Mercury in Products: Manufacturer Requirements

• Louisiana Mercury statutes and LDEQ regulations
  • https://legis.la.gov/legis/Law.aspx?p=y&d=410531
  • https://www.deq.louisiana.gov/resources/category/regulations-lac-title-33
    • Part 1, Chapter 27
  • It is the responsibility of the manufacturer/importer/distributor or trade group to understand and fulfil all requirements set forth.
• Under statute, the state is directed to collaborate and communicate with other states and/or regional organizations
  • The Interstate Mercury Education and Reduction Clearinghouse (IMERC) is the organization that LDEQ and other states coordinate with, and is the primary means to fulfil multiple Louisiana state requirements:
    • Notifications
    • Labeling
      • Including prior-to-purchase notice to consumer, as applicable
    • Phase-out exemptions
  • IMERC members have developed guidance, How-To videos, and forms/applications to streamline processes and timelines (2024-2025)
    • https://www.newmoa.org/programs/mercury-clearinghouse/imerc-guidance/.
  • Certain products that exceed mercury limits are allowed for sale within the state following the exemption process. As part of consideration to allow sales of these products, all aspects of statue/regulations (listed above) must be fulfilled.  To apply for an exempton:
    • Read and understand Louisiana statutes and regulations
    • Obtain and submit the IMERC Phase-Out Exemption Form to the IMERC portal
      • https://www.newmoa.org/wp-content/uploads/2023/02/Exemption_Application-2024.pdf
      • https://imerc.newmoa.org/Public/EnSuite/Shared/Pages/Main/Login.aspx
    • Notify LDEQ of submittal via: DEQ-MercuryExemptionRequest@la.gov
    • Track and maintain deadlines within the company/trade organization
  • All questions and communications concerning mercury in products can be sent to the LDEQ email above.