Product-Specific Labeling Guidelines

Large appliances
If your product is a large appliance, labeling requirements remain the same for the new law as they were under the 1998 law. The definition for large appliance includes additional products that were not included under the 1998 law. Labeling for large appliances where the product is sold in a store where that appliance is on display shall meet all the requirements by labeling the product, and the mercury-added component in the product. If the product is soldfrom a showroom floor, the prior-to-purchase visibility requirement can be met by placing the product label on the appliance itself. If the product is not sold in a store where the appliance is on display, then the manufacturer must comply with the prior-to-purchase visibility requirement.

Motor vehicles
Motor vehicle labeling requirements remain the same for the new law as under the 1998 law. Labeling for motor vehicles is no longer an alternative method of labeling that has to be renewed every three years, but the same labeling requirements for motor vehicles have been specifically written into the new law.

Labeling for motor vehicles require:

• No label on the internal mercury-added components within a motor vehicle;
• The vehicle label to list the mercury-added components included in the vehicle (The mercury-containing devices will vary with vehicle type);
• The vehicle label to be placed on the driver side doorpost (unless otherwise approved by the Vermont Department of Environmental Conservation) of motor vehicles so equipped;
• The motor vehicle dealer will be responsible for applying the door post label (only in the case of a trade of a new vehicle by a dealer with a dealer in another state);
• No label on used motor vehicles;
• Label placement at a clearly visible location near the entry point on motor vehicles without suitable doorposts. This location will be subject to the approval of the Department; and
• The approved label wording as follows:

Products that contain one or more non-replaceable or non-removable
mercury-added lampsused for backlighting, LCD panels, scanning images or copying images
If your mercury-added product falls into one of the above categories, the labeling requirements can be met by providing a label on the larger product that contains the mercury-added lamp and in the care and use manual for the larger product. Vermont's 1998 law requires the larger product to be labeled as well as the internal lamp and that the manufacturer provide some prior-to-purchase visible label. If a manufacturer submits a plan and wishes to comply with the new law whereby there is only a requirement to label the larger product and the care and use manual, Vermont will accept this labeling as fulfilling the requirements of the 1998 law as well as fulfilling the requirements of the 2005 law. By doing this, the manufacturer may eliminate the necessary to change labeling methods for products sold in the State of Vermont after July 1, 2007.

Products with an LCD panel less than 7" in diagonal
If your product has an LCD display panel less than 7" in diagonal and you are currently complying with the 1998 Vermont requirements by utilizing the approved alternative #0285, then your labeling requirements would remain the same for the new law as they were under the 1998 law utilizing the authorized alternative. The requirements for labeling a product with an LCD display panel less than 7" in diagonal are to place labeling information in the care and use manual. Information in the care and use manual must be provided in at least a 10 point font and meet the wording criteria for a standard label.

Products that contain one or more replaceable mercury-added lamps
If your product has as its only mercury added component a lamp or lamps at least one of which is intended to be replaceable by the user or consumer, the internal lamp(s) must be labeled, the larger product must be labeled, the care and use manual (if any) must be labeled and if the lamp is placed within a housing intended to be replaceable by the consumer, the housing must also be labeled.

If your mercury-added product is a luminaire, the product, the lamp(s) and the package must be labeled regardless of whether the mercury-added lamps are sold separately from the luminaire.

Flashlights or portable lanterns
If your product is a flashlight or a portable lantern in which the lamp is the only mercury-added component, the product is exempt from labeling requirements until July 1, 2009; however, the mercury-added lamp must be labeled.