REGULATORY SPOTLIGHT

California’s Proposition 65 and the Future of Direct Thermal Media

Understanding Proposition 65

Proposition 65, officially known as the Safe Drinking Water and Toxic Enforcement Act of 1986, aims to warn California residents of possible exposure to chemicals with the potential to cause cancer, birth defects or other reproductive harm. On December 29, 2023, Bisphenol S was added to the list of regulated chemicals. Businesses operating in California, or providing products to California consumers, must provide “clear and reasonable” warnings on products that may cause significant exposure to BPS. The full Proposition 65 List of Carcinogens or Reproductive Toxicants, as of January 3, 2025, can be found here:

CA OEHHA Chemicals List

Minimizing Risk

The California Office of Environmental Health Hazard Assessment (OEHHA) clarifies that a Proposition 65 warning does not imply that a product violates safety standards or requirements. These warnings are aimed at helping consumers evaluate potential risks and purchasing decisions. Proposition 65 requirements extend beyond California’s borders. Any product sold to California consumers must adhere to these regulations, regardless of where the business operates.

Direct thermal suppliers and converters must consider steps to meet regulatory requirements over time and to address consumer safety concerns as similar regulations related to BPS emerge in other states, including Washington, and across the European Union.

Ricoh Electronics offers an expanding range of BPS-free and completely phenol-free direct thermal products. All REI DT products are BPA-free and contain no added PFAS. To address the growing concerns around BPS, Ricoh Electronics is working to eliminate phenol from all formulations as quickly as possible, while maintaining the product quality customers rely upon.

Ricoh Electronics has added the necessary warning labels to direct thermal products containing BPS. Proposition 65 warning placement can be found in the Roll Label Guide. However, end-use products developed with this label stock may require additional labeling provided by converters and/or their customers. It is essential for customers and converters to take immediate action to understand individual obligations under these regulations.

Roll Label Guide

Legal Notice

We strongly encourage all customers to take necessary action to understand any additional compliance obligations that may be required under this regulation. Ricoh Electronics is committed to selling products that adhere to regulatory requirements and, therefore, is working to ensure compliance with Proposition 65; however, this regulation may have obligations that our customers may have to follow, which are separate from actions taken by Ricoh Electronics. Ricoh Electronics, Inc. will not indemnify or defend against liability for Proposition 65 non-conformance.

Additional Resources

For more information about California Proposition 65, visit the OEHHA Proposition 65 website, linked below. Stay up to date on the latest updates and measures taken by Ricoh Electronics our Regulatory Compliance Resource Center webpage.

Ricoh Regulatory Compliance Resources

California OEHHA Proposition 65