 |
|
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:
FLUORESCENT AND HID
LAMPS CONTAIN MERCURY-
DISPOSE OF THESE LAMPS ACCORDING TO LOCAL, STATE OR FEDERAL
LAWS.
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:
- 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.
- 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.
Guideline:
No label is required on the product or package of automobile
replacement parts.
|
|
|
103
South Main Street 
