February 2015
Happy 2015!

Labeling Requirements for Mercury-Added Products

The IMERC Labeling Workgroup has been busy reviewing applications for alternative labeling plans for mercury-added products. After much consideration, the Group has determined that any mercury-added product that includes the following information on the product label meets the minimum "standard" requirements for all IMERC-member states requiring labeling: 
  • Text that states "contains mercury" (in 10 pt. font)
  • Hg in a circle symbol 
  • Crossed out wheelie bin 

If manufacturers are able to include additional information to indicate that the product can be recycled, the Workgroup recommends that they include: 

  • Chasing recycling arrows 
Manufacturers must certify that their product label meets the requirements when they complete their triennial notifications. If not, they must apply for an alternative label that is subject to approval by the States.

In addition, the Workgroup recently approved an alternative label that conforms with a new Federal Trade Commission (FTC)-mandated label for screw-based compact fluorescent lamps (CFLs). These types of lamps are used mainly by consumers, and the Workgroup is pleased that the product label will clearly indicate that mercury is in the bulb and it requires proper disposal. The Workgroup will continue its review of applications throughout the winter and spring.


The states of Connecticut, Louisiana, Maine, Massachusetts, Minnesota, New York, Rhode Island, Vermont, and Washington prohibit the sale of mercury-added products unless they have an approved label.  These products and their packaging must have a visible and durable label that indicates that it contains mercury and should be managed or disposed of properly. The standard labeling requirements, as well as information for companies wishing to apply for an "Alternative Label" are available at: www.newmoa.org/prevention/mercury/imerc/labelinginfo.cfm

2013 Triennial Mercury-added Product Notifications

To date, more than 60 percent of eligible manufacturers have successfully submitted their 2013 Mercury-Added Product Triennial Notifications using IMERC's e-filing system.  The IMERC Notification Workgroup has been diligently reviewing these forms to ensure companies' compliance.  

As we near the end of the queue of submissions, IMERC will turn its attention to those manufacturers that have not filed for 2013 and are suspected of being in non-compliance. 
IMERC staff will begin reaching out to these companies in the next couple of months. Failure to comply with the requirements will result in non-notifiers being referred to the States for enforcement.

Notification through the e-filing system enables firms to comply with the Mercury-added Product Notification requirements of Connecticut, Louisiana, Maine, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont. Reporting is required for any company that sold or distributed mercury-added products into the states listed above during calendar year 2013.  Helpful documents, including links to a User Guide and an online video demonstration are available at: www.newmoa.org/prevention/mercury/imerc/efiling.cfm.

Update Company Contact Information

IMERC Alert shares critical information with manufacturers, distributors, and importers of mercury-added products and trade organizations that represent those companies on IMERC members' regulatory requirements concerning mercury-added products.

If you are receiving this Alert in error or if you need to update or add additional company contacts, please contact IMERC staff at
imerc@newmoa.org or (617) 367-8558.