Producers’ Guide to Vermont HHW Compliance

This Fall, Vermont became the first U.S. state in which producers needed to register under a Household Hazardous Waste (HHW) Extended Producer Responsibility (EPR) law. The deadline for registration was November 1, 2025, and the state may restrict sales for any producer that has not yet registered. Restriction is subject to state enforcement under Vermont law so producers are encouraged to confirm their status and obligations with their legal counsel.

Producers that participate in Interchange 360’s Vermont program can meet the compliance requirements for the state. If you have not already done so, complete our Vermont Participation Agreement and register for the Vermont program in The Vault. Our Member Services team will then work directly with you to make sure you meet the requirements including registering, reporting, and remitting fees. Interchange 360’s role is administrative and is offered as a service to producers to assist with compliance. Producers must still make their own determinations on how best to meet their legal obligations.

There are important and unique benefits to participating in the Interchange 360 program, including:

• Compliance Efficiency: For producers across the petroleum and lubricants supply chains (including related packaging and services), the Interchange 360 program is designed to streamline compliance processes and reduce duplicative reporting. These efficiencies can also lower administrative costs and burdens.
  
• Simplified Reporting: Report through The Vault, just as you would for other state programs you are participating in through Interchange 360.
  
• Standardized Invoicing: You will receive invoices and make payments to Interchange 360 just as you would for other programs.
  
• Long-Term Consistency: The state will allow independent stewardship organizations in 2030, and possibly before. Interchange 360 plans to operate as such as soon as the law allows. Participating in the program now ensures a smooth transition down the road. As timelines evolve, we will update producers on recognized compliance options. Interchange 360 will continue to focus on administrative consistency rather than influencing market behavior.
  
• Industry Expertise: The Interchange 360 team has decades of dealing specifically with petroleum and lubricant EPR programs. We will work to ensure the industry is fairly represented in the overall HHW program with the state. Our engagement focuses on accurate compliance administration and transparent reporting.

If you missed the November 1 deadline, reach out to our Member Services team as soon as possible for assistance. We can help you understand available compliance pathways and next steps under state law.

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