Starting January 1, 2026, the state of Washington will restrict the sale, distribution, and manufacture of intentionally added bisphenols in thermal paper under the Safer Products Restrictions and Reporting Rule (WAC 173-337-114).
▶Bill Content:
According to the Washington State Department of Ecology, thermal paper is coated with a material that changes color when exposed to heat. Products made of thermal paper include receipts, packaging labels, and tickets.
The Ministry of Ecology assumes that a detected bisphenol concentration exceeding 200 ppm indicates intentional addition of bisphenol. Manufacturers can refute this assumption by submitting a declaration containing the following information to the Ministry of Ecology
Submit the name and address of the declarant
Credible evidence, relevant information, data, or sources supporting the claim that bisphenol is not intentionally added.
The final regulatory analysis report by the Ministry of Ecology and Environment states: "Thermal paper is one of the primary sources of human exposure to BPA and BPS—the most widely studied bisphenols.". ”
This rule does not apply to consumer products manufactured before January 1, 2026, or consumer products regulated by the FDA as medical devices.
▶Bill Background:
WAC 173-337-114 is a section under Chapter 173-337 of the *Washington Administrative Code*, titled "Safer Products Restrictions and Reporting," officially adopted by the Washington State Department of Ecology on May 31, 2023, and effective July 1, 2023. Its legislative background traces back to Chapter 70A.350 of the *Washington Revised Code* (RCW 70A.350), revised by the state legislature in 2021, which authorizes the Department of Ecology to establish a regulatory program targeting "priority chemicals" in "priority consumer products" to reduce exposure to toxic chemicals, protect public health and the environment, and enhance product ingredient transparency.
