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Safer Choice

Partnership to Evaluate Alternatives to Bisphenol A in Thermal Paper

About the Project | Milestones and Publications | Partnership Participants

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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.

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More information?

If you would like more information, please contact Laura Romano at