State Mercury-Added Product Notification Process

Who is Required to Submit Product Notification Forms?

This reporting requirement applies to anyone that manufactures, sells, distributes, or imports a mercury-added product for sale into a state with a Product Notification requirement (Connecticut, Louisiana, Maine, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont).

In order to comply with these requirements, companies must submit their first notification before making any mercury-added products available for sale or distribution in the states listed above. After initial approval, reporting companies must submit an updated notification every three years. The next triennial notification reports – covering US sales during calendar year 2024 – are due by July 1, 2025

What is the Purpose of Having Product Notification Requirements?

“Product Notification” requirements enable interested parties (e.g., consumers, recyclers, policymakers) to stay informed about:

  • What companies sell mercury-added products;
  • Which products contain intentionally-added mercury;
  • How much mercury is contained in specific products; and
  • The total amount of mercury sold in the US (in a given calendar year) for specific products.

How Are Notification Forms Submitted and Processed?

The product notification process starts when a reporting company submits a Mercury-Added Product Notification through IMERC’s online reporting system. Once received, a submission undergoes an Administrative Review by the IMERC Coordinators to ensure it contains all the required information. Complete applications are then reviewed by a multi-state Notification Workgroup, which is composed of representatives from the IMERC members states who have been appointed to the workgroup by the Commissioner or Director of their environmental agency.

Reporting users receive a generic email confirmation from the system immediately when their submission is approved. Within two weeks of receiving this confirmation, IMERC will issue a formal approval letter, which contains important information – such as additional reporting requirements or state-specific product sales restrictions/bans that have implications for your products. Consequently, it is imperative that they be accessed promptly and read thoroughly. Click here for instructions on how to access approval letters. If you do not have access to a formal approval letter within two weeks of submission approval, please contact the IMERC Coordinators at imerc@newmoa.org.

What Does IMERC Do With the Data?

Once a Mercury-Added Product Notification is approved, the data from the submission is added to the IMERC’s Mercury-Added Products Database. The database only contains information from approved submissions. The purpose of this database is to communicate information regarding the amount and purpose of mercury in products. Users are able to search the database by Company, Product Category, and/or Mercury Amount.

If you represent a company listed in the database, and you believe that your product information is incorrect, contact imerc@newmoa.org.