Compliance

A Commitment To Our Partners

As the ever evolving landscape of North American regulatory legislation continues to change, Kanzaki is committed to ensuring we offer products that are not only compliant with the latest chemical safety standards, but also designed and engineered responsibly, with the intent of improving the overall sustainability of our organization.

Impacts Of Impending Legislation

As new legislation is introduced, converters and laminators must rely on their suppliers ability to stay informed and knowledgeable about the implications of new regulations in various US states. Kanzaki has a team of experts and technicians dedicated to understanding the latest standards and engineering solutions for our partners.

Below are some upcoming regulations that we expect to have direct implications on the direct thermal industry.

CA. BPS, Prop. 65

BPS, a common chemical in direct thermal paper coatings, has been designated as hazardous. Any products being sold into CA containing BPS may require hazard labeling.

STARTING DEC. 29, 2024

Learn More...

WA. Bisphenol Ban

Products containing Bisphenols (a common chemical compound found in most direct thermal products) above 200 ppm will not be eligible for sale in the state of WA.

STARTING JAN. 1, 2026

Learn More...

Your Solution To DT Compliance Concerns

Kanzaki is proud to introduce our Enviro-Compliance Initiative, a growing portfolio of products designed with safer chemistry and increased sustainability to remain compliant for sale in all 50 states. When you see the Enviro-Compliance DT label on one of our product info sheets, it indicates:

Utilizes Patent Pending No-Phenol-Added Direct Thermal Chemistry.
Compliant In All 50 States. (Includes: CA, Prop 65 and WA Bisphenol ban)
Engineered with Environmental Health and Safety In Mind.
Designed for Reduced Waste & Increased Sustainability.

This is an on-going initiative with a strategic timeline of products slated to launch between 2024-2026. Sign up below to receive email updates about new products and other helpful information related to regulatory legislation and compliance in the Direct Thermal Industry.

Understanding Our Terminology

As regulations are implemented and the market reacts, new terminology is continually introduced to facilitate the conversations and marketing of product developments taking place in response to new regulations. One example of this is the term "Phenol Free" emerging in the direct thermal market in recent years. This has been in response to expanding regulations limiting the use of Bisphenols, like (BPA, BPS amongst others).

Below we explain why Kanzaki is choosing to use the term "No-Phenols-Added" in place of "Phenol-Free".

"No-Phenols-Added"

“No-Phenols-Added" is synonymous with “phenol-free" as used by other DT suppliers.

Indicates that no phenols were intentionally added during the manufacturing process. This is a more accurate and defensible statement.

Using this term could potentially decrease liability exposure, compared to stating “phenol free.”

ACCURATE TERMINOLOGY

"Phenol-Free"

Use of “Phenol-Free” is common industry jargon in the thermal paper industry, but is chemically inaccurate in describing the current state of affairs.

Thermal paper manufacturing involves many chemicals and upstream raw materials which could contain detectable levels of Phenolic compounds that are not hazards or restricted by regulations.

The WA state bisphenol ban prohibits only bisphenols that are "intentionally added", acknowledging the impossibility behind the idea of eliminating all phenols as a contaminant completely.

MISLEADING, INNACURATE

IMPORTANT NOTE: Kanzaki has a dedicated Environmental Department that diligently screens every supplier and every raw material that we include in the production of our products. We are required by California State Law to disclose any use of chemicals listed under California Prop. 65 in our products.

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BPS & CA Prop 65 FAQ

1. What is California Proposition 65?

California Proposition 65, also known as the Safe Drinking Water and Toxic Enforcement Act of 1986, requires businesses to provide warnings when their products expose consumers to chemicals known to cause cancer, birth defects, or other reproductive harm. The list of chemicals is updated annually, and companies must ensure compliance with the regulation by labeling products that contain listed substances. More information can be found on the OEHHA website.

2. What is BPS (Bisphenol S) and why was it added to Prop 65?

BPS (Bisphenol S) is a chemical used in thermal paper coatings as a replacement for BPA (Bisphenol A). It is a developer that helps create images on direct thermal paper. BPS was added to the Proposition 65 list because of concerns about its potential to cause reproductive harm. This means companies using BPS must now assess and provide warnings if exposure exceeds safe harbor levels. Learn more about BPS and Proposition 65 on the OEHHA BPS Fact Sheet.

3. How does the addition of BPS to Prop 65 affect paper converters and laminators?

If your business manufactures or converts direct thermal labels or paper containing BPS, you must assess the potential exposure of your products. If the exposure exceeds California's safe harbor levels, your products must carry a Prop 65 warning label. Failure to comply with the regulation can lead to fines and legal actions. For more details on compliance, you can visit the official Prop 65 regulatory guidelines.

4. What steps should paper converters and laminators take in response to this change?

Review formulations: Check if BPS is present in your thermal paper products.

Testing and analysis: Conduct exposure assessments to determine if your products exceed the safe harbor levels for BPS.

Update labeling: If necessary, include Prop 65 warnings for BPS exposure on your product packaging.

Explore alternatives: Consider using BPS-free thermal paper options.

5. Are there safe harbor levels for BPS under Prop 65?

It is unclear if CA will establish specific safe harbor levels for BPS. However, Prop 65 establishes specific safe harbor levels for chemicals that cause reproductive toxicity. For BPS, the safe harbor level set by California is 0.1 milligrams per day for dermal exposure (skin contact). This means that if the exposure to BPS from your product is at or below this level, no warning is required. If the exposure exceeds this threshold, a warning label must be applied.

To comply with Prop 65, it is crucial to assess your products and ensure that BPS exposure falls within the acceptable range. This may involve conducting exposure testing or collaborating with testing labs to ensure your direct thermal papers meet these safety standards.

6. What should I do if my product exceeds the safe harbor level?

If testing reveals that BPS exposure exceeds the safe harbor level, you must:

Provide clear and reasonable warnings: Add appropriate Prop 65 warning labels on your packaging and product documentation.

Implement risk mitigation strategies: Consider adjusting your product’s formulation or switching to BPS-free alternatives.

Learn about the requirements for clear and reasonable warnings under Prop 65 according the the CA Government.

7. Are all direct thermal papers affected by BPS under Prop 65?

Not all direct thermal papers contain BPS, as some use alternative chemicals as developers. It’s essential for paper converters and laminators to review their thermal paper formulations and work with suppliers to determine if BPS is used and explore safer alternatives where applicable.

For more information on potential alternatives, consult with thermal paper suppliers like KANZAKI, who have teams of technical experts researching materials that comply with Prop 65.

8. What are the penalties for non-compliance with Prop 65?

Failing to comply with Prop 65 can result in fines of up to $2,500 per violation, per day. Businesses may also face legal actions, including lawsuits from both public enforcement bodies and private citizens.

To read more about penalties and who enforces Prop 65, Click Here.

9. How can I find BPS-free direct thermal papers?

DT paper manufacturers, like KANZAKI, offer or are developing Non-BPS and Non-Phenol thermal papers in response to sustainability initiatives and increased regulatory scrutiny. Engage with your suppliers to explore BPS-free options or research developers that meet both performance and regulatory standards.

KSP Customer Service can be reached at (888)-526-9254.

10. Where can I get more information on Prop 65 and BPS?

California Office of Environmental Health Hazard Assessment (OEHHA): The official OEHHA website provides updates and detailed information on Prop 65 requirements and new chemicals. Visit OEHHA’s Proposition 65 page for the latest updates.

Industry Associations: Industry groups such as the Paper and Packaging Board may offer resources specific to paper converters and laminators dealing with Prop 65 compliance.

Legal and Compliance Advisors: Consulting with legal experts who specialize in Prop 65 compliance can help ensure your business meets all necessary regulations.

11. What future developments should I be aware of?

California’s regulatory landscape is continuously evolving. New chemicals may be added to the Prop 65 list, and safe harbor levels may change. Stay proactive by regularly reviewing the OEHHA’s updates and engaging with industry associations to stay ahead of regulatory changes.

You can track updates on chemicals and safe harbor levels at the OEHHA website.

WA Bisphenol-Ban FAQ

1. What is the bisphenol ban in Washington State?

Washington State passed legislation that bans the use of bisphenols, including Bisphenol A (BPA) and Bisphenol S (BPS), in certain consumer products, including thermal paper. This regulation is part of Washington's broader effort to reduce toxic chemicals in consumer goods. The ban applies to thermal paper used in receipts, labels, and other similar products to limit exposure to bisphenols, which have been linked to reproductive harm and other health issues. The full text of the law can be found at the Washington State Legislature website.

2. What bisphenols are covered under the ban?

The Washington State ban specifically covers Bisphenol A (BPA) and Bisphenol S (BPS), both of which are commonly used as developers in thermal paper. The regulation may also apply to other bisphenols if they are used as replacements for BPA or BPS.

3. How does the bisphenol ban affect paper converters and laminators?

If your company manufactures or converts direct thermal paper labels or other products for sale in Washington, you will no longer be able to use thermal paper that contains BPA or BPS. This means:

You must phase out bisphenol-containing materials.

Switch to alternative developers that comply with the ban.

Ensure that your supply chain is free of these bisphenols.

4. What steps should paper converters and laminators take to comply with this ban?

Review your thermal paper formulations: Determine whether your thermal paper contains BPA or BPS.

Find alternatives: Identify and test BPS-free thermal papers that use safer chemicals for developing images on direct thermal paper.

Engage suppliers: Work with your thermal paper suppliers to ensure compliance with Washington State regulations.

Plan product transition: Begin phasing out bisphenol-containing products from your supply chain to meet the state’s deadlines.

5. Are there deadlines for phasing out bisphenols in Washington?

Yes, the legislation has set specific deadlines for when the sale or distribution of bisphenol-containing thermal paper must cease. The key date is January 1, 2025, by which time all thermal paper products sold or distributed in Washington must be free of BPA, BPS, or other restricted bisphenols.

6. What are the penalties for non-compliance?

Businesses that fail to comply with Washington's bisphenol ban may face:

Fines: Penalties for violating the law can be substantial, though exact amounts may depend on the severity and duration of the violation.

Market restrictions: Non-compliant products may be banned from sale in Washington State.

Reputational damage: Failure to meet regulatory standards can damage a company’s reputation, especially with environmentally conscious customers.

7. Are there alternatives to BPA and BPS in thermal paper?

Yes, several alternatives to BPA and BPS have been developed for thermal paper. Some of these include:

Phenol-free developers: New, safer chemicals have been introduced as replacements for bisphenols. These alternatives reduce toxic exposure and comply with Washington’s regulations.

Vitamin C-based developers: Some thermal paper manufacturers have explored vitamin C-based chemical formulations, which are considered safer and environmentally friendly.

It is recommended to work with your thermal paper suppliers to ensure that the alternative materials meet both performance and regulatory standards.

8. Do these bans only affect Washington, or could they spread to other states?

Although the current ban is specific to Washington, other states have been considering similar legislation as part of the broader movement to regulate chemicals of concern in consumer products. States such as California, Maine, and New York have also been scrutinizing the use of bisphenols in various products, so it is possible that similar restrictions could be adopted elsewhere.

9. Where can I get more information on the Washington State Bisphenol Ban?

Washington State Department of Ecology: This is the primary agency responsible for regulating chemicals under the bisphenol ban. Their website provides updates, guidance, and resources for businesses. Visit here.

Legal and Compliance Advisors: Consulting with legal professionals who specialize in environmental and chemical regulations can help ensure your company’s compliance with Washington’s ban.

Industry Groups: Organizations like the Paper and Packaging Board or the Specialty Paper Industry provide insights on how other companies are adapting to the bisphenol ban.

10. What future developments should I be aware of?

Regulatory trends toward reducing harmful chemicals in consumer products are growing both in the U.S. and globally. Washington’s bisphenol ban could be a precursor to similar regulations in other states or at the federal level. Additionally, the state’s program to reduce harmful chemicals is continually updated, so businesses should monitor potential new additions to the list of restricted chemicals.

Additional Resources:

Washington State Legislature: The official website of Washington's laws and regulations can be found at https://apps.leg.wa.gov/. You can search for specific laws, like the bisphenol ban, directly on this site.

Washington State Department of Ecology: The Department of Ecology’s website provides detailed information on reducing toxic chemicals in products, including the bisphenol ban and safer alternatives. You can visit their main page here: https://ecology.wa.gov/, and search for relevant programs like "Safer Products for Washington" and bisphenol regulations.