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IMERC Guidance Materials Notification

IMERC Notification Guidance

Notification on Mercury Content of Products

If you manufacture, sell, distribute, or import a mercury-added product that you wish to sell in the states of Connecticut, Louisiana, Maine, Massachusetts, New Hampshire, New York, North Carolina (automobiles only), Rhode Island, and Vermont you must file a Mercury-Added Product Notification Form. This may be done once through IMERC or directly with each individual state.

What is a Mercury-added Product?

A mercury-added product is a product, a commodity, a chemical, a product with one or more components, or a product that cannot function without the use of that component, that contains mercury or a mercury compound intentionally added to the product, commodity, chemical, or component in order to provide a specific characteristic, appearance, or quality, or to perform a specific function, or for any other reason. These products include formulated mercury-added products and fabricated mercury-added products.

A fabricated mercury-added product is a combination of individual components, one or more of which has mercury added, that combine to make a single unit.

A formulated mercury-added product is a chemical product, including but not limited to laboratory chemicals, cleaning products, cosmetics, pharmaceuticals, and coating materials that are sold as a consistent mixture of chemicals.

What is the Purpose of Mercury-added Product Notification?

"Product Notification" requirements are intended to inform consumers, recyclers, policy makers, and others about:

  • Products that contain intentionally-added mercury;
  • The amount of mercury in a specific product; and
  • The total amount of mercury in the specific products that were sold in the US in a given year.

How Can Companies File the Required Notification Forms?

The IMERC notification process is completed by manufacturers through an online e-filing system. Once the submission is submitted to IMERC, it is reviewed by a multi-state group that is appointed by the Commissioners or Directors of the states' environmental agencies. The submission and approval of the Mercury-added Product Notification Forms through IMERC enables manufacturers, distributors, and their trade representatives to comply with all of the states that have the Notification requirement in their state laws. All aspects of the Notification process, including Form submission, attachment submission, and post submission communications, are handled through the e-filing system.

The e-filing system launched on November 1, 2011. Prior to that time, companies submitted their product notifications via hard-copy forms. For reference, copies of these blank forms are included below. Companies who have never submitted a Notification Form using the e-filing system should contact the IMERC Coordinator at 617-367-8558 to get set up with an account.

For Single Manufacturers:

For Multiple Manufacturers (via Trade Association):

For Lamp Manufacturers Only:

What Does IMERC Do With the Data Submitted?

Following approval of the submission in the e-filing system, the information from the Forms is entered into the IMERC Mercury-added Products Database. The Database is intended to inform consumers, recyclers, policy makers, and others about:

  • Manufacturers of mercury-added products
  • Products that contain intentionally-added mercury
  • Mercury content in products
  • Total mercury used in in product lines sold in the US every three years starting in calendar year 2001

Mercury-added Product Notification Forms that have not been approved are not included in this database.



Last Modified 11/10/2014

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