The Vermont Household Hazardous Waste (HHW) Extended Producer Responsibility (EPR) Law (full statute here) requires manufacturers of some of the most toxic forms of solid waste to assist with covering the costs for managing these products 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.

State law mandates that producers of “covered household hazardous products” form a Stewardship Organization that can implement the obligations of this new law. However, the Vermont Agency of Natural Resources (ANR) has not received any valid Stewardship Organization registration and will pursue implementation of an agency led program as outlined in the law.

ANR has responsibility for administering this law and will be providing guidance to product manufacturers and solid waste management entities via this website, stakeholder meetings, and ongoing communications. In addition to registering manufacturers, implementing a collection plan and billing producers for implementation of the HHW EPR program, ANR will be responsible for ensuring compliance of all covered manufacturers and their products under this new law.

Manufacturers are required to register with ANR by November 1, 2025. Manufacturers can register through ANR’s online registration form.

Full implementation of this program will take effect after July 1, 2026.

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Vermont Household Hazardous Waste (HHW) Extended Producer Responsibility (EPR) Law Timeline

Manufacturer Register with Agency

November 1, 2025 – Manufacturer Registration: On or before November 1, 2025, a manufacturer of a covered household hazardous product shall register with ANR via ANR’s online registration form.

November 1, 2025 – Sale Prohibited of Household Hazardous Products that Do Not Participate: A manufacturer of a covered household hazardous product shall not sell, offer for sale, or deliver to a retailer for subsequent sale a covered household hazardous product without registering with the stewardship organization.

Initial Stewardship Organization State Registration

July 1, 2025 – Agency Collection Plan: If no stewardship organization is formed on or before July 1, 2025, ANR shall adopt and administer a plan. See Collection Plan below for more details.

Annual Stewardship Organization State Registration

July 1, 2026 – Annual Stewardship Organization Registration Renewal: A stewardship organization shall renew its registration with ANR annually on July 1. ANR will post a “Stewardship Organization Registration Renewal Form” here in a few months.

Collection Plan

July 1, 2026 – Agency Collection Plan: In absence of a registered stewardship organization forming by July 1, 2025, ANR shall adopt and administer a collection plan.

Pursuant to 10 V.S.A. § 7187 (Act 59 of 2025), The Agency shall charge each manufacturer the prorated costs of plan administration, the Agency’s oversight costs, and a hazardous waste reduction assessment of 10 percent of the plan’s total cost to be deposited in the Solid Waste Management Assistance Account of the Waste Management Assistance Fund, for the purpose of providing grants to municipalities and small businesses to prevent pollution and reduce the generation of hazardous waste in the State. When determining a manufacturer’s assessment under this section, the Agency may allocate costs to a manufacturer of covered household hazardous products based on the sales of covered household hazardous products nationally prorated to the population of Vermont.

The Agency has initiated an RFP for a contractor to assist with obtaining materials sorting information for covered HHW products from municipal HHW collectors in order to help determine cost allocation. The Agency is also planning to release an RFP seeking a contractor to assist with obtaining national sales data from covered producers and with setting up a billing system for covered producers. The Agency will notify registered producers of their obligation to pay fees once a system is set up and a Collection Plan is adopted.

6-months After Plan Approval (DATE TBD):

• Collection Plan Implementation: The Agency will adopt, implement and administer the Collection Plan.
• 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.

Subsequent Plans (Date TBD):

• Subsequent Collection Plan Implementation: After the expiration of the initial plan approved by the ANR (up to 3 years,) the registered Stewardship Organization(s) must submit one Collection Plan for all manufacturers to ANR.

18-months After Plan Implemented (DATE TBD) – Annual Reports: Stewardship organization(s) submits the annual report to ANR 18 months after Plan implementation and annually thereafter.

Public Awareness Surveys: During the first year of program implementation, 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.

Miscellaneous Dates

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. See ANR’s Fee Recommendation Memo here.

June 11, 2025 – Paint Products Removed and in Paint Stewardship: Under title 10 V.S.A. § 7181(4)(B)(iv) the definition of “covered household hazardous product” is amended to exclude “paint products” as that term is defined in section 6672 of this title. Paint products have been added to the Vermont Paint Stewardship Program under 10 V.S.A. Chapter 159, subchapter 4.  Separate guidance and timeline to follow for ANR’s review of an amended Paint Program Stewardship Plan. Please contact Steve Pincuspy with PaintCare at spincuspy@paint.org with any questions about the expansion of the paint product stewardship program and their manufacturer registration process.

July 1, 2026 – Covered HHW Disposal Banned: Landfill disposal ban on Covered Household Hazardous Products goes into effect.

July 1, 2027 – Solid Waste Plan Flexibility Repealed: Section 13. “SOLID WASTE PLAN; FLEXIBILITY” of Act 59 of 2025 is repealed on July 1, 2027.

September 1, 2030 – Collection Plan Audit: Stewardship organization(s) is required to submit a Collection Plan Audit to ANR and every 5 years thereafter.

The DEC Solid Waste Management Program occasionally hosts informational meetings to help manufacturers understand their obligations under this new law.