States

Vermont

Compliance Program Option

EPR for Household Hazardous Waste

State Overview

Vermont’s Household Hazardous Waste (HHW) Extended Producer Responsibility (EPR) Law is the only statewide HHW EPR program in the country and it includes many petroleum and automotive products. It is also the only program where the state will serve as the initital Stewardship Organization (SO) until additional SOs are permitted in mid-2027 that can each cover a “class” of household hazardous products.

Producer Compliance

In June 2026, H.915 was signed into law amending the original HHW EPR law and creating a pathway for organizations such as Interchange 360 to serve as SOs for a particular “class” of household hazardous products such as automotive products. However, these additional SOs may not register with state until July 1, 2027.

In the meantime, the Department of Environmental Conservation will continue to serve as the SO. Producers should review Vermont’s Covered Products List carefully as it differs significantly from other state programs. Obligated producers, if they have not done so already, should register with the state, as the deadline was November 1, 2025. It is anticipated that producer reporting will begin in early 2027. The state previously granted permission to Interchange 360 to register, report, and remit fees on behalf of producers. Interchange 360 will continue to offer this service until it is approved as a SO.

Once the state releases its Collection Plan in Summer 2026, more details will become available. There will likely be a transition required for producers of automotive products from the state SO to Interchange 360 once it is approved. Those participating in the Interchange 360 program in advance, will already be meeting their compliance requirements and will not need to change reporting systems, data requirements, or payments.

Producers can participate in the Interchange 360 Program by completing the Vermont Participation Agreement, creating an account in The Vault, and uploading the Agreement. The Member Services team will contact you directly to assist with the next steps in registration with the state.

Vermont Base Fees

Interchange 360’s efforts in Vermont are funded by producer fees. Each individual producer’s fees are based on the volume of covered materials it sells into the state versus the estimated costs of activities.  Producers are responsible for paying back to the start date of planning fees regardless of their join date. To learn more about fees, visit our Producer Fees/Dues page.

If you have any questions, please contact our Member Services team.

EPR Law Passed	Planning Fee Dates	Planning Fees	Implementation Fee Start Date	Implementation Fees
2023	January 1, 2025 – present	$0.14/gal	July 1, 2027	TBD

Notice of Fee Changes – July 2026