State Mercury-Added Product Notification & Labeling - An Overview
This Guidance Document is designed to help manufacturers, importers and distributors of mercury-added products understand how to comply with Labeling and Notification requirements in Connecticut, Louisiana, Maine, Massachusetts, Minnesota, New Hampshire, New York, North Carolina, Rhode Island, Vermont, and Washington State.
Information on these state specific mercury requirements is available at the following websites:
For more information on IMERC member state mercury products legislation see: www.newmoa.org/prevention/mercury/modelleg.cfm.
The participating states are coordinating these mercury reduction initiatives through the Interstate Mercury Education and Reduction Clearinghouse (IMERC) in order to:
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 are IMERC-Member State Mercury-added Product Labeling & Notification Requirements?
Labeling Products and Packaging
Vermont was the first state in the Northeast to enact a labeling law and was the only state that required a Certified Labeling Plan to be filed. All other states obtain the labeling information they need from Vermont. A labeling plan approved in Vermont usually met the labeling requirements in other Northeast states, Louisiana, Minnesota, and Washington State. Due to changes in Vermont's law, manufacturers are no longer required to file a Certified Labeling Plan with the Vermont Agency of Natural Resources (available at http://www.mercvt.org/label/forms.htm). As part of the new Notification e-filing process, manufacturers will be asked to certify that their products are labeled in accordance with states' requirements. This "certification form" will also be available on the IMERC website in Fall 2011 for those companies that wish to file a paper copy.
Notification on Mercury Content of Products
Following approval of the submission, the information from the Forms is entered into the "IMERC Mercury-added Products Database" and posted on the IMERC website. Mercury-added Product Notification Forms that have not been approved are not included in this database. All hard copy Forms that are submitted to IMERC are available to the public.
What is the Purpose of Mercury-added Product Notification?
"Product Notification" requirements are intended to inform consumers, recyclers, policy makers, and others about:
How Can You Get More Information?
If, after reviewing this guidance, you have any questions or concerns, contact:
1 The product notification requirements in North Carolina apply to automobiles, only.