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Bisphenol S has replaced bisphenol A in thermal paper


By 2022, 61 % of all thermal paper in the EU is forecast to be based on bisphenol S (BPS).

Helsinki, 18 June 2020 – ECHA’s fourth and final market survey on the use of BPA and other developers in thermal paper confirms that paper manufacturers have continued to replace BPA with BPS. In 2019, 187 kilotonnes of BPS-based thermal paper were placed on the EU market. By 2022, it is expected that 61 % (or 307 kilotonnes) of all thermal paper in the EU will be BPS-based.

The EU-wide ban on bisphenol A (BPA) in thermal paper took effect in January 2020. According to the survey, BPA-based thermal paper still had a 29 % market share in 2019 in the EU. From 2020 onwards, BPA is expected to be replaced mainly by BPS.

The wide use of BPS in thermal paper raises concern as BPS is suspected to affect human reproductive and hormonal systems.

“Replacing a hazardous substance with one that is also suspected to be hazardous is not what regulators or EU citizens want to see. Our scientific committees stated already in 2015 that a restriction on BPA in thermal paper will reduce risks only if industry chooses other alternatives than BPS. We need to increase our understanding about BPS and other bisphenols. To that end, there are ongoing regulatory actions”, says Peter van der Zandt, ECHA’s Director for Risk Management.

Belgian authorities are currently evaluating whether the use of BPS poses a risk to human health or the environment. Their conclusions are expected by 2021. In addition, Belgium made a proposal in 2019 to harmonise the classification and labelling of the substance as toxic to reproduction. ECHA’s Committee for Risk Assessment is expected to give its opinion on this proposal in spring 2021.

Moreover, ECHA is currently looking at bisphenols as a group rather than as individual substances, to collect information for a more comprehensive regulatory strategy concerning these chemicals.


Since 2017, ECHA has been monitoring the use of developers on the EU thermal paper market – and in particular the replacement of BPA with BPS and other alternatives – at the European Commission’s request. As BPA in thermal paper has been restricted since 2 January 2020, this report will be the last of its kind.