How to Determine if Your Solar Panel Contains Hazardous Waste and What to Do About It
Solar is proving to be as resilient in adoption as it is in nature. Powering through federal uncertainties, solar energy continues to provide more of the world with energy independence and clean, renewable energy from the sun. The results of reducing sole reliance on fossil fuels, decreasing carbon emissions, and providing potential cost savings on residential, C&I electricity bills, providing opportunities in the potential to sell excess power back to the grid, environmental sustainability, low maintenance costs, and potential property value increase; are only some of the reasons solar is here to stay as a prevalent energy source. Like any type of material and packaging materials, how to handle the materials once their life is over is a top priority for our team at Solar eWaste Solutions. While solar panels are quite incredible and designed to be safe and durable during their use, their material composition or solder points may classify them as hazardous waste under certain conditions. Here’s what you need to know about determining whether your solar panels are hazardous waste and how to handle it responsibly.
When it comes time to dispose of your project’s solar panels that are determined to be hazardous waste, you’ll want to follow the regulations under the Resource Conservation and Recovery Act (RCRA) to make sure the panels are safely recycled or disposed of.
What makes solar panels hazardous waste?
Source: ResourceGate
Solar panels are considered solid waste when discarded, but whether they are classified as hazardous waste depends on their composition and the results of specific testing. These modules are encased in layers of adhesive-like poly(ethylene-co-vinyl acetate) (EVA), protected on the back with polyethylene terephthalate (PET) and poly(vinyl fluoride) (PVF) sheets, topped with glass, and framed in aluminum. Once assembled, the modules are integrated into full-size panels. According to the EPA, hazardous waste classification typically hinges on whether a panel exhibits one of the following characteristics:
What makes solar panels hazardous waste?
Depending on the solar panel’s composition and the results of specific testing will determine whether your panel is classified as hazardous waste or solid waste. It’s important to remember PVs are encapsulated in layers of glue-like poly(ethylene-co-vinyl acetate) (EVA), covered with a back sheet of polyethylene terephthalate (PET) and poly(vinyl fluoride) (PVF), topped with glass, and surrounded by an aluminum frame. According to the EPA, hazardous waste classification typically hinges on whether a panel exhibits toxicity and ignitability, reactivity, or corrosivity.
Toxicity. Many solar panels contain metals like lead, cadmium, telluride, or selenium, which can leach into the environment if not properly managed.
Ignitability, reactivity, or corrosivity. While less common, panels meeting these criteria may also be hazardous.
The Toxicity Characteristic Leaching Procedure (TCLP) is used to determine if a solar panel is a hazardous waste. This test simulates landfill conditions to see if toxic metals leach out at levels exceeding regulatory limits. For example, lead concentrations exceeding 5.0 mg/L in the TCLP extract classify the panel as hazardous waste (40 CFR § 261.24).
Key EPA Guidance is as follows
The generator—the entity removing the panel from service—is responsible for conducting hazardous waste determinations.
Some panels are known to exceed TCLP limits for lead, cadmium, or selenium, making them hazardous waste.
TCLP testing can be substituted with “generator knowledge,” which includes information about the panel’s composition and manufacturing process.
Steps to determine if your solar panel is hazardous waste
Identify the module’s composition. Sourcing the manufacturer data sheets or material safety data sheets (MSDS) will help identify if the panels consist of potentially hazardous components like lead or cadmium.
Conduct TCLP Testing. If there is insufficient knowledge of the panel’s composition, perform TCLP testing to determine leachate toxicity levels. This is especially important for panels removed during large-scale decommissioning projects.
Apply EPA’s recycling exclusions. Panels sent for legitimate recycling under specific exclusions (e.g., 40 CFR section 261.4(a)(23)) do not require a hazardous waste determination. Check whether your state has adopted these exclusions.
Document Your Process. Request detailed records from your PV recycler to confirm testing and decisions regarding the classification of your panels, ensuring compliance and reducing liability.
What to do if your solar panel contains hazardous waste
Proper management is critical to avoid environmental harm and legal penalties if your panel is classified as hazardous waste. Here are the steps to take.
1. Identify approved facilities
Hazardous waste panels must be sent to an RCRA-permitted hazardous waste facility or a legitimate recycler. The EPA encourages recycling because critical minerals like silicon, aluminum, and copper can be recovered.
2. Comply with transportation requirements
Ensure panels classified as hazardous waste are transported under a manifest system in compliance with federal and state regulations. This ensures traceability from your site to the recycling facility and further downstream, where materials go to the secondary market.
3. Understand Universal Waste Standards
Currently, solar panels are not federally classified as universal waste, but some states (e.g., California) have included them in state-specific universal waste programs. Managing panels as universal waste can simplify compliance in those states. The EPA is looking to designate solar panels as universal waste federally.
4. Partner with Vetted Recyclers
Work with recyclers that meet the criteria, provide traceability, and ensure transparency and documentation. Ensure the recycler manages hazardous residuals responsibly.
Use this checklist to validate your recycling partners: A Checklist for Solar Owners to Perform Due Diligence on Solar PV Recyclers.
What are the risks of mismanaged Solar PV Panel Waste?
Failing to properly classify and manage hazardous solar panel waste carries significant risks. Here are just a few.
Environmental Contamination. Improper disposal can lead to toxic leachate entering groundwater.
Regulatory Fines. Misclassifying hazardous waste as non-hazardous can result in hefty penalties under RCRA.
Reputational Damage. Poor waste management practices can harm your brand’s reputation and public trust.
To avoid these risks, solar developers and installers can develop robust waste and recycling management programs, partner with experienced solar eWaste recyclers with environmental professional experience.
How a vetted recycling facility can help
Recycling solar panels reduces environmental risks and captures valuable materials. Aluminum frames are just a start when it comes to recycling solar PV panels, but copper, glass, silicon, antimony, and silver should also be recycled.
The EPA emphasizes the importance of distinguishing between legitimate recycling and practices that shift waste to less regulated regions. Here’s what reputable recyclers will do.
1. Demonstrate compliance with all hazardous waste regulations.
2. Perform appropriate tests to determine if a panel should be classified as hazardous waste.
3. Provide documentation of recycling activities and residual waste management.
4. Avoid speculative accumulation or improper resale to secondary markets.
Improving solar panel recycling waste management
To improve end-of-life (EOL) recycling management for solar modules, the EPA is drafting new rules to classify solar panels as universal waste under 40 CFR § 273. This would streamline recycling processes, encourage innovation in recycling technologies, and reduce the regulatory burden on generators. Until then, you’ll want to stay proactive and stay informed about federal and state regulations to stay in compliance, or you can consult with the Solar eWaste Solutions team by contacting us.
Managing solar panel waste responsibly ensures compliance with environmental regulations and protects public health and natural resources. You can mitigate risks by identifying whether your solar panels are hazardous and following EPA guidelines for disposal or recycling. If in doubt, consult with our value recovery experts at Solar eWaste Solutions to navigate this complex landscape effectively for your organization.