Starting January 1, 2026, intentionally added bisphenols in thermal paper will be restricted for sale, distribution, and manufacture in Washington state under the Safer Products Restrictions and Reporting Rule (WAC 173-337-114 (3)).
Additional Information
According to the Washington State Department of Ecology, thermal paper is paper coated with a material formulated to change color when exposed to heat. Examples of thermal paper products include sales receipts, packing labels, and tickets.
The Department of Ecology presumes the detection of bisphenol concentrations above 200 ppm indicate the intentional addition of bisphenol. Manufacturers may rebut this presumption by submitting a statement to Ecology with the following information:
• The name and address of the person submitting the statement
• A statement that a bisphenol was not intentionally added, along with credible evidence supporting the statement and information, data, or sources relevant to demonstrate the bisphenol was not intentionally added.
Ecology’s Final Regulatory Analyses Report stated “…thermal paper contributes a significant fraction of human exposure to BPA and BPS—the most thoroughly studied bisphenols”.
The rule does not apply to consumer products manufactured before January 1, 2026, or those consumer products regulated by the FDA as medical devices.
Regulation: WAC 173-337-114:
Implementation Plan: Rule Implementation Plan: Safer Products Restrictions and Reporting
Final Regulatory Analyses: Preliminary Regulatory Analyses for Chapter173-337 WAC, Safer Products Restrictions and Reporting
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