What Is AB 1604?
AB 1604 was introduced in January 2026 by Assemblymember Catherine Stefani (D–San Francisco) and has moved through the legislature with unanimous bipartisan support. It adds Chapter 12.3 to Part 3 of Division 104 of California's Health and Safety Code.
The law covers paper proofs of purchase—receipts issued at the point of sale for the retail sale of food, alcohol, tangible goods, or services. It applies to any business that accepts payment through cash, credit, or debit transactions. Healthcare providers are specifically exempted.
The bill's key finding, written directly into the legislative text: retail workers who handle receipts daily have 30% higher levels of BPA or BPS in their bodies compared to people without regular receipt contact, according to data from the Environmental Working Group and the CDC.
If you want to read the full bill text, it's available on the California Legislative Information site.
The Two Deadlines You Need to Know
Deadline 1: January 1, 2027 — BPA Banned
After this date, your business cannot provide a paper receipt that contains intentionally added bisphenol A (BPA). This applies to both the business providing the receipt and the manufacturer producing the paper.
Most businesses shifted away from BPA-coated thermal paper years ago—but not necessarily toward safe alternatives. The paper industry largely replaced BPA with bisphenol S (BPS), which is why a receipt labeled "BPA-Free" can still be illegal under the 2028 deadline.
Deadline 2: January 1, 2028 — All Bisphenols Banned
This is the bigger change. After January 1, 2028, no paper receipt in California may contain any intentionally added bisphenol—including BPS, BPF, BPAF, tetrabromobisphenol A, or any other chemical in the bisphenol class.
The law defines "bisphenol" as any chemical with two phenol rings connected by a single linker atom. The only compliant receipt paper after 2028 is phenol-free thermal paper—paper that uses an entirely different chemistry to produce print.
Who Enforces This Law, and What Are the Penalties?
AB 1604 is enforced by the California Department of Toxic Substances Control (DTSC). Enforcement authority also extends to the Attorney General, county counsels, district attorneys, and city attorneys.
Penalties are civil, not criminal:
- First violation: up to $5,000
- Each subsequent violation: up to $10,000
- Prevailing plaintiffs are entitled to attorneys' fees and costs
Those numbers may seem manageable for a large retailer—but for an independent café, restaurant, or small shop, a string of violations adds up fast.
There's an additional wrinkle. The bill requires manufacturers to use the least toxic alternative when replacing bisphenols. This isn't just about swapping one chemical for another—the replacement has to be genuinely safer.
California Already Has a Receipt Problem: Proposition 65
AB 1604 is coming, but California's receipt paper enforcement is already happening right now—under Proposition 65.
BPS was added to California's Prop 65 list of reproductive toxicants in December 2023, with enforcement beginning January 1, 2025. Since then:
- Over 325 Prop 65 Notices of Violation (NOVs) targeting BPS in thermal receipts were filed in the first half of 2025 alone
- More than 200 companies have been targeted, including Albertsons, Ralphs, Walgreens, Circle K, and hundreds of smaller businesses
- Prop 65 civil penalties can reach $2,500 per violation per day—and because no safe harbor level has been established for BPS, even trace amounts trigger the requirement
- Enforcers have argued that each receipt issued to a customer is a separate violation
This isn't a future problem. California businesses are being sued right now over the paper in their receipt rolls. AB 1604 represents the permanent legislative fix—but getting compliant with phenol-free paper protects you from both AB 1604 and ongoing Prop 65 enforcement in one move.
For more on what the underlying research shows about bisphenols and reproductive health — the basis for Prop 65's listing — see our article on BPA, BPS, and fertility.
Why "BPA-Free" Paper Is Not Enough
The single most important thing to understand before buying new receipt paper: BPA-Free does not mean bisphenol-free.
When BPA was first identified as harmful, thermal paper manufacturers swapped it out for BPS—another bisphenol with similar chemistry. A 2022 Ecology Center report found that BPA-based receipts had been "almost entirely" replaced by BPS in the US market. BPS was labeled as a BPA alternative and marketed as safer. It isn't.
BPS is now on California's Prop 65 list as a reproductive toxicant. It's covered by AB 1604's 2028 deadline. And testing shows that BPS transfers to skin on contact just like BPA does.
If your current supplier sells you "BPA-Free" paper, ask them directly whether their paper is phenol-free—meaning it contains no bisphenols of any kind. If they can't confirm that in writing, assume it contains BPS.
For more detail on the science behind both chemicals, see our article on the science of bisphenols.
How to Get Compliant: A Step-by-Step Checklist
Step 1: Find Out What's In Your Current Receipt Paper
Call or email your paper supplier and ask two questions:
- Does this paper contain BPA?
- Does this paper contain any bisphenols, including BPS?
Ask for written confirmation—a spec sheet or safety data sheet (SDS) that identifies the color developer chemistry used. If the supplier can't answer question 2, treat the paper as non-compliant for 2028.
Step 2: Identify Phenol-Free Alternatives
Look specifically for paper marketed as phenol-free or non-phenol thermal paper. This category uses alternative color developers—common ones include Vitamin C (ascorbic acid)-based chemistry—that contain no bisphenols.
Major paper distributors now carry phenol-free options. When sourcing:
- Confirm the paper is compatible with your POS printer model (most standard 80mm and 58mm thermal printers work fine with phenol-free rolls)
- Check roll dimensions match your current paper (width, core size, roll diameter)
- Order a sample roll first to confirm print quality before switching your whole supply
Our resources page lists phenol-free paper suppliers and can help you find the right product for your printer.
Step 3: Update Your Supply Chain
Once you've identified a compliant supplier, document the change:
- Keep a copy of the product spec sheet confirming phenol-free status
- Note the transition date in your compliance records
- If you have multiple locations, ensure all locations switch—not just your flagship store
For multi-location businesses and franchises, this is a supply chain coordination issue. Start conversations with your paper distributor now, before January 2027 creates a demand surge.
Step 4: Consider Going Digital
The most complete compliance solution is eliminating paper receipts entirely. California already has existing infrastructure supporting digital receipts:
- Email receipts
- SMS receipts
- QR code receipts linked to a purchase record
- App-based receipts for loyalty program members
If your POS system already supports email receipts, this option has zero ongoing paper cost and eliminates the compliance issue permanently. Some customers still prefer paper—you can offer both.
Step 5: If You Can't Switch Immediately, Post Prop 65 Warnings
While you're transitioning, if you're still issuing BPS-containing receipts in California, you need to comply with Prop 65 right now. That means posting a clear and reasonable warning at the point of sale. The required language:
WARNING: This product can expose you to Bisphenol S (BPS), which is known to the State of California to cause birth defects or other reproductive harm. For more information go to www.P65Warnings.ca.gov.
Post this warning visibly at checkout—on the register, at the counter, or on a placard at the point of sale. This is your protection against Prop 65 enforcement actions while you complete the transition to phenol-free paper.
How AB 1604 Compares to Washington State's Ban
California's law follows the path set by Washington State, which banned all intentionally added bisphenols in thermal paper effective January 1, 2026. If you're already compliant in Washington, you're in good shape for California's 2028 deadline.
The key differences:
| Washington State | California AB 1604 | |
|---|---|---|
| BPA ban effective | January 1, 2026 | January 1, 2027 |
| All bisphenols ban | January 1, 2026 | January 1, 2028 |
| Enforcement agency | Ecology Department | DTSC + AG + local prosecutors |
| Penalties | Up to $5,000/day | $5,000 first / $10,000 subsequent |
Washington's ban also preceded a wave of similar state-level activity. Connecticut banned BPA in receipts in 2011. Illinois followed in 2019. The EU restricted BPA in thermal paper in 2020. California's law, covering the most populous US state, represents a significant acceleration of this national and global trend.
For the full detail on Washington's requirements, see our Washington State receipt paper ban compliance guide.
What About Healthcare Providers?
AB 1604 explicitly exempts healthcare providers as defined in California Health and Safety Code Section 123105. If you're a medical office, clinic, hospital, or other healthcare entity, the law does not apply to your patient receipts and transaction records.
That said, Prop 65 enforcement is not limited by the same exemption. Healthcare businesses that issue thermal receipts to patients are still potentially subject to Prop 65 warning requirements for BPS exposure.
The Worker Protection Angle
Most of the public conversation around AB 1604 focuses on consumer exposure—a customer touching one receipt at checkout. But the health case for this law is really about workers.
A customer touches a receipt for a few seconds. A cashier handles dozens to hundreds of receipts every shift, every working day, for years. The CDC and Environmental Working Group data cited in the bill's findings shows that retail workers carry 30% higher bisphenol body burden than the general population.
Research on the hand sanitizer effect adds another dimension: using hand sanitizer before handling receipts can increase the amount of BPA absorbed through the skin by up to 100 times, according to a study published in PLOS ONE. Workers who sanitize frequently—as became standard during and after the COVID-19 period—face higher exposure than those who don't. For the full exposure numbers and how they compare across professions, see our article on how much bisphenol exposure is too much.
If you have employees who handle receipts all day, switching to phenol-free paper isn't just a compliance issue—it's a workplace health decision. In the meantime, our cashier safety guide covers practical protective steps employees can take.
Frequently Asked Questions
Does AB 1604 apply to my business if I only give receipts to commercial clients, not consumers? The law covers receipts provided at the point of sale for the retail sale of goods and services. B2B-only businesses that don't issue retail point-of-sale receipts may be outside the scope, but consult legal counsel if this is ambiguous for your situation.
What if my supplier says their paper is "BPA-Free"? Ask specifically whether it's phenol-free. BPA-Free often means the BPA has been replaced with BPS or another bisphenol—which is still non-compliant under the 2028 deadline and currently triggers Prop 65 warning requirements.
Can I use thermal labels and stickers with bisphenols? The law covers paper proofs of purchase (receipts). Thermal labels and stickers are not explicitly within AB 1604's scope—but they have been targeted separately under Prop 65. If your business uses thermal labels on packaging or product sold in California, consult your compliance counsel.
What if AB 1604 doesn't pass before the deadline? As of this writing, AB 1604 has passed two Assembly committees unanimously and is moving through the legislature. However, even if the bill were delayed or amended, Prop 65 enforcement on BPS in receipts is already active and ongoing. Switching to phenol-free paper remains the practical protection regardless of the bill's final timeline.
I run multiple locations across different states. What do I need? Washington State's ban (all bisphenols, effective January 2026) and California's AB 1604 (BPA by 2027, all bisphenols by 2028) create the most demanding requirements currently in place in the US. Phenol-free paper satisfies both. For businesses operating nationally, switching your entire supply chain to phenol-free paper eliminates multi-state compliance complexity.
The Bottom Line
California's AB 1604 is moving fast and has broad political support. By the time most businesses notice it, the 2027 deadline will be close. The businesses that act now—switching to phenol-free paper before the deadline—avoid the compliance scramble, eliminate ongoing Prop 65 enforcement risk, and protect their employees from a preventable source of chemical exposure.
What you need to do:
- Find out what chemistry your current receipt paper uses
- Source phenol-free thermal paper compatible with your POS equipment
- Document the switch with supplier spec sheets
- Train your purchasing team so the compliant paper stays in your supply chain
Visit our resources page for phenol-free paper options and links to suppliers. If your business is also navigating Washington State's already-in-effect ban, our Washington State compliance guide covers that state's specific requirements in detail.
The transition is straightforward. The alternative—waiting for enforcement to find you—is not.