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Standard Labeling Requirements

Placement of labels should:

  • Be placed directly on the mercury-added component and package;
  • Be placed directly on the incorporated component in addition to the larger product for products which incorporate mercury-added components;
  • Be placed on the package of the larger product;
  • Provide a prior-to-purchase label which notifies the customer of the presence of mercury before its purchase (e.g. web site, sales literature, packaging-whatever the customers see prior-to-purchase depending on how the product is marketed); and
  • Be a legible label that is visible on the product.

Label wording and material should:

  • Be at a minimum 10 point font for all labels including information placed in sales literature, care and use manuals as well as product labels (there is no minimum label size but the label must be adequate to accommodate minimum label wording at 10-point font);
  • 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;
  • Clearly inform the purchaser that mercury is present and provide information for disposal; and
  • Identify the component within a larger product with sufficient detail so that it may be readily located for removal.

Examples of approved label wording:

"Contains Mercury, Dispose According to Local, State or Federal Laws"

"Contains Mercury, Dispose of Properly "

Package label is required:

  • On all 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);
  • On a replacement part package, if a component replacement part is sold as an individual item to end-use consumers; and
  • On a package when a manufacturer purchases a product from another manufacturer and repackages the product to identify the product with their specific company name. The manufacturer repackaging the product is responsible to label the package.

Exceptions to the requirements for standard product labeling are:

  • Specific labeling for certain mercury-added products, (such as products with a mercury-added lamp as the only component, large appliances and motor vehicles that specify methods for labeling that differ from "standard labeling" requirements); and
  • When a 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.

 


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