Certified Labeling Plans

Vermont Mercury-Added Product Labeling Law requires that:

"each manufacturer certify that it has developed a labeling plan for its mercury-added products that complies with the labeling law . . . The labeling plan shall include detailed descriptions of the products involved and the label size, material, content, location, and attachment method for each product and for the product packaging, where necessary under the rules, so a label is clearly visible at time of purchase."

Note: If a manufacturer cannot comply with standard labeling requirements they must submit an alternative labeling request prior to submitting the Certified Labeling Plan.

Vermont is the only state, thus far, that requires the submission of a Certified Labeling Plan. Other states in the region, however, have labeling requirements and will utilize Vermont's database labeling information to determine if a manufacturer is in compliance for labeling in their specific state. Manufacturers may be referred to other states if we have knowledge of variations in labeling laws. Overall, the Northeast regional state's mercury-added labeling requirements are very similar. According to the Interstate Mercury Education and Reduction Clearinghouse (IMERC) "A labeling plan approved in Vermont probably will meet the labeling requirements in other Northeast states."

How to file a Certified Labeling Plan?

1. Download the Certified Labeling Plan form off the website - this is a legal sized paper form (8 ½" x 14") - to print this form on standard sized paper (8 ½" x 11") some adjustments may have to be made prior to printing. (If you have difficulties printing this form, please contact Karen Knaebel for assistance.)
2. Complete the form, making certain that the submitted form has an original signature.
3. Make certain that products are listed with adequate detail.
   • The product in the TYPE OF PRODUCT column should be the product of the manufacturer submitting the form- whether it is a component or the larger product. You can provide this information by product category, series or family of products, provided all labeling is identical as to label size, attachment location and wording.
   • The PR column is an indicator of what the component part is, such as switch, lamp, etc. indicated by abbreviation listed at the bottom of the form.
   • The PRODUCT IDENTIFIER column is an identification of how the manufacturer identifies its products - model names, model numbers - series numbers (e.g. MBPXXXX)
   • If one product has more than one mercury-added component, simply drop down in the "PR" column and list one under the other.
   • If one product has more than one label location, information can be dropped down in each of the "Label Size & Material," "Location & Attachment Method," and "Content (wording) & Font Size" columns. For example a single product may have 1) product label, 2) package label, 3) information in sales literature and 4) information on the web site. Each of these four labeling locations can be conveyed in the labeling plan by placing numbers in each of the columns and dropping down in the column to list the appropriate information.
   • In the ALT#/ GL # column - If you are using standard labeling, this column does not require a number. If you are using one of the guidelines or alternatives that have been assigned for product categories, indicate the appropriate number. (i.e. #0216, #103, etc.) If you have applied for alternative labeling on an individual product and have been assigned an alternative number, indicate the number assigned in this column.
4. Once the form is completed, mail the form with an original signature to the address indicated on the form.