California Governor Gavin Newsom signed AB 1604 on September 30, 2026, creating tiered restrictions on bisphenols in paper receipts. The law adds California to a growing number of states regulating both the chemical composition of thermal receipt paper and the rules around when paper receipts may be issued.
California Joins Other States in Restricting Bisphenols in Receipt Paper
AB 1604 targets paper "proofs of purchase" (including receipts provided at point of sale for food, alcohol, goods, or services) in two phases:
- January 1, 2028: Prohibits manufacturing, distributing, selling, or offering for sale a paper proof of purchase containing intentionally added bisphenol A (BPA)
- January 1, 2029: Expands the restriction to all intentionally added bisphenols
By defining "bisphenol" structurally rather than listing individual compounds, California's law covers common substitutes like bisphenol S (BPS). That matters because many manufacturers replaced BPA with BPS after earlier restrictions took effect. The law also requires manufacturers replacing bisphenols to use the "least toxic alternative" and prohibits specified carcinogens and reproductive or developmental toxicants as substitutes. Violations are subject to administrative penalties imposed by the Department of Toxic Substances Control of up to $5,000 for a first violation and $10,000 for each subsequent violation.
California's framework follows Washington state, where restrictions on intentionally added bisphenols in thermal paper (including receipts, tickets, and labels) took effect January 1, 2026 under the state's Safer Products program. Washington's rule includes a rebuttable presumption that bisphenols detected above 200 parts per million were intentionally added.
California and Washington are not the first states to regulate chemicals in receipt paper. Connecticut has prohibited BPA in thermal and cash-register receipt paper for more than a decade. Illinois similarly prohibits BPA-coated thermal paper from being manufactured for sale in the state and generally prohibits its distribution or use for business and banking records, including receipts and records of credit, withdrawals, deposits, and debit- and credit-card transactions.
California and Washington, however, represent a broader approach. Rather than regulating BPA alone, both states have moved toward restrictions on bisphenols as a class.
New York and New Jersey Consider Limits on Paper Receipts
Legislatures in New York and New Jersey are considering proposals that move beyond chemical content to address when businesses provide paper receipts at all.
- New York (S.7507-A/A.8359): Would shift businesses toward an opt-in model. Starting January 1, 2028, covered businesses generally could provide a proof of purchase only at the consumer's option rather than automatically printing one. Beginning in 2030, consumers requesting a proof of purchase generally could choose between paper and electronic formats.
New York is separately considering S.9688/A.1276, which would prohibit BPA in transaction paper and restrict manufacturers from replacing BPA with another chemical established to be a carcinogen, developmental toxin, endocrine disruptor, or reproductive toxin. Manufacturers instead would be required to use the "least toxic alternative." - New Jersey (A.1851): The proposed "Paper Receipt Reduction Act" initially would prohibit covered business and banking records printed on paper containing added BPA or BPS. Beginning in the thirteenth month after enactment, covered retailers and service providers generally could no longer provide paper records, subject to specified exceptions. The proposal extends beyond retail receipts to credit slips, withdrawal and deposit slips, debit- and credit-card transaction records, and associated coupons and advertisements.
The New York and New Jersey proposals thus reflect another potential shift in receipt regulation: from controlling the chemicals used in paper to reducing the circumstances in which paper receipts are generated in the first place.
Proposition 65 Creates More Immediate Risk for BPS in Receipts
While California's new statutory restrictions do not begin until 2028, businesses already face private enforcement involving BPS in receipt paper under Proposition 65.
BPS is listed under Proposition 65 as a chemical known to cause reproductive toxicity. Private enforcement groups have issued numerous 60-day notices alleging exposure to BPS through thermal receipts, targeting retailers and restaurants as well as receipt-paper manufacturers, distributors, and other supply-chain participants.
Those claims are already producing settlements. In August 2026, the Center for Environmental Health announced agreements involving 163 retailers, manufacturers, and receipt-paper distributors concerning alleged BPS exposure from receipt paper. According to the organization, the settlements require participating companies to transition to BPS-free or broader phenol-additive-free paper. In September 2026, the organization also obtained the first court-approved settlements involving BPS in receipt paper.
Other settlements similarly have required businesses to use qualifying BPS-free receipt paper and pay civil penalties and attorneys' fees and costs.
California businesses therefore may face current Proposition 65 exposure involving BPS while preparing for statutory restrictions that eventually will reach the broader bisphenol class.
Receipt Regulation Expands Beyond BPA
The state approaches reflect an evolving regulatory landscape. Connecticut and Illinois adopted earlier BPA-specific restrictions. Washington now regulates bisphenols more broadly, and California will phase in a similar approach. New York is considering restrictions designed to prevent problematic BPA substitutions, while New York and New Jersey also are considering limits on routine paper receipt distribution.
The resulting compliance issues extend well beyond paper manufacturers. Retailers, restaurants, hotels, financial institutions, paper suppliers, and other businesses that issue receipts increasingly may need to consider both what is in their receipt paper and when they may provide it.
Venable is continuing to monitor state legislative and regulatory developments affecting paper receipts and bisphenols. The Venable team can assist businesses in evaluating applicable requirements, assessing supply-chain and point-of-sale practices, and responding to Proposition 65 notices and other enforcement activity.