Labeling Alternative #ALT-0258
Mercury-Added Lamps

Mercury-Added Lamp Manufacturers

Based on the request of lamp manufacturing members of National Electrical Manufacturers Association (NEMA), the Agency has approved an alternative labeling for lamps that may be used by the NEMA members to meet Vermont’s labeling legislation. The approval includes a condition that NEMA agrees to financially support a campaign in Vermont to educate consumers on the meaning of the alternative label on the lamps. The alternative also uses the lamp recycle website established by NEMA on the packaging to help inform consumers about state disposal laws. NEMA members have indicated they wish to provide other manufacturers of lamps the ability to utilize the same labeling alternative, including the web site, without the necessity of contributions to a public education campaign.

The alternative approved, the conditions of that approval and the implementation date of labeling are outlined below.

Approved Alternative

The Agency approves the Hg symbol in a circle for labeling of mercury-added lamps. The symbol will be no less than 10 point font and the same color as existing coloring on the lamp. The Department recognizes there may be some exceptions where the circle may not be feasible and only Hg with an underline can be used because of size. (See conditions for use of Hg below)

The Agency approves package (shipping cases and product package) and insert labeling of "Hg – LAMP CONTAINS MERCURY, Manage in Accord with Disposal Laws, See: www.lamprecycle.org or 1-800-000-0000" in a minimum 10 point font. The Department understands that the 800 number provided on the label will be the telephone number of each lamp manufacturer.

In addition to the items above, NEMA members have agreed, as a provision of the NEMA alternative, to provide contribution for a Vermont public education campaign. This effort is imperative for the effectiveness of the use of a symbol for labeling. Non-NEMA members will not be required to contribute to this campaign to utilize this alternative.

Approved Alternative Duration

This alternative is approved for use until March 1, 2005. Requests for approval of a two year renewal or renewal with modification must be received by September 1, 2004, six months prior to the expiration date of the alternative.

Implementation of Labeling

The following dates replace those in earlier correspondence and on the web site for submission of alternative requests and approval of certified labeling plans. Manufacturers will be subject to enforcement for failure to meet deadline dates.

Complete certified labeling plans including additional alternative labeling requests must be submitted and postmarked no later than October 15, 2002. Plans must be complete and must include all information requested on the form together with detailed information on alternative requests for any lamps that the company believes cannot be labeled using the #0258 alternative. Plans for lamps that propose "no label" on the lamp itself will not be approved unless evidence is shown that physical characteristics (such as small size or extreme heat) prevent labeling directly on the lamp. In such cases, the manufacturer must make a proposal for an alternative method to inform the consumer. This information must also be included in the certified labeling plan submitted by the October 15th deadline in order for the plan to be considered complete. Incomplete submissions will not be accepted until the missing material is submitted. We suggest you carefully evaluate the necessary content of the submission based on this letter and the website and should you have any questions, contact Karen Knaebel at (802) 241-3455 or E-mail at karen.Knaebel@state.vt.us.

An alternative approval number has been assigned to this alternative as #0258 and should be referenced on any correspondence and indicated in the column marked (ALT#) on the certified labeling plan for those products which will be labeled with Hg in a circle.

Manufacturers must identify products that cannot be labeled with Hg in a circle and submit an exceptions list of products that will bear Hg. The list must identify the product by type (i.e. HID)and list model numbers within that category, identify the reason that the Hg in a circle cannot be utilized. Exceptions must be submitted and postmarked no later than November 15, 2002.

Any additional information requested by the Department in order to finalize plans must be submitted and postmarked no later than December 15, 2002.

Mercury-added lamp products manufactured after November 30, 2003 shall be labeled in accord with each manufacturers’ certified labeling plan in order to be sold for use in the state of Vermont.

Additional Guidance

If you manufacture a mercury-added lamp and wish to utilize this alternative, you need to reference it in your Certified Labeling Plan. When completing your plan, indicate the alternative number 0258 in the column marked (ALT#).

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