Skip to content
Contact Us
State Response

Vermont

The Vermont Household Hazardous Waste (HHW) Extended Producer Responsibility (EPR) Law (Act 58 of 2023 and Act 59 of 2025) was enacted for manufacturers to fund the collection system of covered materials and provide public education and outreach to consumers on how to recycle such products.  

As no initial independent Stewardship Organization (“SO”) was selected by the state, the program will be run by the Vermont Agency of Natural Resources (“ANR”). As such ANR has the full responsibility of administering the program. 

Effective November 1, 2025, a producer may not sell, offer for sale, or deliver to a retailer for sale any covered product unless registered with the state. Producers who have signed a Participation Agreement with LPMA will be registered with the state by LPMA.

How To Register:

By signing LPMA’s Vermont Participation Agreement, the producer grants authority to LPMA to: 

  1. Register on its behalf with ANR in Vermont.  LPMA will notify each participating producer once they have been registered and/or if there were any issues with the registration process.
  2. Provide the ANR with any required information necessary to complete registration, including producer name, contact information, brand names, and product names. (ANR Registration)
  3. Report and remit fees on behalf of the producer. 
  4. Provide the ANR with any required information necessary for reporting, including what may be considered confidential. Such information may include sales data.  

Completing the Participation Agreement allows LPMA to register in Vermont on behalf of producers.

Login or create an account in The Vault, select the Vermont program, fill out the required information, and upload the Participation Agreement.

Participating producers will report and remit fees directly to LPMA. LPMA will in turn report the necessary data and information required by law to the ANR. LPMA will notify each producer once their report has been filed, along with any issues that may have prevented a successful filing. If a report was rejected, LPMA will inform the producer of any corrections needed in a timely manner. LPMA will also be responsible for remitting the share of participant producer fees to ANR, along with meeting any deadlines to do so set by the Act and/or the ANR. LPMA will notify participating producers once the fee has been paid or if there were any outstanding issues with submitting payment and any corrections that are required.  

What it Means for Producers of Petroleum, Lubricants, and Automotive Products 

Producers should carefully review the list of covered products under the Vermont HHW EPR law. Covered products include items such as automotive products and cleaners, degreasers, lubricants, and motor oil in their original container. Producers that manufacture such products that are regularly used or purchased to be used for personal, family, or household purposes need to register by November 1, 2025 in order to be included on LPMA’s list of Registered Producers.

Note: Producers should also check with their own legal counsel and review the state law and regulations directly to determine their own obligations.

EPR Fees/Dues Reporting and Remittance

Producers are reminded that Planning Fees for Vermont went into effect as of January 1, 2025. Members and Participants report sales data by state and calculate their total remittance owing for the reporting period through The Vault, our secure online portal. Sales data reporting and payment is due 30 days after the reporting period ends.

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

Timeline

Vermont News

Vermont FAQs

Is Interchange 360 the Stewardship Organization in Vermont?

No. The EPR program in Vermont is run by the state. The Interchange 360 program is designed to assist producers with complying with state requirements and provides added conveniences through registration, reporting, and remitting fees using The Vault, the same as its other state programs.

What is the difference between a Stewardship Organization and Producer Responsibility Organization?

There is no difference. Some state laws refer to the organization running the program as a Stewardship Organization, while others call it a Producer Responsibility Organization.

Does Interchange 360 have any plans to serve as a Stewardship Organization in Vermont?

Yes. The state will start implementing a collection plan in 2027. Under the law, the first collection plan can run up to three years, after which additional Stewardship Organizations are allowed.

If I participate in the Interchange 360 program, do I still need to register with the state?

Interchange 360 will register on your behalf, however, you must provide all the information required by the state including the contact responsible for compliance, a list of all covered brands, and all covered products.

Who determines the fees?

The state will determine the fees needed to operate the program. Interchange 360 instituted a planning fee to cover the cost of the services provided. As with other planning fees, these fees will turn into credits once Interchange 360 is approved as a Stewardship Organization and the program matures.

What are producers responsible for?

In addition to reporting and remitting, producers must still make their own determinations on how best to meet their legal obligations. Each producer independently determines its own pricing, production/output, and product quality operations, among other business operation decisions.

Important Documents:

January 20, 2026 – List of producers participating in Interchange 360’s Vermont program

October 31, 2025 – Letter to DEC regarding LPMA participating producer registration

July 3, 2025 – ANR’s Covered Products List

July 2025 – Letter to DEC regarding HHW EPR Stewardship Organization registration

November 20, 2024 – Letter to DEC regarding collaborative approach to EPR for HHW

Link to Vermont Department of Environmental Conservation Household Hazardous Waste EPR page