Background

· Exponential growth in solar PV installations across Europe

· Millions of panels now reaching end-of-life phase

· By 2030, EU solar waste expected to exceed 1 million tonnes

· Concerns over hazardous substances: lead, cadmium, fluoropolymers

· Lack of recycling = loss of critical raw materials

WEEE Directive Legal Framework

· Directive 2012/19/EU: Waste Electrical and Electronic Equipment (WEEE)

· Solar PV panels added to scope in August 2012

· Full producer responsibility enforced from 2014

Scope

· Applies to all solar PV modules placed on the EU market

· Includes crystalline silicon, CdTe, and CIGS panels

· Covers household and commercial installations

· Applies to both EU-based and foreign manufacturers and importer

Objectives

· Environmental Protection: Prevent pollution from hazardous substances like lead and cadmium in end-of-life solar panels

· Resource Efficiency: Promote recovery of rare and valuable materials such as silver, indium, and tellurium

· Producer Responsibility: Make producers accountable for managing the entire lifecycle of their products

· Circular Economy Support: Encourage design-for-reuse, extended product lifespan, and sustainable recycling markets

· Data Transparency: Ensure accurate tracking and reporting of PV panel waste volumes and recycling performance.

Producer Obligations

· Register in national WEEE registry

· Finance collection, treatment, recovery, and recycling

· Provide information on dismantling and reuse

· Submit annual reports on quantities placed and recycled

Thresholds and substance coverage

· WEEE focuses on equipment, but other EU laws apply to substances:

o RoHS: lead, mercury, cadmium, PBDEs, phthalates

o REACH: SVHC reporting >0.1%

o Battery Directive: lithium, cobalt (if storage is included)

· Key panel hazards: lead, cadmium, selenium, fluoropolymers

Collection & Recycling Targets

· Minimum collection rate: 65% of equipment placed on the market

· Minimum recovery rate for PV: ~85% (varies by panel type)

· Focus on material reuse and recovery of rare earths and metals

Are solar panels recycled in Europe?

· According to a Yale Environment 360 report, only around 10% of solar panels are currently being recycled in both the United States and the European Union.

· This low rate persists despite the EU’s regulations mandating solar panel recycling, largely due to the high costs and technical challenges involved.

Can solar waste be recycled?

Materials like glass, gallium and other useful organic components can be successfully recycled from a GaAs solar cell by using methods like nitrogen pyrolysis and vacuum decomposition.

What is the lifespan of a solar panel?

· Solar panels typically have a lifespan of 25 to 30 years, although they can continue to operate for longer periods with some efficiency loss.

· Their efficiency gradually declines over time, with a common rate of 0.5% to 0.8% per year. Even after 25 years, panels may still produce around 85% of their original output.

What will happen to solar panels after 25 years?

· After 25 years, solar panels typically continue to function, but their efficiency and electricity output decline. While they may not be as efficient as when new, they still generate power and can provide substantial savings.

· The “useful life” of a solar panel is considered to end when its output falls below 80% of its initial capacity, but it can still generate power for many years beyond that.

Potential for Replacement or Upgrade

· At the 20–30-year mark, you might consider replacing or upgrading your solar panels, which could involve replacing individual panels, upgrading to newer, more efficient panels, or adding new panels or a battery for improved performance

Disposal and Recycling

· When solar panels reach the end of their useful life, it’s important to dispose of them properly. Certified recycling facilities can extract valuable materials and prevent toxic waste.

· Many manufacturers also offer take-back programs

Technology

· Traceability Tools: Use of barcodes, QR codes, and digital product passports for tracking panels

· AI & Robotics: Automated dismantling of panels to recover materials more efficiently

· Advanced Recycling Methods: Thermal, chemical, and mechanical processes to extract silicon, silver, and rare metals

· Data Platforms: Digital systems to monitor collection rates and report EPR compliance in real time

· Blockchain Pilots: Transparent record-keeping for product origin, lifespan, and recycling history

Benefits

· Environmental Protection: Reduces pollution by ensuring safe handling of toxic substances like lead and cadmium

· Circular Economy Enablement: Encourages reuse and recycling, reducing reliance on raw material extraction

· Design Innovation: Incentivizes development of eco-friendly and easily recyclable panel technologies

· Green Job Creation: Expands employment in recycling, refurbishment, and compliance sectors

· Landfill Reduction: Diverts millions of tons of solar waste from landfills each year

· Brand & Regulatory Advantage: Enhances producer credibility and ensures compliance with EU laws

Challenges Faced by Solar PV Manufacturers

1. Financial Burden of EPR Compliance Producers, especially small and medium enterprises (SMEs), find it costly to finance the collection, treatment, and recycling of waste solar panels, as required under Extended Producer Responsibility (EPR).

2. Complex Multi-country Registration Each EU Member State has its own WEEE registration procedures, making it administratively difficult and time-consuming for manufacturers operating across borders.

3. Designing for Compliance Many older panel designs contain hazardous substances (e.g., lead, cadmium), which do not meet current eco-design or RoHS standards, complicating recycling and legal compliance.

4. Take-Back Logistics Setting up or coordinating infrastructure to collect and return end-of-life panels, especially from remote or residential installations is a logistical and financial challenge.

5. Recordkeeping and Reporting Manufacturers are required to track how many units they place on the EU market and how much waste they take back and recycle. Accurate reporting is complex and requires robust systems.

Solutions for Manufacturers to Comply with WEEE

1. Join Collective Producer Schemes By participating in a collective scheme (e.g., PROs – Producer Responsibility Organizations), manufacturers can share compliance costs, reduce the per-unit burden, and simplify logistics like collection and recycling.

2. Use Authorized Representatives Hiring local compliance experts helps manufacturers manage registration and legal obligations across different EU member states, avoiding duplication and legal errors.

3. Adopt Eco-Design Principles Designing solar panels using recyclable materials and avoiding restricted substances (as per RoHS Directive) makes it easier to comply with WEEE and improves recyclability at end-of-life.

4. Partner with Compliance Schemes & Logistics Firms Outsourcing tasks such as take-back and proper disposal to certified partners ensures compliance while saving manufacturers from building complex infrastructure themselves.

5. Use Digital Tools & Reporting Platforms Automation tools help manufacturers track placed-on-market volumes, recycling rates, and generate compliance reports accurately and efficiently.

Incentive Schemes for Solar Panel Waste Management

· Eco-Modulation of EPR Fees Lower fees for products designed for easy recycling or containing fewer hazardous materials to reward sustainable design.

· Subsidies for Recycling Technology EU and national grants (e.g., LIFE Programme, Horizon Europe) support the development of advanced PV recycling technologies.

· Collection Bonuses Some member states offer incentives to collection centers or end-users for returning solar panels at end-of-life.

· Financial Support for SMEs Small producers may receive simplified compliance options or financial support from collective compliance schemes.

· Innovation Funding Public-private partnerships and R&D grants for creating eco-friendly panel materials and improving circularity.

Annexures I–III of the WEEE Directive

 

Annex I – Categories of EEE (Electrical and Electronic Equipment)

Defines ten categories of equipment covered by the WEEE Directive, including:

· Large household appliances

· Small household appliances

· Consumer equipment

· IT and telecommunications equipment

· Lighting equipment

· Electrical and electronic tools

· Toys, leisure and sports equipment

· Medical devices

· Monitoring and control instruments

· Automatic dispensers → Photovoltaic panels fall under Category 4: Consumer Equipment

Annex II – Illustrative Examples of Products Covered

Gives examples under each category for clarity. For solar:

· “Photovoltaic panels designed for use in a system that is permanently installed by professionals”.

· Confirms PV modules are explicitly included in WEEE scope.

Annex III – Minimum Requirements for WEEE Collection and Treatment

outlines obligations for:

· Storage and transport of collected waste

· Treatment techniques, such as removing fluids and hazardous components

· Ensuring reuse and recovery is maximized

How to Comply with the WEEE Directive in the EU?

Step.1) Register with the National WEEE Authority

· Producers must register in each EU Member State where they place PV panels on the market.

· Registration includes providing business details, product types, and volumes.

Step.2) Join a Producer Compliance Scheme (PRO)

· Producers can join authorized collective schemes that manage waste collection, treatment, and reporting on their behalf.

· These schemes ensure you meet your Extended Producer Responsibility (EPR).

Step.3) Finance Collection & Recycling

· You must cover the cost of collecting and properly recycling end-of-life solar panels.

· This may include setting up collection points or using take-back networks.

Step.4) Mark Products with the WEEE Symbol

· All PV panels must display the crossed-out wheeled bin symbol.

· It indicates the product must not be disposed of with regular waste.

Step.5) Provide Recycling Information

· Manufacturers must make available technical documentation on dismantling, hazardous parts, and treatment.

· This helps recyclers handle the waste safely.

Step.6) Report Annually

· Producers must submit annual reports on the number of units sold and collected/recycled.

· This data is sent to the national authorities or through their PRO.

Step.7) Ensure Substance Compliance (RoHS & REACH)

· Products must not contain banned substances like lead, mercury, or cadmium beyond set thresholds.

· If a substance is over 0.1%, it must be reported under REACH (SVHC reporting).

How to Comply with India’s Solar PV Waste Rules?

Step.1) Register on the E‑Waste Management Portal

· Register as a solar panel manufacturer/producer under the E‑Waste (Management) Rules, 2022 via the MoEFCC portal.

Step.2) Maintain Distinct Waste Inventory

· Record and log waste PV modules/panels/cells separately in the portal’s inventory system, up to the financial year 2034–2035.

Stp.3) Store Waste as per CPCB Guidelines

· Comply with draft CPCB rules on storage until 2034–35; follow requirements for covered, ventilated areas, impervious flooring, stacking limits, fire safety, labeling, and recordkeeping

Step.4) File Annual Returns

· Submit annual returns, including data on quantities produced, sold, and stored waste deadline each year until 2034–35

Step.5) Set Up Take-Back and Collection Systems

· Create collection mechanisms (take-back, public drop-off, or service center’s); provide helpline and web info for consumers; ensure authorized recycler integration

 

Step.6) Use Approved Transport Procedures

· Use covered transport vehicles authorized under the Hazardous and Other Wastes (Management) Rules, 2016

Step.7) Work with Authorized Recyclers

· Only engage CPCB authorized e-waste or solar recyclers; ensure recyclers follow CPCB mandating recovery requirements

Step.8) Avoid Restricted Substances

· Under Rule 16, modules must not contain >0.1 % lead or >0.01 % cadmium aligning

RoHS type limits

Key 2025 Updates on Solar Waste in EU

1. Legal Clarification on Producer Responsibility

· As of March 2024, the Council and Parliament officially amended the WEEE Directive.

· It clarified that producers are responsible for PV panels placed on the market from 13 August 2012 onward.

· This addresses confusion caused by conflicting interpretations in previous years.

2. Transposition Deadline

· Member States must transpose the new amendments into national law by late 2025.

· Producers must start complying with these updates during Q3–Q4 2025.

3. Consideration of PV as a Separate Category

· The EU is evaluating whether to create a distinct WEEE category for solar PV panels, instead of classifying them under “large equipment”.

· This could lead to more accurate recovery targets and tailored EPR fees.

4. Mandated Review by End of 2026

The amendment includes a review clause, requiring the European Commission to assess:

· Whether the WEEE framework is sufficient for managing growing PV waste,

· If a separate PV category is needed,

· And how to address export and end-of-life traceability issues.

Key 2025 Updates on Solar Waste in India

1.Draft Guidelines Issued by CPCB (June 2025)

The Central Pollution Control Board (CPCB) released draft guidelines on storage, handling, and transportation of waste solar modules and cells. These are open for public comment until June 25, 2025. Key points include:

· Mandatory covered, ventilated and impervious storage areas

· Stacking limits (max 20 layers, ≤2 metres high)

· Fire safety systems, labeled containers, and emergency response plans

· 19.5 m³/tonne minimum space for stored solar waste

2. E‑Waste Rules 2022 – Enforcement Begins

Effective April 1, 2023, solar PV modules, panels, and cells are officially classified as ‘CEEW 14’

e-waste, with the following obligations continuing through 2034–35

· Mandatory portal registration for producers

· Distinct inventory of solar waste

· Annual filing of production/sales/waste data

· Storage per CPCB SOPs

· Recycling via CPCB-authorized recyclers

3. RoHS-Exemption Clarification (Jan 2023)

The E-Waste Second Amendment Rules, 2023, added solar photovoltaic equipment to Schedule II exemptions for RoHS limits on lead and cadmium framing them with specific thresholds

4. Compliance Emphasis & Industry Input (2025)

The CPCB has actively sought industry consultation, inviting stakeholder input on the draft solar waste guidelines. This participatory approach aims to ensure practical, enforceable standards

Conclusion

· Solar energy is clean, but solar panel waste is a rising environmental concern.

· Regulations like the EU WEEE Directive and India’s E-Waste Rules ensure responsible end-of-life management of PV modules.

· ️ Key tools include Extended Producer Responsibility (EPR), eco-design, collection systems, and authorized recycling.

· Recent amendments show that governments are actively refining laws to address future waste volumes.

· Compliance is not just legal, it’s essential for resource efficiency, environmental safety, and circular economy goals.

Global PCCS Support:

● End to end support in regulatory compliance.

● Supply chain data collection and management.

● Validation of the declaration received mainly through IMDS.

● Report to customers.

● Latest updates on new regulations and changes.