Are thermal labels BPA- and BPS-free? The rules that apply from 2026 to 2029
Which bisphenol rules cover direct thermal labels in the EU, US and India, what changes in 2027, and five questions to ask your thermal label supplier.
Most courier labels are printed on direct thermal paper. The printer heats a coated paper, and the coating turns black where it is heated.
That coating is where the BPA question lives.
The short answer depends on where your labels go. In the EU, BPA has been banned in thermal paper since 2020. Washington State went further in 2026 and restricted all intentionally added bisphenols, BPS included. India's thermal paper standard now asks for BPA-free coatings. California has passed a law on receipts that starts in 2028.
For 2027 itself, I found no new thermal paper rule taking effect. The thing to watch is an EU proposal expected by March 2027 that could cover BPS too. So "BPA-free" is no longer the full question. Ask whether the label is free of all bisphenols.
Checked against official sources on 28 October 2026.
Why a thermal label contains bisphenols at all
A direct thermal label has no ink. The EU explains the material well in the recitals of Commission Regulation (EU) 2016/2235: thermal paper is a base paper with at least one coating, which may contain BPA, and the coating changes colour when heated. BPA works there as the developer that makes the dark colour appear.
When the EU banned BPA in thermal paper, it already worried about a switch to a close cousin. The same regulation asks ECHA, the EU chemicals agency, to watch for a substitution trend towards BPS and report back.
It reminds me of a sweet shop that drops one food colour and quietly moves to another from the same family. The box can truthfully say "no colour X".
It says nothing about colour Y.
A thermal transfer label works differently. Its face has no heat-sensitive coating, because the ink comes from a ribbon. So the colour developer question does not arise on the label face at all. Our lesson on direct thermal or thermal transfer explains both methods.
The rules, place by place
| Where | What the rule says | From | What kind of rule |
|---|---|---|---|
| EU | BPA in thermal paper at 0.02% by weight or more may not be placed on the market | 2 January 2020 | Law |
| EU | Wider restriction on bisphenols, BPS included, with thermal paper reported in scope | Dossier expected by 12 March 2027 | An intention only |
| EU | BPA banned in food-contact adhesives, printing inks, coatings and plastics | Main step 20 July 2026, with a 12-month filling window | Law |
| Washington State | Intentionally added bisphenols restricted in thermal paper | Products made from 1 January 2026 | Law |
| California | BPA in paper receipts, then all bisphenols | 1 January 2028 and 1 January 2029 | Law, as reported |
| India | BPA-free coatings for thermal paper made to the standard | 2025 revision | Indian Standard |
EU: in force since 2020, and the 2027 step
Entry 66 of Annex XVII to REACH, added by Regulation (EU) 2016/2235, says BPA shall not be placed on the market in thermal paper in a concentration of 0.02% by weight or more after 2 January 2020.
The text says thermal paper. It does not limit itself to receipts, so my reading is that a direct thermal paper label sold in the EU falls inside it.
The 2027 date is the next step, and it is not a ban yet. Freyr, a compliance consultancy, reported in May 2026 that Germany had told ECHA it intends to propose a restriction on bisphenols that act as endocrine disruptors in the environment. As reported, it would cover BPA, BPB, BPS, BPF and BPAF, thermal paper is among the uses named, and the dossier is expected by 12 March 2027. After a dossier come committee opinions and a decision by the European Commission. That usually takes years, so no date for a BPS ban exists yet.
EU food contact: only if your label touches food
Commission Regulation (EU) 2024/3190 bans BPA in the manufacture of food-contact materials, including adhesives, printing inks, varnishes and coatings, and plastics.
The dates matter for anyone packing food for the EU. Single-use food-contact articles made with BPA could be placed on the market until 20 July 2026. They may then be filled with food and sealed for 12 more months, so roughly until 20 July 2027. Single-use articles for preserving fruit, vegetables and fishery products get until 20 January 2028.
Most labels sit on the outside of a pack and never touch the food. A label stuck straight onto cheese, fish or fruit is a different case. For that label, ask for a food-contact compliance statement that names Regulation (EU) 2024/3190.
USA: Washington now, California for receipts
Washington's rule, WAC 173-337-114, restricts intentionally added bisphenols in thermal paper from 1 January 2026. It does not apply to products made before that date, or to products the FDA regulates as medical devices. Ecology, the state regulator, presumes that bisphenols above 200 ppm were intentionally added, unless the maker proves otherwise.
California's AB 1604 was signed on 30 September 2026, as reported by SGS. The reports say it bans intentionally added BPA in paper receipts from 1 January 2028 and all intentionally added bisphenols from 1 January 2029. Labels are not reported to be in scope. I could not open the bill text itself, so treat these details as reported.
India: a standard, voluntary for now
The Bureau of Indian Standards revised IS 17568 in 2025. Its Standards of the Month note for November 2025 says the first revision mandates BPA-free coatings, recommends BPA-free packaging, and adds two categories, thermal coated and top coated.
Two words of caution. An Indian Standard is voluntary unless the government makes it compulsory through a Quality Control Order, and I did not find one for thermal paper. And the BIS note speaks of BPA-free coatings. It does not mention BPS.
What changes in 2027, in one list
- By 12 March 2027, as reported: the EU bisphenols dossier. Watch it, but nothing is banned by it.
- Around 20 July 2027: the end of the 12-month filling window for most single-use food-contact articles made with BPA in the EU.
- No new thermal paper rule takes effect in 2027 in the EU, Washington, California or India, as far as I found.
- If you also supply till rolls into California, 2028 and 2029 are the dates to plan for.
Five questions to ask your label supplier
- Is this label direct thermal or thermal transfer?
- If direct thermal, which colour developer is in the coating: BPA, BPS, another bisphenol, or a developer that is not a bisphenol? "BPA-free" alone does not answer this.
- Can you share the paper coater's declaration and a test report for this lot, with the laboratory, the method, the date and the result?
- Does the paper conform to IS 17568:2025?
- If the label may touch food going to the EU, is there a food-contact statement covering the adhesive and the ink?
Then file each answer against the lot number of the rolls you bought. We would call this traceability for your own labels, and it costs nothing but a folder.
A check you can do yourself: scratch the label face hard with a fingernail. A dark mark means a heat-sensitive coating, so it is direct thermal and the questions above apply. No mark means thermal transfer.
I cannot tell you from a photo whether a label contains BPS. Nobody can. It needs a laboratory test or the coater's declaration.
If the answers do not satisfy you, switching to thermal transfer removes the coating question, at the cost of a ribbon. Our lesson on the real cost per shipping label shows how to price that change.
These five questions apply to us as well. Jagannath Labels, our group's label company, should answer them in writing like any other supplier would. Send them to us through the contact page and hold us to the same standard.
Questions buyers ask
Does the EU BPA rule cover direct thermal labels, or only till receipts?
The EU text says "thermal paper", not receipts. A direct thermal paper label is thermal paper with an adhesive on the back, so I would treat it as covered. The recital that explains the rule talks about receipts because cashiers handle them most.
Is BPS the safe replacement?
The EU itself was not sure. When it adopted the BPA ban for thermal paper in 2016, it asked ECHA to watch for a switch to BPS. Washington State now restricts BPS along with BPA. If you want to avoid the question, ask for a label free of all bisphenols.
Can I test my labels for BPA myself?
No. It needs a laboratory. What you can do yourself is check whether a label is direct thermal at all, with a fingernail scratch, and then ask the supplier for a test report on that lot.