Certified Labeling Plans

A Certified Labeling Plan form must be submitted to the Vermont Department of Environmental Conservation (VT DEC) as hard copy with an original signature by October 1, 2006. The form should be mailed to:

Vermont Department of Environmental Conservation
103 South Main Street
Waterbury, VT 05671-4911
Attn: Karen Knaebel

After the October 1, 2006 Certified Labeling Plan submission, any changes in labeling methods for products or product categories or new products that have not been reported to the Department of Environmental Conservation must be submitted and reviewed by the Department for approval.

Manufacturers who currently have a Certified Labeling Plan on file with Vermont:
Must submit an updated plan no later than October 1, 2006. Indicate "update" on the Certified Labeling Plan form. Manufacturers who have complied with labeling requirements prior to the new law may have additional labeling requirements if they do not meet standard labeling for the 2005 law or have different requirements under specific labeling for certain mercury-added products.

Manufacturers who are not a manufacturer of a product subject to Vermont's 1998 labeling law and who were not required to label in Vermont prior to the 2005 law:
Must submit a Certified Labeling Plan no later than October 1, 2006 in order to sell their products in the State of Vermont after July 1, 2007.

Manufacturers who are subject to Vermont's current labeling law and have not filed a Certified Labeling Plan:
If your product is a thermometer, thermostat, switch, medical or scientific instrument, electric relay or other electrical device, mercury-added lamps, and batteries other than button cell or if your product is a larger product which contains one of these as a component, you must be labeling your product according to Vermont 1998 requirements in order to legally sell your product in the state.

Any manufacturer who does not have a Certified Labeling Plan on file with the State of Vermont and/or is not labeling according to Vermont requirements is out of compliance and subject to enforcement action. You must contact the Department and make arrangements to label and file a Certified Labeling Plan immediately. There is NO extension of time for products currently out of compliance.

Manufacturers who manufacture a new mercury-added product after July 1, 2007 and want to sell the product in the State of Vermont:
Must obtain an approved Certified Labeling Plan before selling their mercury-added product in the State of Vermont.

Motor vehicle manufacturers:
Motor vehicle manufacturers who have no other mercury components in their vehicles other than those included in the vehicle itself, (such as automobiles and light trucks) must submit their updated labeling and notification information directly to IMERC on the new auto manufacturers reporting form. All other motor vehicle manufacturers including RV manufacturers must submit an updated Certified Labeling Plan to Vermont no later than October 1, 2006.

NOTE TO ALL MANUFACTURERS:

• Other states have passed labeling legislation and Vermont's legislation is equivalent to other state requirements and may be more stringent in some instances. Vermont is the only state that requires the submission of a Certified Labeling Plan and therefore, other states utilize the information collected in Vermont to determine compliance in their state. By filing a Certified Labeling Plan and obtaining an approval for labeling in the State of Vermont, you will likely comply with requirements in other states that have labeling legislation.
• Manufacturers who have already filed a Notification form with IMERC are encouraged to use the same product categories when reporting for labeling, provided the labeling on all products (within the category) is identical in regard to placement of and the wording on the label.