Safer Choice

Partnership to Evaluate Alternatives to Bisphenol A in Thermal Paper

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About the BPA Alternatives Assessment Partnership

One of Bisphenol A's (BPA) uses is as a developer in thermal paper, and this assessment evaluates potential hazards associated with 19 thermal paper developers that are likely to be functional alternatives to BPA. Thermal paper systems include a developer and other components, such as dyes and sensitizers, which are described in more detail below. In addition, the assessment provides background information about how thermal paper is made and considerations for choosing an alternative.

Note that a chemical listed in the report as an alternative does not constitute EPA's endorsement of it. All of the alternatives are associated with some trade-offs; this report does not identify any functional chemicals with low concern for all human health and environmental hazard endpoints.

Read about BPA and why it is of concern to EPA


On September 8, 2015, a new version of the final report was posted with a technical correction in the hazard designation for developmental toxicity of Pergafast 201.

On January 29, 2014, through its Design for the Environment (DfE) program, EPA released a final alternatives assessment for bisphenol A (BPA) in thermal paper.

A draft of this assessment was open for public review and comment during the period from July 31, 2012 to October 1, 2012.

Why did DfE conduct an alternatives assessment?

EPA issued an action plan in March 2010 for bisphenol A (BPA) under its Existing Chemical Management Program. The plan called for DfE to assess the potential hazards associated with BPA and its functional alternatives so product manufacturers could use the information to reduce the likelihood of unintended consequences of using substitutes for BPA. Read more information on the goals of DfE's alternatives assessments.

DfE's BPA alternatives assessment partnership

The goal of this assessment is to identify known and potentially functional alternatives to BPA in thermal paper and to provide information on their potential hazards. To implement this goal, DfE convened stakeholders to identify and develop information on alternatives to BPA in thermal paper, including thermal paper used for cash register receipts. DfE evaluated the hazards associated with BPA and the functional alternatives that act as developers for dyes in this application. Human health and environmental profiles for each chemical are based on a review of literature in the public domain, structure-activity relationship modeling, and, in some cases, proprietary information shared by stakeholders.

The assessment is based on:

  • A review of literature in the public domain;
  • Structure-activity relationship modeling, and;
  • In some cases, proprietary information shared by stakeholders (information from the partnership is being made available to decision-makers and the public in a manner that protects proprietary information)

Background on BPA

In thermal printing applications, BPA functions chemically as a developer, which reacts with white or colorless dyes (color formers) in the presence of heat, converting them to a dark color. BPA is used mostly as a developer in lower-grade thermal paper applications, such as receipts. While thermal paper represents a small fraction of the total use of BPA, the use of BPA in thermal paper could increase cumulative human exposures and direct and indirect environmental releases of BPA. Reducing use of BPA in receipts is an opportunity to reduce one source of human exposure and releases to the environment.

"Free" or unreacted bisphenol A (BPA) has been reported present in thermal paper. Workers in certain occupations, such as cashiers and restaurant servers who handle thermal paper often, may be at greater risk of exposure. Hand-to-mouth behavior and mouthing of inappropriate objects puts young children -- who may be the most sensitive to BPA -- at greater risk of potential exposure. Additionally, older children and teenagers may potentially be exposed as they start to buy goods and as they enter the workforce, especially as cashiers.

In addition to direct human exposure to BPA through contact with thermal paper, recycling of these papers may contribute residual BPA to the supply of recycled paper; BPA has been detected in recycled toilet paper and other products. BPA in recycled toilet paper may be an additional source of release to the environment, since not all BPA is expected to degrade in wastewater treatment plants. BPA can also be discharged directly to surface water during the recycling process.

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See all publications from this partnership.

Milestones Completion Date
Partnership kickoff meeting July 2010
Posted partnership objective, project description, and methodology - including critical milestones, roles, and responsibilities August 2010
Compiled list of functional BPA alternatives November 2010
Completed draft evaluation of ecological and human health hazards and environmental fate of BPA and alternative developers September 2011
Posted draft report, "Bisphenol A Alternatives in Thermal Paper," for public review and comment July 2012
Posted final report, "Bisphenol A Alternatives in Thermal Paper" January 2014
Posted response to the formal, written public comments January 2014
Posted revised final report, "Bisphenol A Alternatives in Thermal Paper" September 2015

Meeting Materials

These materials predate the formation of the Partnership. Some of the documents may be dated.

Kick-Off Meeting - July 15, 2010

The kick-off meeting materials from this partnership are available online.

  • Agenda
    • Introduction - Cal Baier-Anderson, DfE
    • Action Plan Introduction - Mary Dominiak, EPA
    • NIOSH Presentation - Cherie Estill, NIOSH
    • Introductory Comments - Roger McFadden, VP and Chief Scientist, Staples
    • Background on DfE - Clive Davies, Chief, DfE
    • Thermal Paper Science - Kelly Grant, DfE
    • Draft Report Outline - Cal Baier-Anderson, DfE
    • Alternatives to BPA - Kelly Grant, DfE
    • Alternatives Assessment Methodology - Clive Davies, Chief, DfE
    • Hazard Assessment - Libby Sommer, DfE
    • Endocrine Activity for Alternatives Assessments - Cal Baier-Anderson, DfE
    • Next Steps - Cal Baier-Anderson, DfE
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Partnership Participants

Thermal Paper Manufacturers

Pam Barker, Appleton Papers, Inc.
Mike Friese, Appleton Papers, Inc.
Pete Popovics, Cenveo/Nashua
Jouko Mäkitalo, Jujo Thermal
Mari Koskinen, Jujo Thermal
Fred Paris, Kanzaki
Michael Horn, Koehler Paper
Dirk Keller, Koehler Paper
Bernd Gerecht, Mitsubishi
Takahisa Kato, Mitsubishi
Theodore Rice, Mitsubishi
Gary Toussaint, Nashua Corporation
Trevor Kelley, Nashua Corporation
Todd Ostrowski, Tighe & Bond

Thermal Paper Converters

Dough Dahrsnin, LabelWorld
Dave Starr, Heartland Label Printers
Andrew Dennison, Heartland Label Printers
Dave Blum, Heartland Label Printers
Jim Check, Heartland Label Printers
Mike Rapier, Liberty Paper Products, LLC
Jerry Butler, NCR
Bram van Staalduinen, NCR
Debora Jeske, NCR
Steve Nahm, NCR
Terie Syme, Prestige Label Co.
Stacey MacNeil, UPM Raflatac
Steven Schwartz, RiteMade Paper

Chemical Manufacturers (Developers and Colorformers)

Steve Aderman, AdChem Technologies
Al Wiedow, BASF
Omi Kapel, BASF
Frank Kearney, ESCO
Robin Heath, Nagase America Corporation
John Wrubel, Nisso America
Toshiyuki Iwama, Nisso America
Tadashi Kawakami, Nisso America

Point-of-Sale Original Equipment Manufacturers

Ron Mateas, Epson
Sal Rizvi, Star Micronics America, Inc.


Drew Du Bois, Kroger
Jeff Brown, Safeway
Roger McFadden, Staples
Holly Wipf, Target
Zach Freeze, Wal-Mart
Jason Wadsworth, Wegmans
Joe Dickson, Whole Foods

Trade Association

Steven Hentges, American Chemistry Council
Erik Lieberman, Food Marketing Institute
John Billings, Food Marketing Institute
David Wagger, Institute of Scrap Recycling Industries, Inc.
Sarah Walczewski, Retailer Industry Leaders Association

Trade Unions

Jackie Nowell, United Food and Commercial Workers

Non-Governmental Organizations

Mark Rossi, Clean Production Action
Michelle Harvey, Environmental Defense Fund
Sonya Lunder, Environmental Working Group
David Andrews, Environmental Working Group
Sarah Janssen, Natural Resources Defense Council
Darby Hoover, Natural Resources Defense Council
Brian Penttila, Pacific Northwest Pollution Prevention Resource Center
Pam Eliason, Toxics Use Reduction Institute
Erica Schreder, Washington Toxics Coalition

Government Participants

John Bucher, National Institute of Environmental Health Sciences
Kris Thayer, National Institute of Environmental Health Sciences
Cherie Estill, National Institute for Occupational Safety and Health
Steve Schrader, National Institute for Occupational Safety and Health
Mike Babich, Consumer Product Safety Commission
Vanee Komolprasert, Food and Drug Administration
Gary Ginsberg, Connecticut Department of Public Health
Terry Goldberg, Northeast Waste Management Officials' Association

International Participants

Paolo Castello, Joint Research Centre of the European Commission
Kate McKerlie, Environment Canada

Green Chemistry Consultants

John Warner, Warner Babcock Institute
Sarah Newsky, Warner Babcock Institute
Manfred Krautter, EcoAid

BPA Partnership EPA Contacts

Clive Davies, Design for the Environment
Cal Baier-Anderson, Design for the Environment

Technical Consultants

Lauren Heine, Clean Production Action
Abt Associates Inc.
SRC Inc.

How do I get more information?

If you would like more information, please contact Cal Baier-Anderson of DfE at or 202-564-1933.