Mercury Clearinghouse - Report to IMERC
Mercury-Added Product Reporting
IMERC’s electronic filing system is an online platform designed to help the regulated community (“manufacturers”)1 comply with the mercury-added product (MAP) reporting requirements of the thirteen IMERC member states (“the States”)2. By providing a centralized location to submit applications, the system ensures that companies selling or distributing products into the States meet the applicable Mercury-Added Product Notification, Product Labeling, and/or Phase-Out requirements.
New User Setup Guide
NOTICE: Manufacturers, importers, and users of mercury or mercury-added products in a manufacturing process are also required to comply with the EPA’s Mercury Inventory Reporting Rule under the Toxic Substances Control Act (TSCA). This federal requirement is distinct from state-level reporting obligations, such as those facilitated by IMERC, and must be completed to ensure comprehensive compliance. For more information about EPA’s reporting requirements for mercury, click here.
Guidance Documents
- How to Create a New Reporting User Account [PDF]
- How To Submit Your First Triennial Notification [PDF]
- How to Resubmit a Notification Returned for Amendment [PDF]
- How to Delete Draft or Incomplete Submissions [PDF]
- How to Access Approval Letters [PDF]
- How to Renew a Triennial Application [PDF]
- How to Submit an Alternative Labeling Plan Application [PDF]
- How To Submit a Phase-Out Exemption Application [PDF]
- Recorded Training Demonstration for Reporting Users [YouTube; 36:28]
Types of IMERC Reporting
Any entity – herein known as a “manufacturer” – that manufactures, sells, distributes, and/or imports a mercury-added product into the states of Connecticut, Louisiana, Maine, Massachusetts, New Hampshire, New York, Rhode Island, or Vermont is required to file a Mercury-Added Product Notification Form every three years. In addition to this requirement, automobile manufacturers must submit annual updates if they intend to sell into these states. In the case of a multicomponent mercury-added product, the manufacturer is the last manufacturer to produce or assemble
Additional information about the Mercury-Added Product Notification process can be found here.
The states of Connecticut, Louisiana, Maine, Massachusetts, Minnesota, New York, Rhode Island, Vermont, and Washington prohibit the sale of mercury-added products unless they fulfill the prior-to-purchase visibility requirements under their state labeling laws.
If a product cannot be labeled in accordance with IMERC’s standard labeling criteria, the reporting company must submit an Alternative Labeling Request to IMERC for consideration by the States. A separate request must be submitted for each product that does not adhere to established criteria.
Additional information about the Mercury-Added Product Labeling Guidelines and the Alternative Labeling Request process can be found here.
Mercury-added product phase-out is the systematic process of eliminating the use, manufacture, and sale of products containing mercury due to its hazardous effects on human health and the environment. To achieve this, government agencies establish deadlines for phasing out certain product categories, enacting sales bans on specific products, and implementing strict disposal and recycling protocols.
Phase-out exemptions are state-specific allowances and statutory exemptions made within the regulatory framework for mercury-added product phase-outs. These exemptions recognize that in certain cases, the elimination of mercury use is not immediately feasible due to technical or practical limitations. Products granted exemptions can continue to be used, manufactured, or sold for a specified period or under specific conditions (e.g., collection plan requirements).
Applicants seeking an exemption from phase-out must complete and submit a Phase-Out Exemption Application for each state that they are requesting an exemption from. IMERC facilitates interstate review of exemption requests, however, each state agency makes a state-specific decision regarding each request. Upon approval of a phase-out exemption request, each state sends a letter to the applicant detailing the conditions of the approval.
Additional information about Mercury-Added Product Phase-Out and the Phase-Out Exemption application process can be found here.
Forms Required for Reporting
This form must be signed by a senior management official3 and attached to every Mercury-Added Product Notification submission. This is in addition to checking the box in the “Certification of Submission” portion of the online application. Your application will not be considered until this signed form is provided.
Other than the signing of this certification form, the entire Product Notification submission process – including uploading your signed PDF attachment – is handled using IMERC’s online reporting system.
For guidance on submitting your first notification, please reference this tutorial. For notification renewals, please follow these guidelines.
Please be advised that IMERC is currently in the process of revising the Alternative Product Label Application. The revised forms will be available after January 1, 2025. To receive updates via email, please subscribe to the IMERC Alert newsletter.
To apply for an exemption from a phase-out requirement, applicants must submit a Mercury-Added Product Phase-Out Exemption Application to each state from which they are seeking an exemption.
New phase-out exemption requests are generally due one year before the effective date for which they are seeking an exemption, but regulations vary greatly amongst the IMERC member states. Exemption renewals should be submitted to the appropriate state(s) before their expiration date. In all cases, we strongly encourage you to review the mercury-added product regulations in the applicable state(s).
For additional guidance, please reference this tutorial.
1. IMERC defines a “manufacturer” as an entity that manufactures, sells, distributes, and/or imports a mercury-added product into one of the IMERC member states. For multicomponent mercury-added products, the manufacturer is defined as the entity responsible for producing, assembling, and/or selling the final mercury-containing product into one or more of the States.
2. The thirteen IMERC member states are: Connecticut, Louisiana, Maine, Massachusetts, Michigan, Minnesota, New Hampshire, New Jersey, New York, North Carolina, Rhode Island, Vermont, and Washington.
3. A senior management official is a corporate officer or the individual responsible for the overall operation of a facility or an operational unit of a facility, such as a plant manager, superintendent, manager of environmental programs, or person of equivalent responsibility.
