Market Update: California Proposition 65


The state of California added Bisphenol S (BPS) to its list of chemicals regulated under its Proposition 65 law (Safe Drinking Water and Toxic Environment Act of 1986).

BPS is a color developer that is commonly used in thermal papers to create the image. BPS replaced Bisphenol A (BPA) which was previously added to Proposition 65 in 2015. Beginning in 2012 BPS has been the primary color developer used in thermal paper.

Proposition 65 requires warnings starting one year from the listing date, which is Dec. 29, 2024. To comply with the Proposition 65 legislation, Iconex will add Proposition 65 warning labels to all thermal receipt paper products beginning in early July regardless of their ship-to location. Labeling products approximately 6 months before the legislation takes effect provides the best path for compliance. We also recommend that customers manage their current inventory to ensure compliance by rotating current non-compliant products and implementing an audit process for all shipments being sent to California.

Iconex will not provide indemnity for Prop 65 non-compliance. We strongly suggest that all customers take the steps necessary to understand any additional compliance on your part that may be required with this legislation. Likely, customers using BPS-containing products will also need to warn the consumer at the point of purchase.

Receipt products using phenol-free papers feature alternative color developers that are not affected by this legislation. As the market leader, Iconex has a suite of phenol-free papers available to facilitate any customers who wish to transition their current products and avoid any issues related to compliance. Bond and carbonless receipt products will not require a warning label to comply with Proposition 65, as they do not contain color developers.

Iconex appreciates your partnership as we navigate the implementation of the upcoming legislation. Please reach out to your sales representative with any related questions.

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