By Grimaldi Law Offices Summer Associate Cecilia Grimaldi
Illinois has joined several jurisdictions in banning “thermal paper.” Under the new law, “thermal paper” is defined as paper with bisphenol A (BPA) added to the coating. Beginning January 1, 2020, no person can manufacture thermal paper in the state. Further, no person can distribute or use thermal paper made after January 1, 2020 to make business or banking records such as those recording receipts, credits, withdrawals, deposits, or credit or debit card transactions. However, the manufacture provision will not apply to paper containing recycled material.
This prohibition on receipt paper containing BPA follows a similar ban in Connecticut. Additionally, New York’s Suffolk County regulates BPA in thermal paper. Notably, California has shelved a similar proposed ban on paper receipts containing BPA or bisphenol S (BPS), although with BPA identified on the Proposition 65 list since May 2015, a number of Proposition 65 claims have alleged exposures to the chemical in thermal receipt paper.
While the Illinois EPA supports the ban, it has admitted “no scientific consensus exists on the human health threat posed by BPA in thermal paper.” The lack of scientific consensus has not stopped “retailer regulation,” however: Costco Canada, for example, recently has banned the use of receipt paper coated with BPA and BPS.
Grimaldi Law Offices has been advising clients for over 20 years on chemical and product regulation. For knowledgeable advice and in-depth analysis on your chemical regulatory compliance obligations, contact Grimaldi Law Offices at (415) 463-5186 or email us at firstname.lastname@example.org.
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