Written on: November 1, 2025 by Nicholas Georges
The Vermont Household Hazardous Waste (HHW) Extended Producer Responsibility (EPR) law—originally enacted in 2023 and amended earlier this year—requires producers of “covered household hazardous products” to join a stewardship organization (SO) to fund the costs of HHW management.i,ii Because no industry-sponsored SO was established to administer the collection plan under the law, the Vermont Agency of Natural Resources (ANR) will take responsibility for this role.
A key provision in the implementation timeline requires companies that sell, offer for sale or supply covered household hazardous products to retailers to register with ANR by Nov. 1, 2025, via the online registration form.iii The form requests basic information about the registering organization and the household hazardous products they sell. Companies are prohibited from selling household hazardous products in the State if they do not participate in this program.
Under the law, a “covered household hazardous product” refers to a consumer product offered for retail sale that meets the criteria in Subchapter 2 of the Vermont Hazardous Waste Management Regulations,iv including products exhibiting hazardous characteristics, such as ignitability and corrosivity. The scope of the law also includes gas cylinders.
During negotiations, the Household & Commercial Products Association (HCPA) was able to secure exemptions for certain product categories, including pesticides registered with the Agency of Agriculture, Food & Markets. It is important to note that architectural paint, which had been managed under a separate stewardship program long before the introduction of Vermont’s HHW EPR law, is also excluded.
Not all consumer aerosol products are included under Vermont’s HHW EPR law.v Only those that exhibit a specific hazardous waste characteristic, such as ignitability or corrosivity, are required to register with the SO.vi Companies can refer to ANR’s Covered Products Summary to check if a product is covered under the law.vii
As administers of the law, ANR will charge companies a flat fee to manage the disposal of household hazardous waste. Eventually, this flat fee will become a company-specific cost based on the number of covered products sold in the Green Mountain State. ANR will also charge companies an administrative fee (which would have been waived had an SO been established), as well as 10% of the plan’s total cost, which will be used to fund grants for municipalities and small businesses to prevent pollution and reduce hazardous waste generation.
As the first program of its kind, Vermont’s initiative represents a significant effort in establishing an EPR framework specifically for managing HHW. Companies should start to prepare for other States to follow suit; California and Illinois are actively considering similar HHW EPR policies.
For the latest updates or if you have any questions, please contact me at [email protected]. SPRAY
i Act 58 of 2023
ii Act 59 of 2025
iii link
iv link
v See Question 31 under ANR’s FAQ Document
vi See Question 32 under ANR’s FAQ Document
vii link
