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Product-Specific Labeling Guidelines

In order to assist manufacturer's of mercury-added products with the development of product labels which meet the intent of Vermont's labeling law, the Department of Environmental Conservation has established the following product-specific labeling guidelines:

Fever Thermometers

Guideline #GL-101

An established labeling guideline has been accepted by the Vermont Agency of Natural Resources regarding labeling for fever thermometers.

As a class, it is not feasible to directly label a fever thermometer on the product surface due to product size.

Therefore, fever thermometers, as a class, may be labeled on the product packaging without further approval as an alternative.

Large Appliances

Guideline #GL-102

An established labeling guideline has been accepted by the Vermont Agency of Natural Resources regarding labeling of large appliances guidelines.

According to the Vermont labeling rule, products which contain internal "switches" must not only have the switch labeled, but the outside of the larger product must also be labeled. In this case, it would be necessary to have a label on the outside of the appliance as well as on the internal switch.

Other circumstances have been brought to our attention which also pertain to the appliance industry.

Some appliances contain internal devices which contain mercury and are not "switches." Under the law and rule, the larger product does not require a label. However, the rule also includes a reference that a label must be "visible prior to purchase." Because of this requirement, it was necessary for the Agency to make an interpretation to determine what would be "visible" to the consumer prior to purchase.

Because large appliances are purchased primarily based on the inspection of a similar model in a showroom, the Agency has determined that in order to comply with the "visibility" requirement of the rule, it is necessary for the manufacturer of the large appliance to place a label on the outside of the appliance in addition to the label that must be affixed to the mercury-containing device within the appliance.

Light Fixtures

Labeling guidelines have been approved by the Vermont Agency of Natural Resources regarding the labeling of light fixtures, which includes table lamps and overhead lighting fixtures.

According to the Vermont mercury-added product labeling law and rule, fluorescent and other mercury-added lamps (bulbs) require labeling. These lamps may be incorporated into lighting fixtures when sold for use in Vermont.

Guideline #GL-103

If the lighting fixture sold for use in Vermont is packaged, and mercury-added lamps are within the packaging, the package may be labeled in addition to the lamps to fulfill the visibility requirements for the mercury-added product labeling law regardless of how the product is sold.

Guideline #GL-105

Based on an agreement negotiated with National Electrical Manufacturer's Association (NEMA), the following guideline has been established regarding luminaires as defined below.

If the product is a luminaire* (other than linear fluorescent luminaires) the following labeling method has been accepted by the Vermont Agency of Natural Resources as a method to achieve full compliance by manufacturers of these products with the Vermont mercury-added product labeling law:

Insert a notice on a page in the front section of its catalogs and on its website as follows:

For further information on local, state or other requirements for disposal of
mercury-containing lamps, see www.lamprecycle.org.

This notice shall be introduced in connection with the next printing of the luminaire manufacturer's catalog over the next three years beginning November 14, 2003.

*Luminaire - A complete lighting unit consisting of a lamp or lamps together with the parts designed to distribute the light, to position and protect the lamps and ballast (where applicable), and to connect the lamps to the power supply.

Important Notes:

  1. If a fixture that is sold for use in the state of Vermont is packaged without the lamps installed either in the fixture or included within the fixture package, the product is not considered a mercury-added product and does not have requirements under Vermont's labeling law.
  2. Other states, such as Connecticut, have more stringent labeling requirements for this type of product, which may include some of the requirements of Vermont as well as additional requirements that are specific to that state.

Automobile Replacement Parts

Guideline #GL-104

An established labeling guideline has been accepted by the Vermont Agency of Natural Resources regarding labeling of automobile replacement parts.

Automobile replacement parts include any mercury-added products - or - products which contain mercury-added components, which are to be used exclusively as replacement parts in vehicles propelled by internal combustion engines or electric motors such as automobiles, vans, trucks, motorized construction equipment, motorized recreational vehicles, motorcycles, forklifts, etc.

Automobile replacement parts do not include mercury-added replacement parts in the coach (living) portion of a motorized recreational vehicle.

The automobile industry currently has an alternative labeling approved for vehicles which allows a single door-post label to be affixed to the vehicle and no internal original equipment mercury-added parts are required to be labeled. According to our information, original equipment mercury-added parts are manufactured to standards which provide for these parts to last the life of the vehicle without replacement. We do not believe it reasonable to require labeling of the replacement parts under these circumstances.


No label is required on the product or package of automobile replacement parts.


Mercury Education & Reduction Campaign    103 South Main Street    Waterbury, VT 05671    802-241-3455
MERC is a program of the Vermont Department of Environmental Conservation

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