3. Table of Contents
1 INTRODUCTION..................................................................................................................................1
2 PROJECT APPROACH AND RESOURCING ....................................................................................2
3 MARKET ANALYSIS OBJECTIVES AND SCOPE ............................................................................2
4 LÄNSTRAFIKEN’S REQUIREMENTS................................................................................................2
4.1 CURRENT STATE............................................................................................................................2
4.2 TARGET STATE AND FUNCTIONAL SPECIFICATIONS ..........................................................................3
5 MARKET ANALYSIS...........................................................................................................................3
5.1 THERMAL PRINTING TECHNOLOGY ..................................................................................................3
5.2 WHAT IS THERMAL PAPER? ............................................................................................................4
5.2.1 The Structure of Thermal Paper..............................................................................................5
5.2.2 Choosing the Right Thermal Paper.........................................................................................6
5.3 HISTORICAL DEVELOPMENT OF THERMAL PAPER.............................................................................7
5.4 THERMAL PAPER MARKET SIZE AND APPLICATIONS .........................................................................8
5.5 THE USE OF BISPHENOL A..............................................................................................................9
5.6 INDUSTRY STRUCTURE, TRENDS AND PROFITABILITY .....................................................................10
5.6.1 Industry Structure ..................................................................................................................10
5.6.2 Industry Trends......................................................................................................................11
5.6.3 Industry Profitability ...............................................................................................................13
5.7 THE REGULATORY ENVIRONMENT.................................................................................................14
5.7.1 Regulation in the EU .............................................................................................................14
5.7.2 The US Regulatory Environment and the EPA Assessment ................................................15
5.8 MANUFACTURER/SUPPLIER INTERVIEWS .......................................................................................16
5.8.1 Findings.................................................................................................................................17
6 THE OUTLOOK FOR BISPHENOL-FREE PAPER ..........................................................................19
6.1 PRODUCT ATTRACTIVENESS TO MANUFACTURERS ........................................................................19
6.2 BARRIERS TO DIFFUSION ..............................................................................................................20
7 CONCLUSIONS AND RECOMMENDED NEXT STEPS ..................................................................22
4. 1 Introduction
Although a large number of studies on the toxicity and hormonal activity of BPA in laboratory animals
have been published, there have been considerable discrepancies in outcome among these studies with
respect to both the nature of the effects observed as well as the levels at which they occur (WHO, 2010).
In particular, the effects in some of the research studies were described at dose levels several orders of
magnitude below those at which effects were reported in studies conducted in accordance with standard
test guidelines. This has led to controversy within the scientific community about the safety of BPA and
has resulted in various national authorities taking different risk management actions. The issue has also
received much attention in the media, which has led to a concerned general public.
During the fall of 2010 the Jegrelius Institute for Applied Green Chemistry (Jegrelius) analysed and found
high levels of the suspected endocrine disrupting chemical Bisphenol A (BPA) in ordinary receipts. These
results were in line with studies undertaken elsewhere and have had a major impact in Sweden and other
countries and given rise to a need to find alternatives to receipts that contain BPA.
The research found that those that handle receipts regularly, for example cashiers, may be exposed to
almost twice as much bisphenol A as a normal person. The report concluded that there is a risk that this
exposure may be a health hazard and thus the use of thermal paper that contains bisphenol A should be
minimised.
Analysis showed that Länstrafiken Jämtland (Länstrafiken), a regional transportation company owned by
Jämtland County Council, also had high levels of BPA in their bus tickets. In view of the potential risk to
its employees who handle large quantities of bus tickets, Länstrafiken decided to seek an alternative
solution. Länstrafiken have recently replaced their old thermal paper with a new paper which does not
contain BPA. It is currently unclear what replacement chemical(s) is included in this product or what the
risks of this new paper may be. Furthermore, Länstrafiken have stated an intention to replace their
ticketing machines on all buses from the Summer 2011. As such, a review of the current (or near to)
market offerings has been requested in order that an informed decision can be made during this
procurement.
Länstrafiken and Jegrelius have now formed a cooperation to find a solution and have initiated a project
entitled “Bisfenolfria biljetter - Länstrafiken Jämtland”. This project has four specific objectives:
1. To highlight and give an explanation for the conflicting views and information from industry,
government, scientists and environmental organizations in the risk assessment of BPA.
2. To identify the technology front and the market for BPA-free thermal paper in general and identify
specific products suitable for Länstrafiken’s needs and situation.
3. To undertake a risk assessment of the substitute chemicals for BPA in the alternative products.
4. To build a body of material and knowledge with which to provide further assistance and
cooperation to other companies seeking alternatives to BPA in their receipts.
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5. 2 Project Approach and Resourcing
Jegrelius is responsible for project management and reporting. Lena Stigh and Tomas Östberg have
been assigned by Jegrelius to lead the project and deliver the final report. Justin Jeffs of Scandinavian
Sustainability Consulting has been assigned with responsibility for producing the market analysis.
Activity Responsibility
Problem Description BPA Tomas Östberg
Market Analysis Justin Jeffs
Patent Search and Analysis Lena Stigh
Risk Assessment of Alternatives Lena Stigh/Tomas Östberg
Final Report Lena Stigh
A total of 55 hours have been allocated for the market analysis.
3 Market Analysis Objectives and Scope
The objective of the market analysis is to understand the market potential to procure a suitable BPA-free
product for Länstrafiken. The analysis is global in terms of the general market situation but has a focus on
Sweden and Länstrafiken in respect of product procurement. The analysis has been undertaken in three
stages:
1. A preliminary market analysis based on desk based research
2. Discussions with employees of Länstrafiken to understand the current state situation and future
state desired/required situation.
3. Meetings with the major suppliers of thermal paper to the Swedish market to validate the market
analysis findings and to understand what products are currently available or in the pipeline.
No consideration has been paid to alternative ticketing solutions (eg; SMS, smart phones). Nor has
consideration has been paid to the ticketing infrastructure currently used by Länstrifiken in light of the
plans to change this in the Summer of 2011. Länstrafiken is a member of Svensk Kollektiv Trafik (SKL)
and thus there is an opportunity to utilise the findings of this report as the basis for a wider project on
behalf of other members of this organisation. No specific consideration has been given to the
requirements of SKL in this report.
4 Länstrafiken’s Requirements
4.1 Current State
Länstrafiken’s ticketing infrastructure is provided by FARA ASA, a supplier of IT solutions to the public
transport sector in the Nordic countries. The thermal paper used by Länstrafiken was previously
purchased from FARA but is now purchased from Schades AS, a Danish company whose core business
is the production, sale and distribution of both plain and printed paper rolls, self-adhesive labels and food
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6. wrap. Schades have production facilities in Denmark, France, Germany and the UK and provide products
to a variety of industries including retail, financial institutions, lotteries, gaming and entertainment,
ticketing, stationary, food and logistics. Schades sell more than 100 million POS rolls and 6 billion labels
every year.
Länstrafiken currently use Jujo’s AP50KS-NP paper which is manufactured in Finland and converted by
Schades. This is a non-topcoated paper developed for direct thermal printing and designed for use in
cash registers, receipts, coupons and point of sale (POS). The paper is produced without phenol
chemisty and has a ten year image stability and printability guarantee. Länstrafiken currently purchase
circa 10,000 rolls each year.
4.2 Target State and Functional Specifications
Länstrafiken wish to purchase a thermal paper which has a better environmental profile than the
previously purchased paper which contained bisphenol A. A contract has recently been signed with FARA
ASA to upgrade the existing ticketing infrastructure for Länstrafiken. This implementation is expected to
be implemented by June 2011. Any replacement paper rolls therefore need to be compatible with this
infrastructure. The volume of rolls purchased is expected to be unchanged from circa 10,000 per year.
The paper rolls should be capable of being pre-printed on the reverse and do not need to be top-coated.
5 Market Analysis
5.1 Thermal Printing Technology
There are two types of thermal printing:
Thermal Transfer
Direct Thermal Printing
Thermal transfer printing is where a printer prints an image onto paper (or some other material) by melting
a coating of ribbon so that it stays glued to the material on which the print is applied. It contrasts with
direct thermal printing where no ribbon is present in the process. The main application is to produce
barcode labels for product and shipping identification as the ribbons tend to wear out quickly with other
applications.
Direct thermal printing is the preferred technology for a wide variety of commercial applications including
point of sale receipts, luggage tags, faxes, and labels. In the direct thermal printing process, a printed
image is produced by selectively heating specific areas of coated thermal paper as it is passed over a
thermal print head. The coating undergoes a colour change in the areas where it is heated, producing an
image. This temperature-induced colour change is termed as thermochromism (MacLaren etal, 2003).
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7. Figure: The direct thermal printing process (Source: Mitsubishi, 2010)
5.2 What is Thermal Paper?
Thermal paper is a special fine paper that is impregnated with a chemical that changes colour when
exposed to heat. It is used in thermal printers and particularly in cheap, lightweight devices such
as adding machines, cash registers and credit card terminals.
The surface of the paper is impregnated with a solid-state mixture of a dye and a suitable matrix. When
the matrix is heated above its melting point the dye reacts with the developer, shifts to its coloured form,
and the changed form is then conserved in metastable state when the matrix solidifies back quickly
enough.
Components of thermal paper include:
Colour former – Leuco dye that is light/coloured or colourless but will change to a dark colour with
the addition of a proton which opens the lactone ring.
Colour developer – the weak acid that donates a proton to the colour former, changing it from
light to dark.
Modifier/sensitizer – can reduce the melting point of the colour former & developer mix.
Binders – adhere the coating to the paper.
The degree to which the colour-reagents (leuco colour former, acceptor) react is precisely controlled by
special melting point regulators (sensitisers). In this way, various monochrome shades can be created
depending on the amount of energy transferred.
The thermal head in the thermal printer transfers the heat to the thermal paper. A thermal head consists
of a multitude of miniature heating elements distributed along its printing width. Each of these tiny heating
elements is electronically controlled to deliver the right amount of energy at the right time. In this way, the
individual colour points are created which together form the final image – text, graphs, bar codes, etc. A
backing roll ensures that the thermal paper stays in constant contact with the thermal head. A thermal
printer has considerably fewer moving parts than any other printer.
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8. Figure: A chemical reaction occurs when heat is applied to the paper (Source: Source: EPA, 2010).
Typically the coating will turn black when heated. But coatings that turn blue or red are sometimes used.
While an open heat source such as a flame can discolour the paper, a fingernail swiped quickly across
the paper will also generate enough heat from friction to produce a mark on such paper.
5.2.1 The Structure of Thermal Paper
Thermal paper is made up of a base paper layer onto which various layers of chemical compounds are
added. The layers typically include a protective topcoat, the reactive thermal coat, a foundation pre-coat
and a protective backcoat.
Figure: Cross Section of Top-Coated Thermal Paper. (Source: EPA, 2010)
(i) Topcoat
An optional additional topcoat can be applied to the thermal coat to protect the thermal paper from
mechanical abrasion (e.g. through scratches), chemical influences (e.g. through oils, fats, varnishes or
organic solvents) and other environmental influences (e.g. through high humidity or water). A topcoat on
the front side of the thermal paper also extends the service life of the thermal head of the printer by
reducing or eliminating the transfer of residue from the thermal coating on to the thermal print heads. A
top coat can also focus the heat from the thermal print head on the active coating and provide better
anchorage of flexographic printing inks applied to the thermal paper.
(ii) Thermal Coat
The thermal coat contains the reactive chemicals which react when heat is applied to produce the image
on the paper. The composition of the thermal coat determines the sensitivity of the paper, the image
density, the image preservation and the background density.
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9. (iii) Pre-coat
The pre-coat prevents heat conduction into the paper thus enabling the energy from the thermal head to
concentrate in the thermal layer in order to produce high-resolution printing. This layer determines the
sensitivity of the paper, the brightness and the image density and guarantees an even and smooth
surface onto which the thermal coat is applied.
(iv) Back-coat
A back-coat is also optional but essential when the reverse side of the thermal paper is exposed to
migrating adhesives (e.g. adhesives which are used in the production of self-adhesive labels) or
plasticizers (e.g. from plastics like PVC). Furthermore, special back-coats prevent the paper
from curling and enable the use of water-based solvents, inks and adhesives.
5.2.2 Choosing the Right Thermal Paper
To ensure optimum printing results, it is essential that the paper is ideally matched to the application for
which it is required and the printer employed. The results of printing may be very different depending on
the printer used or the environment in which the product is used. It is thus always necessary to test the
product compatibility under the typical printing conditions to achieve the best printout for the final use. Key
factors to consider are the paper’s sensitivity, ageing stability, printability and certification by the thermal
printer manufacturers:
(i) Dynamic and static sensitivity
Sensitivity is the decisive factor in the selection of the correct paper. The dynamic sensitivity is particularly
important in the choice of paper for certain printers. The faster a printer works, the shorter the time the
paper is exposed to the elements of the thermal printing head. Therefore, a fast device requires paper
with a higher dynamic sensitivity. If low sensitivity thermal papers are used, the heat applied is insufficient
to create a printed result with the necessary density, which in turn reduces the long-term stability of the
print. The static sensitivity defines the temperature at which the colour reaction in a thermal paper begins.
The static sensitivity value is important when the papers used are employed in high-temperature
environments such as for car park tickets.
(ii) Aging Stability
Developments in recent years mean that it is now possible to buy papers designed to meet different
archiving requirements with the best papers offering upto 25 years without fading.
(iii) Printability
It is possible to buy paper that can be printed on the functional as well as on the reverse side. However, it
is important to consider which printing method is used and ensure that it is compatible with the paper
type. When printing the thermal layer, care must be taken that the machine settings are adapted to the
paper and that the inks selected must always be compatible with the thermal layer, regardless of whether
the thermal side or the reverse is being printed.
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10. (iv) Certification by printer manufacturers
The paper must be compatible with the thermal printing head used in the printer in order to guarantee a
long service life for the thermal printer and its individual components while achieving a consistently good
printed result. It is therefore important to match the grade of thermal paper to be used to the equipment.
5.3 Historical Development of Thermal Paper
Thermal papers first came to market in the 1960’s. The first papers were developed by NCR Corporation
and 3M. Despite the NCR paper being of inferior quality, whereby the image would fade rapidly, it took a
leading market position over time due to its relative cheapness (Answers.com, 2010). The first thermal
printing head was developed by Texas Instruments in 1965 and the first thermal printer, connected to a
computer terminal, was launched on the market in 1969. During the 1970s Hewlett Packard began
integrating thermal paper printers into its desktop computers and plotters.
In the 1970s and early 1980s, Japanese producers (such as Ricoh, Jujo, and Kanzaki) using similar dye-
based chemistry to that used by NCR, formed partnerships with barcode printer manufacturers (such as
TEC, Sato, and others) and entered the emerging global bar code industry, primarily in supermarkets
(Answers.com, 2010). U.S. producers such as Appleton (NCR's licensee), Nashua Corporation, Graphic
Controls, and others fought to gain market share. Leading pressure-sensitive label producers such
as Avery Dennison became major consumers of direct thermal paper for label applications.
Sales in thermal paper really took off at the end of 1980’s with the launch of fax machines. This resulted
in large investments in production capacity for fax papers. However, in the early 1990’s the fax market
had peaked and began to decrease due to the penetration of laser and inkjet fax machines which did not
suffer from the fading which was common with thermal paper (Fink etal, 2007). Thermal transfer, laser
printing, electro-photography, and to a lesser extent, ink jet printing, began to take market share for
industrial and warehouse barcode applications due to better durability.
In an attempt to protect their investments in thermal paper production capacity, manufacturers were
forced to seek new applications for direct thermal printing. An investment in improved performance and
reliability, including image stability, printability and thermal resistance properties, has led to an increasing
variety of applications. The rapid development in recent years of fast, quiet, reliable thermal printers has
also allowed the speed and accuracy of the printing to improve. The result has been an overall growth in
the market for thermal paper which has more than compensated for the drop in thermal fax paper.
Today, direct thermal printing technology dominates ticket, tag and label printing and is showing steady
growth and diversity. Point-of-sale (POS) is an ever-growing market for thermal printing. Applications
include printing of bank statements and ATM receipts, receipts from credit card payments and ticketing for
lottery, travel, leisure and sports events. The main uses in manufacturing applications are product
labelling, inventory control, tracking, shipping and maintaining of work in progress. Airline luggage tags
and boarding passes as well as medical charts have also become interesting markets for the thermal
printing industry.
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11. Direct thermal printing has maintained its market penetration and growth due its inherent benefits over
other alternative methods of printing. These can be summarised as follows:
fast printing and no changing of peripherals
high image resolution
very high reliability and durability
small, compact printing units ideal for handheld devices
easy handling in applications
no additional consumables (e.g. toner or inks)
low running costs – low energy and maintenance
low noise due to the "non-impact" printing process
high functionality even under extreme environmental conditions
no fouling of the print head
excellent ink receptivity
The traditional drawbacks of thermal paper, such as paper curling and fading of the printed image over
time, are less of an issue today as the ability to add special layers has developed over the last five years.
These layers also allow printing, most notably advertising, to be applied to the back of the paper. Finally,
a range of thermal papers have security measures available to reduce counterfeiting.
5.4 Thermal Paper Market Size and Applications
After 40 years, thermal printing continues to be a resilient, growing, diversified industry. The worldwide
market for thermal paper in 2006 was approximately 845 thousand metric tons valued at $1.5–1.6 billion
at the producer level (Fink etal, 2007). The long term growth rate for thermal paper has been 10% per
annum. Growth rates have been above average in developing countries with China’s growth estimated at
15% p.a. (Fink etal, 2007). According to estimates in Europe, about half of thermal paper is used in point-
of-sale receipts and nearly a third for self-adhesive labels used for things like deli-trays, shipping labels,
and luggage tags (EU Risk Assessment, 2008). The European Thermal Paper Association has indicated
the remainder is used for lottery tickets and FAX paper.
Figure: Applications of thermal paper in Western Europe 2005/6 (source: EU Risk Assessment, 2008)
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12. 5.5 The Use of Bisphenol A
Bisphenol A is one of the world's most widely used chemicals. Commercial production of BPA began in
the 1950’s when large-scale uses for polycarbonate plastic and epoxy resins were developed. The global
consumption of BPA in 2003 was estimated to be approximately 3 million metric tons (SRI Consulting,
2004). It is estimated that 1,150,000 tons per year were produced in the EU in 2005/2006 (European
Chemicals Bureau, 2008).
BPA is mainly used for products which are used in the chemical industry, construction, engineering, iron,
metal, plastics and service industries. Of the total global volume produced, 71% is used in the production
of polycarbonates (thermoplastic polymers) and 25% in the production of epoxy resins (European
Chemicals Bureau, 2008). Polycarbonates are used for example in the manufacture of beverage bottles,
baby bottles, cups, plates and mobile phones. Epoxy resins are used for adhesives, paints, varnishes and
protective covers for cans to stop corrosion.
Figure: Production and use of BPA in Western Europe 2005/6 (Source: European Chemicals Bureau,
2008 )
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13. Thermal paper benefits from the economies of scale created through the mass production and use of
bisphenol in plastics and resins. It is estimated that 1,890 tonnes of BPA was used in thermal paper in the
EU during the period 2005/6, which is 0.16% of total BPA use in Europe (European Chemicals Bureau,
2008). This was used to make 2.4x109 m2 of thermal paper, equivalent to approximately 168,000 tonnes
of paper.
BPA has been used in thermal paper since the 1960’s due to its known properties as a developer and the
fact that it was widely available and believed to be safe (Toussaint, 2010). As thermal paper became
more established, industry found other chemicals that also worked and in some applications were better
suited. BPA has never got a toehold in higher-end applications due to its relatively low performance (eg;
low tolerance to heat and light) but has remained the primary choice for lower-end applications such as
supermarket and petrol station receipts because it is roughly half the price of alternatives. Even here
some companies are currently using other chemicals.
In spite of the volume of research in existence indicating the potential hazards of BPA, it remains a widely
used developer in thermal printing due to its efficacy, availability, and low cost (Gregory, 1991).
5.6 Industry Structure, Trends and Profitability
5.6.1 Industry Structure
The boom in fax paper in the 1980’s led to a large scale investment in thermal paper manufacturing
capacity. When the fax market began to peak and then decline in the early 1990’s there was significant
overcapacity and fragmentation in the market, particularly in Europe (Lockie, 1998). This overcapacity
forced European producers to look beyond their borders to sell surplus production. Overcapacity also led
to poor profitability in the sector and subsequent market exits from paper convertors. Producer
consolidation was made difficult due to the lack of small producers in the market. One major
manufacturer, Arjo Wiggins of the UK, divested of Appleton following its acquisition in 2000, and
subsequently exited the thermal paper market.
Instead of consolidation, the industry embarked on a strategy of technology development and
differentiation (Lockie, 1998). The result has been a wide range of specialist papers which are high
performance, tailored products for a broad range of uses, built on a common technology requiring cheap
peripherals. Simultaneously, the industry has invested in automation, production excellence and
economies of scale to improve margins. This strategy has enabled the products to be attractive for a
wider range of end-users including retail POS, travel, gaming, medical and financial services.
There are three distinct layers to the supply chain for thermal paper, namely thermal paper
manufacturing, converting and sales/distribution.
1. Manufacturing is defined as both paper production (often from purchased pulp) and finishing. It is
undertaken in large, automated production plans. The manufacturing companies either own or
license the patents for the different chemical formulations necessary to create the various finishes
of thermal paper.
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14. 2. Converting consists of purchasing paper in jumbo rolls and then slitting them to commonly used
sizes for various industries, for example in ATM machines or POS terminals. Converting also
includes printing additional information on to the paper, such as advertising.
3. Trade consists of purchasing the ready-to-use roles from the convertors and redistributing them
to end customers.
Figure: Supply chain for thermal paper (Source: Author)
The manufacturing market is now dominated by a small number of global firms who produce a wide range
of paper products in addition to thermal paper. These include:
Mitsubishi HiTec Paper
August Koehler
Jujo Thermal Ltd
Appleton
Kanzan
Nashua
A more detailed overview of the global manufacturers of thermal paper is included in Appendix 2. Other
firms exist but these are largely sister companies to these manufacturers with a focus on specific markets.
Most of the global firms have some form of Japanese influence with the exception of Koehler of Germany
and Appleton of the US who have remained independent.
There are significant barriers to entry in to the manufacturing market including a large capital investment
in plant and machinery, the development or licensing of patents, the building of supply chains and the
need for a large sales volume to achieve economies of scale.
There are a limited number of convertors of thermal paper in the Swedish market. Two major convertors
are Schades AS from Denmark, who currently supply Länstrafiken, and RollCo Nordic. Details of these
companies are included in Appendix 3.
5.6.2 Industry Trends
Despite the drop off in the 90’s for fax paper the worldwide thermal paper consumption is actually
increasing and is forecast to continue increasing due to two key factors:
Demand driven by economic growth
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15. Technological developments
A driving factor behind the success of thermal paper is the growth in global retail commerce. The
increased use of bank cards in place of cash also increases the need for proof of purchase receipts, often
a regulatory requirement. The low cost of direct thermal technology makes it especially attractive to
developing markets. Furthermore, the reliability, low maintenance demands and the non-dependence on
peripherals makes thermal printing attractive to these markets which typically lack a service and repair
infrastructure (Lockie, 1998).
Secondly, there is an exponential growth in the amount of information that is being printed. More and
more receipts are being used as a vehicle for advertising. POS receipts are now typically double sided,
allowing advertising to be placed on the reverse side, with the front side containing much more than just
the details of the items purchased. These printing processes place extra demands on the thermal paper
and thus the quality of the thermal paper is of increasing importance.
Travel is a growth market for thermal paper. Self-service terminals are increasingly being installed at
airports in particular, but also at other central arrival and departure terminals for rail, ferry and bus. Almost
all of these devices are equipped with thermal printers for tickets, ticket envelopes and baggage tags.
Likewise there is an increasing trend towards printed 2D barcodes as information carriers, away from
magnetic strips (Mitsubishi, 2010).
Direct thermal printing is becoming increasingly popular for portable, mobile applications thanks to the
compact technology used. The increased use of portable POS terminals, in restaurants for example, is
increasing the demand for thermal paper. The increase in the use of portable computers and smart
phones which can connect to these devices will also provide a further market opportunity for thermal
paper.
One of the early problems with direct thermal printing was that the paper would fade and curl with time or
when exposed to heat, light, moisture or chemicals. Recent developments in coatings, both front and
back, have meant that thermal paper can now be bought with a guaranteed ‘non-fade’ lifetime of upto 25
years. Thermal paper with resistance to chemical, moisture and temperature extremes is also widely
available on the market. This durability has increased the range of uses for thermal paper to include, for
example, guarantees, proof of purchase, legal documents, expense reports, tax records and medical
records.
Many types of tickets, especially travel tickets for public commuter traffic, are prone to counterfeiting. In
Germany alone, damages of hundreds of millions of Euros were reported in 2007 (Mitsubishi, 2010). The
thermal paper manufacturers have responded with products which contain a range of security options
including watermarks in the paper, colour inlays, UV-fluorescent fibres and UV-fluorescent security
features under the topcoat
More recently, Ricoh have developed the first rewriteable thermal technology (Ricoh, 2010). This allows
images to be created and deleted through the controlled application of heat. In this way, a single card can
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16. be pre-printed with basic information and then reprinted with supplementary information specific to the
user. Ticketing is a major potential application of this technology as the users travel period, zones, etc.,
can be changed without the need for the issuance of a new card.
Mobile payment technology, enabled through smart phone technology, is increasingly being used for all
types of transactions, including payments. According to research conducted by Yankee Group and made
public at the Mobile World Congress 2011 in Barcelona, mobile transaction volumes are expected to grow
at a very high rate, with the estimated total value of global mobile transactions rising from USD 162 billion
in 2010 to USD 984 billion in 2014 (ThePaypers, 2010). Mobile banking is also set to become more
mainstream. This trend will undoubtedly have an impact on the number of ATM transactions undertaken
and could result in more paperless transactions in the future, thereby reducing the demand for thermal
paper.
The growth in digital cameras, and more recently high quality cameras built into phones, has had a
significant impact on the printing industry and paper providers overall as fewer prints are now made (Fink
etal, 2007). Similarly, alternative printing technologies such as Dye Diffusion Thermal Transfer (DDTT or
D2T2), inkjet and electrophotographic printing are continuing to develop and are predicted to grow,
particularly for professional and desktop printing. Inkjet is perhaps the closest rival to thermal printing.
However due to the low cost of direct thermal printing relative to inkjet and the simple printing technology
which avoids expensive peripherals, thermal printing is still the preferred choice.
5.6.3 Industry Profitability
The thermal paper industry is dominated by a handful of large manufacturers. Historic oversupply in the
manufacture of thermal paper has led to tough competition and depressed prices in the industry. Despite
the specialisation in end products, margins are tight overall with profitability depending on the cost of raw
materials and strong automation to achieve economies of scale in production. The high cost of plant and
machinery necessitates large sales volumes for manufacturers.
During the financial crisis of 2008 the demand for thermal paper dropped. Due to the large fixed cost base
of manufacturers (a reflection of the high cost manufacturing infrastructure) it is difficult to reduce costs
quickly and as such profitability suffered during this period. More recently demand for thermal paper has
increased to pre-crisis levels across all markets and seems to have reverted back to the long term growth
of 10% per year, led by growth in Asia and Russia (Jujo, 2010). The problematic oversupply versus
demand, a factor of the market for many years, is also predicted to reach a more even balance in the
coming years.
The price outlook is one of increasing prices for thermal paper, typically more than 10% in 2010/11 across
the industry (Jujo, 2010). This is primarily due to the increasing cost of all inputs, in particular freight,
chemicals and especially for wood pulp which almost doubled in price in 2009-10 to reach a nine year
high due to increased demand combined with supply shortages (Jujo, 2010). Further investments in
production capacity are likely to be delayed for the time being thus tightening the spread between supply
and demand further. Investments are however likely in further automation, optimisation and for product
specialisation.
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17. 5.7 The Regulatory Environment
As a substance Bisphenol A is not banned anywhere in the world. Extensive scientific testing and
governmental reviews worldwide have concluded that human exposure to BPA is very low and within the
safety limits set by government authorities. However, recent studies using novel low dose approaches
and examining different endpoints describe subtle effects in laboratory animals at very low concentrations
(EPA, 2010). Some of these low-dose studies are potentially of concern for the environment because the
concentration levels identified with effects are similar to some current environmental levels to which
sensitive aquatic organisms may be exposed.
Regulatory authorities around the world reviewing these low-dose studies have generally concluded that
they are insufficient for use in risk assessment because of a variety of flaws in some of the study designs,
scientific uncertainty concerning the relevance to health of the reported effects, and the inability of other
researchers to reproduce the effects in standardized studies (EPA, 2010).
However, since the low-dose studies do raise questions and concerns, some countries have decided to
restrict the use of BPA-based material in food contact products for small children (ages 0-3) as a
precautionary measure while more data is gathered. Canada is the first country in the world that has
classified BPA as a toxic substance. Bans are also in place in Australia, and a few US states.
5.7.1 Regulation in the EU
In the EU’s 2008 risk assessment for BPA (European Chemicals Bureau, 2008), analysis was undertaken
of the potential health risks from exposure to BPA in the workplace, as consumers, from the environment
and from combined exposures. The assessment concluded that “there is at present no need for further
information and/or testing and no need for risk reduction measures beyond those which are being applied
already. This conclusion applies to the terrestrial and atmospheric compartments, and to secondary
poisoning through the aquatic, terrestrial and marine food chains.” In respect of thermal paper the report
concluded that “Other uses of bisphenol-A, such as in printing inks and thermal paper, are considered to
result in negligible potential for consumer exposure in comparison with the other sources considered and
therefore will not be addressed further in this assessment.”
Research undertaken by a host of European organisations including The Federal Institute for Risk
Assessment (BfR) in Germany, The European Food Safety Authority (EFSA) and the British
Environmental Agency have drawn the same conclusions as the EU risk assessment, namely that there is
no risk to humans from current sources of exposure to BPA (Specialpapper, 2010).
Despite this, France and Denmark have banned BPA in baby bottles. Denmark has taken this one step
further and extended the prohibition to all food products for children up to three years old. Furthermore, a
recent decision by the EU Commission now means that from March 2011 the manufacture of baby
feeding bottles containing BPA in the EU will be outlawed, and from June 2011 the importation and sale
of such bottles will be prohibited (ChemSec, 2010).
In Sweden, the government recently approved the development and implementation of a national action
plan to reduce the presence of toxins in the environment (Swedish Gov, 2010). The Swedish Chemicals
14
18. Agency (KEMI) has been tasked with developing and implementing this plan whereby hazardous toxins
and chemicals are to be identified, restricted and phased out. Discussions between Jegrelius and KEMI
have confirmed that Bisphenol A in thermal paper is currently outside of the scope of this initiative but that
it could be considered for inclusion if a convincing argument is made.
5.7.2 The US Regulatory Environment and the EPA Assessment
Companies in the USA don’t have to report on the chemicals that they are using to the federal
government, to manufacturers that use their products, or to the public (Schreder, 2010). The Toxic
Substances Control Act (TSCA), which was passed in 1976, gives the Environmental Protection Agency
(EPA) very limited ability to require safety testing of chemicals before they’re used in commerce. Of
approximately 80,000 chemicals used in commerce since 1976 only a few hundred have been tested
while more than 62,000 were grandfathered without any requirement that they be tested or their safety
assessed (Schreder, 2010). Manufacturers introducing chemicals after TSCA’s passage must notify EPA
of the new chemical, but don’t have to test it for health and safety or ensure that the safest chemicals are
used.
Most human exposure to BPA comes from food packaging (Willhite etal, 2008). Food and food additives
are regulated by the US Food and Drug Administration (FDA) and are specifically excluded from the
definition of chemical substance under TSCA (EPA, 2010). In order to assess whether changes are
necessary to the TSCA the FDA is undertaking research on the affects of exposure to BPA on humans.
The FDA is also seeking to strengthen its oversight of BPA so the agency can respond quickly, if
necessary, when more scientific evidence becomes available.
In uses subject to FDA jurisdiction, public concern has led the industry to move towards non-BPA-based
materials in products such as baby bottles, cups, spoons and adult drink bottles, and to explore
alternatives in food can linings. Meanwhile, the U.S. Department of Health and Human Services (HHS)
has provided interim recommendations on how parents and families can reduce exposures to BPA while
additional studies are underway (EPA, 2010).
In March 2010, the EPA released a BPA Action Plan (EPA, 2010). In the launch statement, the agency
clearly indicated that it “does not intend to initiate regulatory action under TSCA at this time on the basis
of human health.” The rationale behind this approach is that the exposure to BPA from sources which sit
under the remit of the EPA are small compared to those sources under the remit of the FDA. The EPA is
working with the FDA to support further research in the area of BPA exposure.
The EPA is however considering two rulemaking actions on the basis of concern for potential risk to the
environment from BPA:
1. Adding BPA to new Toxic Substances Control Act (TSCA) 5(b)(4) Concern List
2. Consider TSCA 4(a) rulemaking to develop data on environmental presence and effects
The first assessment of the EPA’s bisphenol A action plan will focus on finding safer alternatives to BPA
used as a developer in thermal paper. The assessment, entitled “Alternatives to BPA in Thermal Paper
15
19. Partnership” started in July 2011 and is being led by the EPA’s Design for the Environment project (EPA,
2010). The goal is to facilitate a movement towards safer alternative developers in thermal paper.
The rationale behind looking at thermal paper is twofold. Firstly, the EPA believes that there are BPA
alternatives readily available which may have a better environmental profile than BPA. Secondly, they
point to the fact that thermal paper contains “free-BPA” (ie; it is not chemically bound) which can be easily
released from the paper onto skin when handled.
To implement its goal, a group of key stakeholders has been gathered to identify and develop information
on alternatives to BPA in thermal paper. Members of the project include representatives from a wide
range of stakeholders including manufacturers, convertors, chemical producers, retailers, green chemists,
NGOs and US government officials (see Appendix 3 for a full list of project members). Industry
involvement in the project is voluntary but to date includes representatives from the major global
manufacturers. Both Canada and the EU are represented on the project, with Paolo Castello from the
Joint Research Centre of the European Commission representing the EC.
The content of the assessment will include evaluating the hazards associated with BPA and the viable,
functional alternatives that act as developers for dyes in this application. Human health and
environmental profiles for each chemical will be based on a review of literature in the public domain,
structure-activity relationship modelling, and, in some cases, proprietary information shared by
stakeholders.
To date the working group have identified a list of seventeen chemicals, aside from BPA, which could be
used instead of BPA, of which thirteen are currently in use to form thermal paper in the U.S., Europe, and
Japan (see Appendix 4). The next milestone, due in April 2011, is to complete a draft evaluation of the
ecological and human health hazards and environmental fate of BPA and alternative developers. The
final report is due by December 2011.
5.8 Manufacturer/Supplier Interviews
In order to validate the findings from the market analysis and to identify suitable bisphenol-free papers,
contact was made with five major manufacturers of thermal paper, two convertors and one supplier:
Kanzan
Jujo
Mitsubishi
Koehler
Nashua
RollCo Nordic (Convertor)
Schades (Convertor)
Point (supplier)
It was intended that through meetings with these companies the project could gain input which would help
Länstrafiken to understand the potential alternatives, allow Jegrelius to undertake a risk assessment on
16
20. the alternatives and to formulate a set of specifications for an ultimate procurement of bisphenol-free
thermal paper.
5.8.1 Findings
In short, the companies contacted either did not respond to direct requests for information or refused to
give information via their convertors/country representatives. Positive meetings and exchanges of
information were achieved via three companies who have relationships with the above manufacturers.
These companies provided useful insight into the structure of the industry, the availability of bisphenol-
free paper and the manufacturers’ positions on BPA-free paper. The following is a summary of findings
from these meetings. The sources of individual comments have been kept confidential.
(i) Availability of Bisphenol-free Paper
Alternative chemicals have been available for many years and have replaced bisphenol in top-coated
papers which are designed for premium products such as lottery and flight tickets which have higher
performance demands. These higher priced products have thus been able to absorb the additional cost of
the alternate chemicals. Due to recent customer demands and increased regulatory investigation
manufacturers have invested significant time and money to develop lower cost non-top coated papers.
There is now a variety of products available on the market although they are typically double the price of
the bisphenol-free alternatives.
(ii) Identifying the Chemical Developers Used
Jujo, the Finnish manufacturer of the paper used by Länstrafiken today, have been unwilling to declare
the chemical developer used in this paper. Other manufacturers have given the same response. A
certificate and detailed specification sheet for Jujo’s paper is included in Appendix 1. The certificate states
that the paper meets all EU regulations regarding chemical contents. Schades also supplies this paper to
other Swedish clients including Skånetrafiken, Kalmar Länstrafik, Jönköpings Länstrafik, ICA, COOP,
H&M, Systembolaget and Ax Foods.
Without the details of the chemicals used it is very difficult to undertake a risk assessment of these
alternative papers. One option suggested is to test the papers using gas chromatography. Reviewing
patents was felt to be a dead-end as manufacturers often do not use the chemicals stated in the patent. It
is common knowledge that some manufacturers such as Appleton have moved to using bisphenol
sulfonate (BPS), a close chemical relative of BPA. BPS has not been studied nearly as extensively as
BPA but in-vitro studies indicate it may also disrupt hormones, with studies indicating it has some
estrogenic and anti-androgenic properties (Kuruto-Niwa etal, 2005). A recent report suggests that BPS is
also more resistant to breakdown in the environment than BPA (Danzl, 2009). It is too early to tell if the
other papers which do not rely on phenol chemistry are any better as their chemical constituents are
either unknown or have not been sufficiently risk assessed.
(iii) The Incentive for Manufacturer’s to Provide Alternatives
Price pressures in recent years have resulted in low profitability and a high investment in automation.
Manufacturers have a well-oiled machine in respect of their manufacturing and distribution supply chain
and are unwilling to disrupt this. Furthermore, changes in the paper can cause problems elsewhere in the
17
21. supply chain, for example printer compatibility, thus requiring significant testing which increases time and
cost.
It was agreed that client and regulatory pressure are two key levers to force the industry to act.
Regulation does not currently restrict the use of bisphenol in thermal paper. In respect of client demand,
there is currently only a very small demand from convertors for the bisphenol-free alternatives as most
customers still demand the lowest priced products. Manufacturers have therefore not made a significant
effort to market these papers for fear of cannibalizing their market share in what is a fiercely competitive
market.
The current client and product profile of the manufacturers will to a certain extent determine how quickly
they act in response to regulatory pressure/client pressure. Where manufacturers rely heavily on sales of
non-top coated paper they are more exposed to regulatory/client demands for bisphenol-free paper as
top-coated paper is already largely bisphenol-free. Overall it is expected that the market will take many
years to move away from bisphenol, especially in developing markets.
(iv) Client-Led Initiatives
There is a perception that clients in both Sweden and Finland are taking the bisphenol discussion
seriously. Meanwhile clients in Denmark, Norway and Germany are less interested in bisphenol-free
paper. Examples of major retail clients who have changed to bisphenol-free paper are Lidl of Germany
and a variety of Swedish clients including H&M, Ax Foods, COOP and Systembolaget. ICA of Sweden
has stated that they will give their stores the option to purchase bisphenol-free paper rolls however it will
not be mandated.
Following a request from its major clients, including H&M, COOP, Ax Foods and Systembolaget, Schades
recently organised a meeting attended by representatives from these companies in addition to
representatives from The Swedish Chemicals Inspectorate (KEMI) and Jujo Paper. During this meeting
the manufacturer of the developer was disclosed confidentially although the chemical constituents were
not. KEMI have stated that they cannot demand to know the developer used providing that the
manufacturer ensures compliance with EU regulations. KEMI are also not empowered to undertake a risk
assessment of the developer used in place of BPA.
ChemSec (The International Chemical Secretariat), based in Sweden, is bringing together their member
companies to discuss the issue with a view to creating a platform for knowledge and cooperation amongst
its members who include IKEA, B&Q (UK), Boots (UK) and REWE Group (Germany).
(v) Conclusion
It is possible for Länstrafiken to purchase an alternative to the current Jujo paper from Schades, Point
and RollCo Nordic, although the comparison can only be made on price terms. Even paper certified by
Nordic Swan contains BPA. Schades state that they have selected Jujo’s paper as it is the cheapest for
them to buy in of all the papers available on the market.
18
22. 6 The Outlook for Bisphenol-free Paper
In order to assess the outlook for the diffusion of bisphenol-free paper, an analysis of the relative
attractiveness of the product and the barriers to diffusion has been undertaken.
6.1 Product Attractiveness to Manufacturers
There are many factors to consider when evaluating the speed of diffusion for bisphenol-free thermal
paper. At the manufacturing level, these factors may include ease of fabrication, compatibility with other
components of a system, performance advantages, or the ability to earn a greater profit while at the same
time meeting current and future expected regulations. At the user level product performance, compatibility
with existing equipment and cost are the major considerations.
The decision by manufacturers to undertake an investment in diffusing an alternative product will be
determined by the attributes of the product to be diffused (Rogers, 2003). Furthermore, general risk
factors may also have an influence, such as the possibility that economic development may influence the
perceived economic risk that a potential adopter faces in the adoption of a technology.
The factors which determine the speed of diffusion of a new innovation were identified by Rogers as
relative advantage, compatibility, complexity, trialability and observability. These factors along with
general risk factors have been evaluated from the perspective of thermal paper manufacturers to
understand how motivated they may be to embark on such an investment:
‘+’ denotes that the factor is positive in the manufacturer’s eyes
‘-’ denotes that the factor is negative in the manufacturer’s eyes
Attributes Factors
Relative
Advantage
Allows companies to demonstrate their eco-credentials in the face of growing
criticism and regulation
The development of new patents can provide competitive advantage in a
fiercely competitive market
New market with high growth potential for new entrants
Possible to charge a premium to existing products
Most clients demand the lowest cost product
Regulations do not restrict BPA
Significant Investment has been made in the existing supply chain
A potential zero-sum gain for existing manufacturers unless higher margins or
greater market share can be achieved
Compatibility BPA-free alternatives already available on the market and demanded by a
growing number of clients
Existing knowledge regarding thermal printing is still relevant
Compatible with chemicals industry efforts to demonstrate eco- credentials in
the face of concerns over growing waste, emissions and pollution
Potential compatibility issue with printing equipment and inks
Complexity R&D expenditure needed
19
23. Testing will be required to ensure compatibility with the wide range of technical
applications of thermal paper
Trialability BPA-free papers can be trialed on those customers that demand them.
Observability Growing market for non-BPA thermal paper
Increased media and regulatory attention to the problems with BPA
Risk Uncertainty regarding market potential
Uncertainty regarding legislative developments
Admitting liability for current product failings could lead to future litigation
Cannibalisation of existing market
6.2 Barriers to Diffusion
Despite the availability and potential attractiveness to manufacturers of bisphenol-free paper, there are a
number of barriers which will slow the diffusion of these products.
The first major barrier, which is typical of any industry, is often referred to as path dependency (Arthur,
1989; David, 1985). Path dependence means that present decision-making is affected by previous events
or decisions (Puffert, 2003). The historical events or decisions amplify the initial advantages of an
innovation over time due to ‘learning by doing’ (Arrow, 1962) and ‘learning by using’ (Rosenberg, 1982),
and network externalities (Liebowitz and Margolis, 1995).
The feedback process from markets to technical improvements, creating increasing returns, tends to
create a ‘lock-in’ phenomenon. Technological change can go in multiple directions, but once change is
initiated in a particular direction, it becomes increasingly difficult to change its course (Roehrl and Riahi,
2000).
There are three major sources of path dependency in an established innovation system (Geels, 2004):
1. Rules and regimes (eg; government, regulatory) provide stability by guiding actors’
perceptions and actions.
2. Actors having various (and often vested) interests are embedded in interdependent networks
and mutual dependencies which contribute to stability.
3. There are ‘sunk investments’ (for infrastructure, production lines, skills, etc.) which are
difficult to abandon, there is technical interrelatedness (or compatibility standards) between
various components, and there are increasing returns to the actors with increased use of a
technology due to network externality, i.e. an increase in the number of users increases the
quality, availability and variety of a technology and related products.
In respect of Bisphenol-free paper, it is the manufacturers who need to make changes to their production
processes and invest in sales and marketing of these products. Manufacturers are likely to suffer from
path dependency due all three of the major sources identified above. Firstly, the current regulatory regime
20
24. tends to favour BPA as it has been significantly tested by regulatory bodies globally and no firm results
regarding damage to human health have been presented. The European Thermal Paper Association
(ETPA), of which the major manufacturers are members, has recently published a statement to this effect
making reference to the various research projects (Specialpapper, 2010). Each of the members of the
ETPA has published this statement on their websites.
Secondly, the members of the supply chain are embedded in interdependent networks. The paper
manufacturers are typically diversified companies who use a wide range of chemicals to manufacture
their products. The blend of these chemicals is a source of competitive advantage to these companies
placing a strong dependency on the chemical industry.
Finally, any end use technology needs to work with the paper inserted into the system. This necessitates
a close relationship between the paper manufacturers and the manufacturers of the end-use technology.
Changing any of the chemical components of the paper will necessitate a round of testing across all the
potential end use technologies, of which there are many.
It is reasonable to expect that current manufacturers will not cannibalise their existing markets unless a
clear customer demand exists which is more profitable over the long term and/or if regulations demand
so. Despite their denials on the risks of BPA, the manufacturers do seem to sense a move towards tighter
regulatory compliance for BPA and have responded by developing BPA-free products. How quickly these
products diffuse will also be determined by client demand and by the attractiveness of the market.
Currently, most clients are still demanding the cheapest option.
The main barriers which will slow the diffusion of bisphenol-free paper can be summarised as follows:
(1) Political, Institutional and Legislative
(2) Economic
(3) Technical
21
25. Factors
Determining
the Rate of
Innovation &
Diffusion
Current Barriers
Political,
Institutional and
Legislative
Lack of consensus on BPA lifecycle hazards
Lack of legislation prohibiting the use of BPA
Environmental pressures vary considerably according to the geographical
location of a firm's activity
The “grandfathering” of existing products
Existing supply chain relationships and technology
Economic Commitment to new investment by manufacturers
High barriers to entry for new players
A BPA replacement programme requires action by the whole supply chain
Lack of clear, attractive demand
Historic overcapacity and low profitability
Limited number of BPA-free vendors and lack of market push towards bisphenol
free paper.
Technical There are a large variety of thermal paper types for which the new chemical must
meet performance requirements
Testing required to ensure compatibility with printing devices, inks, etc.
7 Conclusions and Recommended Next Steps
The thermal paper manufacturing industry is an oligopoly characterized by overcapacity and poor
profitability. Bisphenol has been used in thermal paper since the 1960’s and continues to be widely used
in non-top coated papers due its low price and low product performance requirements.
Customers and regulators are increasingly aware of the potential risks of bisphenol which has resulted in
investment by the industry in the development of cheaper bisphenol-free alternatives. Non-BPA
alternatives are available on the market today and manufacturers are in a position to shift their production
and marketing over to non-BPA should it be required. This will however incur cost and risk. While an
attributes analysis shows that there are a number of factors in favour of bisphenol-free alternatives, there
is a concern by manufacturers that they will cannibalise their existing market and lose market share
leading to an overall reduction in profitability.
22
26. 23
In order to increase their marketing of these products, manufacturers need to be motivated through a
clear and attractive customer demand and/or legislation. Regulations in the EU and US do not currently
restrict the use of bisphenol in thermal paper although regulatory attention and testing is increasing.
Media attention to the risks of bisphenol has resulted in action from a number of large Swedish
companies including HM, COOP, Ax Foods and Systembolaget. ChemSec are also engaging their
members, which include IKEA, to increase awareness and share knowledge on potential alternatives.
Overall however, most clients are still demanding the cheaper BPA thermal papers which are typically
around half the price of bisphenol-free alternatives.
At present there is a gap in knowledge regarding the chemical developers used in bisphenol-free papers.
There is also a lack of reliable information regarding the risks and effects of these chemicals. It is
therefore difficult to ascertain whether BPA-free papers do in fact have an improved environment profile.
An example of a failure in this respect is the use of bisphenol S (BPS) in place of bisphenol A, where BPS
is now feared to be more environmentally damaging due to its persistence.
Three suppliers of BPA-free paper to the Swedish market have been identified as potential suppliers to
Länstrafiken. These companies collectively can provide access to the full range of BPA-free products.
The manufacturers will not however divulge which chemicals they use as it is a source of competitive
advantage. Sourcing a thermal paper which is not environmentally harmful cannot be achieved without
knowing its chemical contents. Regulators do not demand that manufacturers divulge the chemicals used,
only requiring that they declare compliance with regulations in the markets in which they are sold. Both
Länstrafiken and Jegrelius are too small by themselves to demand that manufacturers provide details of
their papers for risk assessment purposes.
In conclusion, making a recommendation to Länstrafiken at this time can only be done on price and
performance grounds (ie; which BPA-free paper/convertor is cheapest). In order to realise the objectives
of the project a clear and attractive customer group is required which collectively can engage in dialogue
with manufacturers. It is recommended as a next step that Jegrelius engage as part of a larger initiative,
for example with ChemSec, or indeed initiate a project whereby a larger buyers group can be assembled.
An example could be to bring together the other members of Svensk Kollektiv Trafik to initiate a
nationwide project.
27. 24
References
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Danzl, E., Sei, K., Soda, S., Ike, I. and Fujita, M., Biodegradation of Bisphenol A, Bisphenol F and Bisphenol S in
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Gregory, P. High-technology Applications of Organic Colorants; Plenum Press: New York, 1991.
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Rogers EM. 2003. Diffusion of innovations. 5th ed., New York: Free Press.
Rosenberg, N., 1976. Perspectives on Technology. Cambridge University Press, Cambridge.
Schreder,E., 2010. On the Money: BPA on Dollar Bills and Receipts. Washington Toxics Coalition.
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29. Appendix 1 – Certificate and Specification Sheet for the Paper Currently Used by Länstrafiken
26
30. Appendix 1 Continued – Certificate and Specification Sheet for the Paper Currently Used by Länstrafiken
27
31. 28
Appendix 2: Global Manufacturers of Thermal Paper
Company Contact Details Swedish
Office/Distributor
Enviro. Certificates Activities
Undertaken
Products BPA-Free
Available?
Co. Overview
Mitsubishi
HiTec
Paper
Europe
Mr. Kenneth Elfström
HiTec Media Sverige AB
Tel.: 0046-8960948
Mobile: +46 (70) 513 36 67
Email: kenneth.elfstroem@hit
ecmedia.se
Web: http://www.mitsubishi-
paper.com
Mr. Kenneth Elfström
HiTec Media Sverige AB
Södra Catalinagränd 27
183 68 Täby -
Stockholm
Sweden
ISO 14001
FSC
REACH Compliant
NORDIC SWAN
BRC Global
Standard -
Consumer Product
certified
ISO 9001
Supporter of the
TWO SIDES
campaign
Supporter of the
campaign FICTION
AND FACTS
E2E production
from pulp
production to
finished product
Patents
licensed and
R&D support
provided by
parent co
Mitsubishi
Paper Mills
Japan
Sell thermal
paper directly to
converters
Paper and labels
Giroform carbonless paper, Jetscript
digital imaging paper and
Thermoscript thermal paper.
Thermal paper is produced for the
following industries: Retail,
Entertainment, Transport, Gaming,
Banking, Medical
OEM approvals for most brands:
Confirm details with Thomas
Grammel
OEM Manager
Tel. +49 461 8695-314
thomas.gramme@mitsubishi-
paper.com
Yes Locations: Bielefeld +
Flensburg (Germany)
Production Capacity: 155,000
tonnes/year
683 employees
Turnover: 283 million EUR
Owner: Mitsubishi Paper
Holding (Europe): 81.6 %
Mitsubishi Corporation: 18.4
%.. The European Mitsubishi
Paper group belongs to
Mitsubishi Paper Mills, Tokyo
(MPM)
August
Koehler
Papierfabrik August Koehler
AG · Hauptstraße 2 · D-
77704 Oberkirch
Tel. +49 7802 81-0 ·
Fax +49 7802 81-4330
Email: info@koehlerpaper.co
m
Web:
www@koehlerpaper.com
Via Convertors/
Distributors
ISO 9001:2008
ISO 14000 : 2005.
Information Security
ISO 27001:2005
Occupational
Health and Safety
OHSAS
18001:2007.
Paper sourced from
FSC suppliers
E2E product
development,
manufacturing,
marketing and
sales
Own more than
100 patents
Supply papers
to converters in
80 countries
Fine Papers & Special Papers
Coloured Papers & Technical Papers
Thermal Papers
Carbonless Papers
Decor Papers
Full range of end-use direct thermal
labels, tags and tickets.
Approved by (at least) IBM, Epson,
Seiko, MWCR, Hengstler or Mettler-
Toledo
Yes 200 year old company
Turnover: 540 million euros
Sales of 429,000 tons of
paper
Independent company
Head office in Oberkirch and
the mills in Kehl and Greiz.
Planning US plant
Local offices in Europe
(various ex Sweden), US and
China
Jujo
Thermal Ltd
Purchase Dep’t: +358 (0)10
303 2418
Email: jujosales(at)jujotherma
l.com
Web:
http://www.jujothermal.com
Via Convertors/
Distributors
FSC
PEFC
NORDIC SWAN
ISEGA
ISO 9001:2008
ISO 14001:2004
OHSAS
18001:2007
E2E product
development,
manufacturing,
marketing and
sales
Sell thermal
paper directly to
converters
Manufacturer of direct thermal paper
and one-side-coated self-adhesive
labels.
Focus on durable thermal papers for
labels, tickets and POS use
Epson, IBM and SII approved thermal
paper
Yes Locations: Kauttua, Finland
230 employees
Turnover: TBC
Owned by Nippon Paper
Industries,
Ahlstrom and Mitsui & Co.
Appleton
Papers Inc
825 E Wisconsin Avenue
P.O. Box 359
Appleton, WI 54912-0359
Phone: 01-920-734-9841
Web:
http://www.appletonideas.co
m
Via Convertors/
Distributors
ISO 14001
FSC
E2E product
development,
manufacturing,
marketing and
sales
Sell thermal
paper directly to
converters
Manufacture carbonless, thermal,
security papers and Encapsys®
microencapsulated products
Full range of end-use direct thermal
labels, tags and tickets.
Wide range of OEM approvals:
http://www.appletonideas.com/Applet
on/en_US/01/pdf/PrinterApplications
GuideandApprovedPapers.pdf
BPS N.Americas largest producer
of thermal paper
Plants in Wisconsin, Ohio and
Pennsylvania,
Employs 2,000 people
100 percent employee owned.
Sells carbonless and thermal
products into more than 70
countries
European distribution centers
in St. Helens, England, and
Utrecht, Netherlands.
32. 29
Company Contact Details Swedish
Office/Distributor
Enviro. Certificates Activities
Undertaken
Products BPA Free? Co. Overview
Kanzan KANZAN Spezialpapiere
GmbH
Nippesstrasse 5
52349 Dueren
Germany
Tel.: +49 2421 5924-0
Fax: +49 2421 5924-19
Email: sales@kanzan.de
Web: http://en.kanzan.de
Bertil Ranerson
BRC Ranerson
Consulting
Moendalsvägen 3
41263 Gothenburg
031 408825
br@brc.as
ISO 9001
certified according
to FSC-Chain of
Custody
DIN EN 71.3 norm
E2E product
development,
manufacturing,
marketing and
sales
Sell thermal
paper directly to
converters
Manufacturer of thermal papers and
other special products, particularly
inkjet papers.
Four main groups of thermal papers:
KL - Topcoated, KP - Non-
Topcoated, PL - Plotter and KF -
POS/Receipts
Full range of end-use direct thermal
labels, tags and tickets.
Wide range of OEM compatibilities.
Yes 315 employees
Turnover > 100 million Euro.
95% owned by Oji Paper Co.,
Ltd. which has 20,000
employees achieves an
annual turnover of about
8,000 million Euro
Production at Neumuehl mill
in Dueren
Ricoh Ricoh Industrie France SAS
(RIF)
144,route de Rouffach,F-
68920 WETTOLSHEIM
COLMAR,France
TEL:+33-389-20-4175
FAX:+33-389-20-4040
Email: virginie_ernst@ricoh-
industrie.fr
Web:
http://www.ricoh.com/thermal
Various Swedish offices
dealing with IT and
office solutions. Head
office:
Sverige
Ricoh Sverige AB
Röntgenvägen 3
P.O. Box 1536
171 29 Solna
Sweden
Tel.: +46 (0)8 734 33 00
Fax: +46 (0)8 734 33 1
ISO 90001/2
ISO 14001
ISO 27001:2005-
Information Security
Management
System (ISMS)
Thermal paper
manufacturing.
Manufacturer of thermal papers and
other special products including
rewriteable thermal products
Full range of end-use direct thermal
labels, tags and tickets
Range of OEM approvals. Contact
Ricoh for details.
TBC Total Co. Turnover: 2,016.3
billion yen (Year ended March
31, 2010)
Total employees: 108,525
Thermal Paper Production
Plants in Japan, USA, France
and China
Nashua Park Ridge Office
250 S. Northwest Highway
Suite 203
Park Ridge, IL 60068
Phone +1 (800) 323-4265
Web: http://www.nashua.com
tkelley@nashua.com
Via Convertors/
Distributors
TBC Paper convertor
and developer
of thermal
paper products
Full range of end-use direct thermal
labels, tags and tickets.
Sell IBM thermal POS paper
TBC Owned by CENVEO, INC.
since 2009
7 manufacturing locations in
the US.
Parent company (Cenveo)
has 8000 employees and a
turnover of US 2bn.
NCR 3097 Satellite Boulevard
Duluth, Ga. 30096-5810
USA
+1-937-445-1936
Web: www.ncr.com
Point Transaction Systems
AB
Ljusslingan 4
120 06 Stockholm
Sweden
Phone: +46 8 566 287 00
Fax: +46 8 641 7670
www.point.se
ISO 9002
ISO 14000
Paper convertor
and developer
of thermal
paper products
Developer of thermal paper solutions
Full range of end-use direct thermal
labels, tags and tickets
OEM compatibility dependent on
paper – details available on website
Yes The original manufacturer of
direct thermal paper
Turnover: USD4.6 billion
Employees: 21,500
33. 30
Appendix 3: Convertors/Suppliers of Bisphenol-free Thermal Paper for the Swedish Market
Company Contact Details Products BPA Free? Co. Overview
Schades A/S
(Current Supplier to
Länstrafiken)
Måns Palmqvist, Sales Manager
Sweden and Finland
Muskötgatan 11
254 66 HELSINGBORG
Phone +46 4226 3653
mp@schades.com
www.schades.com
Small paper rolls and
self adhesive labels for
retail, financial
institutions, lotteries,
gaming and
entertainment,
ticketing, stationary,
food and logistics
Their products meet all
OEM standards
including NCR, ICL,
ADS, IBM, Omron and
Epson.
Jujo’s bisphenol
free paper
supplied to LT
today
Manufacturing plants in
Germany, France, the
UK and Denmark.
Employees: 200
Turnover: 82 million
Euros (2008)
Produce: 100
million POS rolls and 6
billion labels every year
Owner: Capidea
Managment ApS,
Denmark
Rollco Nordic AB Ellenbergavägen 13
266 32 Munka-ljungby
Martin Walfriedsson, vd
Phone: 042-298020
info@rollconordic.se
Small paper rolls cash
registers, ticketing,
payment terminals and
ATM machines
Distribute Nordic Swan
marked rolls
Can provide
bisphenol free
paper from any of
the five global
manufacturers
7 employees
Turnover 20m SEK
Point Transaction
Systems AB
Ljusslingan 4
120 06 Stockholm
Sweden
Bo Danielsson
Phone: +46 8 566 287 00
Fax: +46 8 641 7670
www.point.se
Electronic payment
systems and
peripherals
They can provide
BPA free rolls
Point is the leading
provider of electronic
payment solutions in
Europe focusing on
payment services to
merchants.
Point is present in 10
European countries.
250,000 customers
480,000 payment
installations
turnover of €
150 Million
34. Appendix 4: Members of the EPA’s Alternatives to BPA in Thermal Paper Partnership
31
Thermal Paper Manufacturers
Pam Barker, Appleton Papers, Inc.
Mike Friese, Appleton Papers, Inc.
Pete Popovics, Cenveo/Nashua
Jouko Mäkitalo, Jujo Thermal
Mari Koskinen, Jujo Thermal
Fred Paris, Kanzaki
Michael Horn, Koehler Paper
Dirk Keller, Koehler Paper
Bernd Gerecht, Mitsubishi
Takahisa Kato, Mitsubish
Theodore Rice, Mitsubishii
Gary Toussaint, Nashua Corporation
Trevor Kelley, Nashua
Todd Ostrowski, Tighe& Bond
Thermal Paper Converters
Doug Dahrsnin, LabelWorld
Dave Starr, Heartland Label Printers
Andrew Dennison, Heartland Label Printers
Dave Blum, Heartland Label Printers
Jim Check, Heartland Label Printers, Inc.
Mike Rapier, Liberty Paper Products, LLC
Jerry Butler, NCR
Bram van Staalduinen, NCR
Debora Jeske, NCR
Steve Nahm, NCR
Terie Syme, Prestige Label Co.
Stacey MacNeil, UPM Raflatac
Steven Schwartz, RiteMade Paper
Chemical Manufacturers
(Developers and Color-formers)
Steve Aderman, AdChem Technologies
Al Wiedow, BASF
Omi Kapel, BASF
Frank Kearney, ESCO
Robin Heath, Nagase America Corporation
John Wrubel, Nisso America
Toshiyuki Iwama, Nisso America
Tadashi Kawakami, Nisso America
POS OEM Manufacturers
Ron Mateas, Epson
Sal Rizvi, Star Micronics America, Inc
Retailers
Drew Du Bois, Kroger
Jeff Brown, Safeway
Roger McFadden, Staples
Holly Wipf, Target
Zach Freeze, Wal-Mart
Jason Wadsworth, Wegmans
Joe Dickson, Whole Foods
International
Paolo Castello, EC Joint Research Centre
Kate McKerlie, Environment Canada
Green Chemistry Consultants
John Warner, Warner Babcock Institute
Sarah Newsky, Warner Babcock Institute
Manfred Krautter, EcoAid
Trade Associations
Steven Hentges, American Chemistry Council
Erik Lieberman, Food Marketing Institute
John Billings, Food Marketing Institute
David Wagger, ISRI
Sarah Walczewski, Retailer Industry Leaders Association
Trade Unions
Jackie Nowell, UFCW
NGOs
Mark Rossi, Clean Production Action
Michelle Harvey, EDF
Sonya Lunder, EWG
David Andrews, EWG
Sarah Janssen, NRDC
Darby Hoover, NRDC
Brian Penttila, Pacific NW Pollution Prevention Resource Center
Pam Eliason, Toxics Use Reduction Institute
Erica Schreder, WA Toxics Coalition
Government
John Bucher, NIEHS
Kris Thayer, NIEHS
Cherie Estill, NIOSH
Steve Schrader, NIOSH
Mike Babich, CPSC
Vanee Komolprasert, FDA
Gary Ginsberg, Connecticut DPH
Terry Goldberg, NEWMOA
Technical Consultant
Lauren Heine, Clean Production Action
Thermal Paper Manufacturers
Pam Barker, Appleton Papers, Inc.
Mike Friese, Appleton Papers, Inc.
Pete Popovics, Cenveo/Nashua
Jouko Mäkitalo, Jujo Thermal
Mari Koskinen, Jujo Thermal
Fred Paris, Kanzaki
Michael Horn, Koehler Paper
Dirk Keller, Koehler Paper
Bernd Gerecht, Mitsubishi
Takahisa Kato, Mitsubish
Theodore Rice, Mitsubishii
Gary Toussaint, Nashua Corporation
Trevor Kelley, Nashua
Todd Ostrowski, Tighe& Bond
Thermal Paper Converters
Doug Dahrsnin, LabelWorld
Dave Starr, Heartland Label Printers
Andrew Dennison, Heartland Label Printers
Dave Blum, Heartland Label Printers
Jim Check, Heartland Label Printers, Inc.
Mike Rapier, Liberty Paper Products, LLC
Jerry Butler, NCR
Bram van Staalduinen, NCR
Debora Jeske, NCR
Steve Nahm, NCR
Terie Syme, Prestige Label Co.
Stacey MacNeil, UPM Raflatac
Steven Schwartz, RiteMade Paper
Chemical Manufacturers
(Developers and Color-formers)
Steve Aderman, AdChem Technologies
Al Wiedow, BASF
Omi Kapel, BASF
Frank Kearney, ESCO
Robin Heath, Nagase America Corporation
John Wrubel, Nisso America
Toshiyuki Iwama, Nisso America
Tadashi Kawakami, Nisso America
POS OEM Manufacturers
Ron Mateas, Epson
Sal Rizvi, Star Micronics America, Inc
Retailers
Drew Du Bois, Kroger
Jeff Brown, Safeway
Roger McFadden, Staples
Holly Wipf, Target
Zach Freeze, Wal-Mart
Jason Wadsworth, Wegmans
Joe Dickson, Whole Foods
International
Paolo Castello, EC Joint Research Centre
Kate McKerlie, Environment Canada
Green Chemistry Consultants
John Warner, Warner Babcock Institute
Sarah Newsky, Warner Babcock Institute
Manfred Krautter, EcoAid
Trade Associations
Steven Hentges, American Chemistry Council
Erik Lieberman, Food Marketing Institute
John Billings, Food Marketing Institute
David Wagger, ISRI
Sarah Walczewski, Retailer Industry Leaders Association
Trade Unions
Jackie Nowell, UFCW
NGOs
Mark Rossi, Clean Production Action
Michelle Harvey, EDF
Sonya Lunder, EWG
David Andrews, EWG
Sarah Janssen, NRDC
Darby Hoover, NRDC
Brian Penttila, Pacific NW Pollution Prevention Resource Center
Pam Eliason, Toxics Use Reduction Institute
Erica Schreder, WA Toxics Coalition
Government
John Bucher, NIEHS
Kris Thayer, NIEHS
Cherie Estill, NIOSH
Steve Schrader, NIOSH
Mike Babich, CPSC
Vanee Komolprasert, FDA
Gary Ginsberg, Connecticut DPH
Terry Goldberg, NEWMOA
Technical Consultant
Lauren Heine, Clean Production Action
35. Appendix 5: List of Known or Expected Functional BPA Alternatives for Use in Thermal Paper
32
36. Appendix 5 (Continued): List of Known or Expected Functional BPA Alternatives for Use in Thermal Paper
33
38. 35
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