Labeling Alternative #ALT-0216
Motor Vehicle Labeling

Motor Vehicle Manufacturers & Motor Vehicle Mercury-Added Component Manufacturers

This guideline applies to the labeling of vehicles propelled by internal combustion engines or electric motors such as automobiles, vans, trucks, motorized construction equipment, motorized recreational vehicles, motorcycles, forklifts, etc.

The Agency has approved an alternative labeling proposal that may be used by any manufacturer of motor vehicles as above where mercury-added components are included in the vehicles. Any such manufacturer may propose other alternatives as well, but time is now short to get approval of another alternative. Motor vehicle manufacturers may also simply meet the rules with no alternative request which generally means all mercury-added components must be labeled and a doorpost label must be provided.

Manufacturers of mercury-added components in motor vehicles may use this alternative; otherwise they will need to label their components.

The approved alternative is as follows:

1. The mercury-added components in a motor vehicle are not labeled.
2. The vehicle label must include the wording required by the rule and must list the mercury-added components in the vehicle. This vehicle label must be placed on the doorpost of motor vehicles so equipped and at a clearly visible location near the entry point on motor vehicles without suitable doorposts.
3. The approved label wording is: (The mercury-containing devices will vary with vehicle type)

4. This alternative is approved for a limited duration of three years beginning March 1, 2000 and must be renewed every three years thereafter.

Additional Guidance

If you manufacture a motor vehicle that is covered by this alternative and you wish to take advantage of it, you need to reference it in your labeling plan. When completing your plan, indicate the alternative number #0216 in the column marked (ALT#). Include the appropriate label information and how you plan to complete the labeling process (i.e. manufacturers to affix prior to shipment, made part of dealer preparation, etc.).

If you manufacture a mercury-added component(s) covered by this alternative and you wish to take advantage of it, you need to reference the approved alternative in your labeling plan. When completing your plan, indicate the alternative number #0216 in the column marked (ALT#). This number should be indicated in the row of the appropriate component part.

If you are unsure whether your product qualifies for this alternative or need any assistance in completing your plan, please contact Karen Knaebel (802) 241-3455.