Interchange 360 Seeks Clarity for Producers as Vermont Develops Household Hazardous Products Program

As Vermont moves forward with implementation of its Household Hazardous Products (HHP) stewardship requirements, Interchange 360 is taking steps to provide producers and service providers with greater clarity about their options for compliance.

The Vermont Agency of Natural Resources (ANR) recently released its Draft Vermont Household Hazardous Products Agency Collection Plan for public review. In response, Interchange 360 submitted a formal letter asking the Agency to publicly acknowledge our intention to submit an independent plan for covered automotive and petroleum products.

This acknowledgement is an important step toward giving producers a clearer understanding of the compliance options available to them as Vermont’s program develops.

Why Interchange 360 is seeking acknowledgement

Interchange 360 is working to establish an independent plan designed specifically for the collection and management of automotive and petroleum products covered by Vermont’s HHP requirements. However, the law does not allow the state to officially approve our plan until July 2027 at the earliest. In the meantime, the state-run program is anticipated to begin in January 2027. The difference is timing and the different programs have the potential to create confusion over compliance requirements and how the programs will work together once the transition takes place.

Public acknowledgement of our intention to submit a plan would allow us to communicate more clearly with producers about upcoming requirements, registration deadlines and the steps they need to take to participate.

It would also allow Interchange 360 to begin providing advance notice to existing collection facilities and other service providers about our plans for Vermont. Early coordination will help ensure the collection network is prepared and that producers, service providers and other stakeholders have the information they need before the program launches.

Ultimately, greater clarity now will support a stronger and more effective program once implementation begins.

What Interchange 360 is doing for the industry

Interchange 360 has formally notified the Vermont Agency of Natural Resources of our intention to submit an independent plan and has asked the Agency to publicly acknowledge that intention as part of the current planning process.

Our proposed approach builds on Interchange 360’s experience developing specialized collection systems for automotive and petroleum products and packaging, providing producers with a compliance pathway tailored to the unique collection and management needs of these materials.

Public comments are open until September 10

The Vermont Agency of Natural Resources is currently accepting public comments on its Draft Agency Collection Plan. Comments must be submitted by September 10, 2026.

Producers and other industry stakeholders affected by Vermont’s HHP requirements are encouraged to review the draft plan and participate in the public comment process.

What producers should do now

Producers that may be obligated under Vermont’s HHP requirements should begin preparing now rather than waiting for program implementation.

Interchange 360 is working with both existing and prospective participants to help them understand the developing requirements and prepare for compliance. Producers interested in participating in Interchange 360’s proposed Vermont independent plan can learn more about registration, program developments and next steps on our Vermont program page.

Learn more about Interchange 360 in Vermont and how to register here: https://interchange360.com/vermont/