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Visibility Requirement Under Vermont Law and Rule

The visibility requirement addresses the product labeling where a label must be "visible during installation and removal" - This may affect your decision for the placement of the label on the product. Also, once a component (switch, lamp, etc.) is placed in a larger product and the label is no longer visible then the larger product would require a label to comply with visibility. The Vermont Mercury Management Rules, Subchapter 8, Special Wastes, Section 6-803(b)(2) states:

"A label must be clearly visible and legible to consumers prior to purchase of the product. The label must be located on a surface of the product that is visible during installation and removal."

The other element of the visibility requirement is that a label must be visible prior-to-purchase. If your product is a retail product and sold as a packaged item, then prior-to-purchase visibility requirements may be met with the package label. If the product is only sold by catalog, Internet, or other means whereby the purchaser does not directly view the product, visibility requirements may be met by placing the labeling information in one of those media.

This requirement may be fulfilled by asking, "What does the customer see prior to purchase?" This may be largely dependent upon how the product is marketed or what type of customer the manufacturer is selling to. If a manufacturer ONLY sells products to other original equipment manufacturers (OEMs), there are no visibility requirement for the manufacturer who sells to the OEM as this requirement only applies to what is "visible" to the end user of the product.

If you have questions, please contact Karen Knaebel at (802) 241-3455.


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