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Labeling Requirements Under Vermont's 2005 Law

Vermont passed labeling legislation (10 V.S.A. §7106) that will replace the 1998 labeling law for products sold in the state effective July 1, 2007.

Current legislation regulates a specific list of mercury-added products (i.e. thermometers, thermostats, switches, medical or scientific instruments, electric relays or other electrical devices, mercury-added lamps, and batteries other than button cells). New legislation for labeling expands that list of products to include all mercury-added products, except button cell batteries, products that contain button cell batteries, dental amalgam, photographic film, any mercury-added product for which federal law governs labeling in a manner that preempts state authority, or prescription drugs or any substance that may lawfully be sold over the counter without a prescription under the federal Food, Drug and Cosmetic Act, 21 U.S.C. § 301 et seq.

Who must comply with the new law?

  • Manufacturers of mercury-added products (which includes both formulated and fabricated mercury-added products);
  • Manufacturers whose products are regulated by the 1998 list of mercury-added products;
  • Manufacturers whose products were not previously regulated under Vermont labeling requirements; and
  • Manufacturers who already have an approved Certified Labeling Plan on file with the State of Vermont.

    NOTE: Definitions of terms such as manufacturer, mercury-added products, formulated, fabricated, etc. are included in the 2005 labeling legislation in 10 V.S.A. §7102.

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