Standard Labeling Requirements

A manufacturer may not sell for use in the state of Vermont, any mercury-added products listed in the law unless they are labeled. Each manufacturer that is required to label must submit a Certified Labeling Plan.

If you manufacture one of the following products, individual guidance has been established for these specific product categories (all other products-refer to standard labeling guidelines below). In most cases, the specific products listed below would also need to fulfill the "visibility" requirements under Vermont Law along with the guidance as listed below.

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)
• large appliances - white goods (Guideline #GL-102)
• light fixtures (Guideline #GL-103)
• automobile replacement parts (Guideline #GL-104)

Note: Guidelines do not have a specific duration and do not require renewal

Standard Labeling Guidelines

The following information is guidance for all other products that are not covered by guidelines but are covered under the product categories listed in Vermont Law that require labeling.

Label Wording

The label must clearly inform the purchaser or consumer that mercury is present in the item and that the item may not be disposed of or placed in a waste stream destined for disposal until the mercury is removed and reused, recycled, or otherwise managed to ensure that mercury does not become part of the solid waste or wastewater.

• The label must identify that the product "contains mercury" - For larger products that incorporate mercury-added components, the label should identify the component part such as "Lamp Contains Mercury" or other such wording to clearly inform the consumer.
• Label should point the Vermont user to the fact that the product cannot be placed in trash and must be recycled or disposed of as a hazardous waste.
• Font size 10 is the minimum. If you are unable to provide a label with this font size or minimum wording below on either the product or package, a manufacturer must submit an alternative labeling request.

Examples of minimum wording:

"Contains Mercury, Don't Put In Trash. Recycle or Dispose as Hazardous Waste"

"Contains Mercury, Dispose According to Local, State or Federal Laws"

"Contains Mercury, Dispose of Properly"

Label Specifications

A label should be placed on the mercury-added component, larger product that contains the component, and the package. There must also be a prior-to-purchase notification or label (visibility requirement).

The label must be located on a surface of the product. If the product has physical characteristics (such as extreme hot or cold temperatures, the product surface is too small or attachment of a label directly on the surface interferes with the specific function of the product), then a manufacturer can submit an alternative labeling request.

For labels affixed to products, the required words or symbols must be printed, mounted, molded or engraved on the surface of the product using materials sufficiently durable to remain legible for the useful life of the product.

Wording should be at minimum 10 point font and style of font used should be adequate to provide for a legible label.

There is no minimum label size. The label size must be adequate to accommodate the minimum label wording at a minimum 10 point font.

For products which incorporate mercury-added components, both the incorporated component and the larger product must be labeled. The label on the larger product must identify and describe each mercury-added component. The label should also identify where in the larger fabricated product each component is found.

Product Package Labeling

• Labels are required on mercury-added product packaging, except when the product either has no package or is not packaged in a conventional type of packaging (where a label cannot be affixed such as shrink wrap, crated or loaded on pallets).
• Labels are not required on a "clam shell" type package where the product label can easily be viewed through the clear packaging.
• If component replacement parts are sold as an individual item to end use consumers, the replacement part package must be labeled.
• If a manufacturer purchases a product from another manufacturer and repackages the product to identify the product with their own company name, the manufacturer repackaging the product is responsible to relabel the package.