Public Comment Period on draft HHW EPR Guidance Documents - HHW EPR FAQ and Covered Products List
All comments on these draft documents should be submitted to Shannon Choquette at Shannon.Choquette@vermont.gov by Monday December 11th at 4pm.
Act 58 of 2023 - Household Hazardous Waste (HHW) EPR Law
Act 58 was signed by the Governor in June 2023 and will require manufacturers of some of the most toxic forms of solid waste to assist with covering the costs for managing these wastes at their end-of-life. For more than 30 years, state law has required municipalities to offer collection of HHW and the costs have grown significantly. This law requires manufacturers to help fund this collection system and to offer public education including source reduction information for consumers.
The Household Hazardous Waste Extended Producer Responsibility Law will begin with product manufacturer stewardship organization registration in January 2025 and collection plan submission in July 2025. Implementation will take effect 6-months after Plan approval, likely sometime in 2026.
ANR will be providing guidance to product manufacturers and solid waste management entities via website, stakeholder meetings and ongoing communications in addition to reviewing and approving manufacturer registrations and the stewardship plan and related reporting requirements. ANR will be responsible for ensuring compliance of all covered manufacturers and their products under this new law.
This page will be updated regularly with the most recent available documents.
Vermont Household Hazardous Waste (HHW) Extended Producer Responsibility (EPR) Law Timeline
January 15, 2024 – ANR Fee Recommendation: ANR shall submit to the Legislature a recommended annual registration fee for its oversight of the household hazardous waste EPR program.
January 1, 2025 – Stewardship Org. Registration: A stewardship organization shall file a registration form with ANR and the Secretary shall only approve one stewardship organization for the first collection plan (up to 5 years).
July 1, 2025 – Collection Plan: For the first Collection Plan one stewardship organization registered with ANR must submit ONE Collection Plan for all manufacturers to ANR. ANR shall approve the Plan for up to 5 years. ANR must hold public comment period during approval process. After the first collection plan (up to 5 years), multiple stewardship organizations may register with ANR and must collaborate to submit ONE Collection Plan for the next plan period.
July 1, 2025 – Covered HHW Disposal Banned: Landfill disposal ban on Covered Household Hazardous Waste goes into effect.
6-months After Plan Approval (DATE TBD):
- Collection Plan Implementation: Stewardship organizations must implement the Collection Plan 6 months after ANR approval (potentially March 1, 2026, assuming plan approval is complete by October 1, 2025).
- Sale Prohibited of Household Hazardous Products that Don’t Participate: Manufacturers cannot sell covered household hazardous products into Vermont unless they are participating in the approved Collection Plan.
18-months After Plan Implemented (DATE TBD) - Annual Reports: Stewardship organization(s) submits the annual report to ANR 18 months after Plan implementation (potentially September 1, 2027) and annually thereafter.
Public Awareness Surveys: During the first year of program implementation (Program Year 1 - 2026), and two years after adoption of the collection plan (DATE TBD), the stewardship organization(s) must complete an annual Public Awareness Survey and report these results to ANR with their annual report.
Annual Performance Goal: During each year of the ANR approved Collection Plan—depending on how long ANR approves the first Plan for—the stewardship organization(s) Plan is required to meet a minimum annual performance goal of a 5% participation rate based on the number of households the collection program serves. Annual Performance Goal data shall be submitted to ANR with the annual report. After the end of the initial approved Collection Plan, the stewardship organization shall propose an annual performance goal for subsequent Collection Plans.
September 1, 2030 – Collection Plan Audit: Stewardship organization(s) is required to submit a Collection Plan Audit to ANR and every 5 years thereafter.