Collaboration in the supply chain is a must to better understand several issues such as: what is needed by users, which alternatives are available from providers, what alternatives to BPA are considered safe and not safe? Initiatives like ChemSec market place or the INERIS certification of phenol free thermal papers are considered good tools to move to safer thermal papers.
The REACH restriction on BPA in thermal paper still raises many questions, e.g. what is meant by "BPA shall not be placed on the market.." ? (e.g. is the use of stocks of BPA thermal paper allowed after January 2020? Is it still allowed to manufacture BPA thermal paper for export? etc.) ECHA and/or enforcement authorities should develop Q&A on the BPA restriction to clarify duties of each actor in the supply chain.
Authorities/policy makers should promote Sustainable/Green Chemistry and fund research to avoid regrettable substitution. Assessment programs of alternatives should continue and be better coordinated at EU level. Instead of assessing substances "one by one", the assessment should use a "grouping approach" (e.g. assess all phenols at once).
Coherency is needed between different pieces of EU legislation (e.g. REACH/ Food Contact Materials) in order to avoid "grey zones" and situations where some uses are restricted in REACH but are still possible under other legislations. BPA is restricted in thermal papers but what about (food contact) "films"?