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:
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.
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