in mind, the company decided to pursue an alternative chemical solution that would avoid the use of bisphenols completely, replacing BPA in thermal paper with Pergafast® 201.
Coop’s future is electronic
“At the March workshop in Belgium, we listened with interest about the regulatory status of well-known alternatives to BPA and also about non-chemical solutions. All in all we believe that the future for Coop Danmark is to move away from chemical solutions and pursue electronic ones,” she predicts.
She also believes others should take a similar approach. “When I attended the Belgian workshop, I was surprised how many suppliers are still supplying bisphenol solutions. In my opinion, there is a real need for authorities and stakeholders in Europe to come together to find safer and sustainable alternatives,” she concludes.
Coop Danmark A/S is Denmark's leading consumer goods retailer. It operates the retail chains Kvickly, SuperBrugsen, Dagli’Brugsen, Coop.dk Shopping, Coop.dk MAD and the subsidiaries Fakta A/S and Irma A/S.
Bisphenol A (BPA)
It is a reprotoxic and endocrine-disrupting substance, has effects on the kidneys and is currently on the Candidate List of substances of very high concern (SVHCs). The restriction of BPA in thermal paper will take effect on 2 January 2020.
Text and interview by Paul Trouth
Published on: 16 May 2019
Top image: © iStock.com/Maica
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Committee for Risk Assessment:
25-28 November 2019 and
3-5 December 2019
Committee for Socio-Economic
26-28 November 2019 and
3-5 December 2019
Member State Committee:
9-11 December 2019
3-7 February 2020 (tentative)
Biocidal Products Committee:
10-11 December 2019
Management Board meeting:
12-13 December 2019