You may have read that the use of BPA in cash receipts has been recently restricted in Europe. How does such a restriction process work and why has BPA been restricted?
Why and how are substances restricted for certain uses?
In Europe, the manufacture and use of chemical substances is regulated by REACH, the Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals. It constitutes the framework legislation on chemicals in the EU. REACH foresees a restriction procedure which may limit or ban the manufacture, placing on the market or use of a substance.
Restrictions can be proposed by Member States, the European Commission or the European Chemical Agency (ECHA), when they have a concern that a certain substance poses an unacceptable risk to human health or the environment. ECHA works with experts from the Member States to provide scientific opinions on any proposed restriction. ECHA’s Risk Assessment Committee (RAC) reviews whether the proposed restriction is appropriate in reducing the risk to human health or the environment. ECHA’s Socio-Economic Analysis Committee (SEAC) reviews the socio-economic impacts of a proposed restriction. Both Committees prepare their opinions which are then submitted to the European Commission for a final decision. The Commission will take a balanced view of the identified risks and of the benefits and costs of the proposed restriction. The ultimate adoption of the restriction involves also Member States and the European Parliament.
What about the BPA restriction in cash receipts?
Thermal paper is a special fine paper that is coated with a reactive layer (sometimes containing BPA as dye developer) that changes colour when exposed to heat. Cash receipts made from thermal paper can therefore contain low levels of BPA. Concerned about potential health risks resulting from exposure to small quantities of BPA, mainly for pregnant workers, the French authorities submitted a proposal to ECHA in 2014 to restrict BPA in thermal paper.
In its June 2015 opinion, ECHA’s Risk Assessment Committee (RAC) stated unequivocally: “Significantly, RAC did not identify a risk for consumers”, thus being consistent with the EFSA opinion on BPA (January 2015) confirming the safety of these applications for consumers. At the same time, RAC proposed that the use of BPA in thermal paper for workers should be restricted, even though the risk identified was very hypothetical and extremely unlikely to become real. ECHA´s Socio Economic Assessment Committee (SEAC) concluded that the socio-economic benefits would unlikely be higher than the socio-economic costs of the proposed restriction. However it noted that there could be other considerations in favour of the restriction that should be taken into account.
The European Commission reviewed the two opinions and concluded in April 2016 that a restriction would be appropriate in order to guarantee a high level of protection for workers (primarily cashiers) who handle thermal paper receipts. Thermal paper containing BPA in a concentration equal to or greater than 0.02 % by weight shall therefore not be placed on the market after January 2, 2020.