A Checklist for Solar Owners to Perform Due Diligence on Solar PV Recyclers
With the adoption of great large-scale solar power projects comes great responsibility. We receive many calls from solar owners nationwide looking for guidance on understanding their responsibility in the end-of-life requirements for their solar panels. While the lifespan of most solar panels ranges from 20 to 30 years, the industry is already facing an increasing volume of panels reaching retirement or being swapped out for more efficient modules, and solar owners want to be prepared to handle their modules responsibly. We’re sharing this information to help more solar owners prepare for end-of-life.
Our conversations with solar owners rapidly develop into a focus on wanting to do things right and making plans today for the future. They’re interested in preparing for management down the road, not just to manage waste but to recover valuable materials like silicon, silver, and aluminum. As friendly experts in the space, it’s our responsibility to share the lay of the solar recycling land, that not all recycling options are created equal, and solar owners must perform due diligence when selecting recyclers. The Superfund Recycling Equity Act (SREA) also plays a critical role in guiding this process and ensuring compliance with environmental laws. Here’s why due diligence is essential and what solar owners need to know about the SREA.
The risks of inadequate recycling practices
When price shopping for a solar recycler, it might seem adequate to compare pricing, but there are more checklist items to consider to ensure risk management and that a) recycling of your panels is actually taking place and b) the greatest possible amount of material is being recovered. Here are three major risks that arise.
Environmental harm
About 97% of materials in solar panels can be recovered, but improper handling can prevent this recovery and increase environmental risks. Improper recycling or disposal of solar panels can potentially lead to the release of hazardous substances, such as cadmium and lead, into the environment. Selecting a recycler without verifying their practices could inadvertently contribute to environmental damage.
Reputational damage
A KPMG survey found that 70% of U.S. CEOs said their ESG programs improved their companies’ financial performance, highlighting how critical responsible recycling partnerships are. As sustainability becomes a core value for businesses and homeowners, associating with a recycler engaged in unethical or illegal practices could harm your reputation.
Legal liability
Inadequate recycling practices could expose solar owners to legal risks. If a recycler improperly disposes of panels, owners could potentially be held accountable under federal or state environmental laws.
What Is the Superfund Recycling Equity Act, and how does it apply to solar recycling?
The Superfund Recycling Equity Act, enacted in 1999, was designed to clarify the liability of entities involved in recycling materials that might otherwise be classified as hazardous waste. Under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), parties involved in hazardous waste disposal can be held responsible for cleanup costs. The SREA provides an exemption for certain recyclers, provided they meet specific criteria.
Here’s how the SREA applies to solar recycling
While the SREA aims to encourage recycling by limiting liability, solar panel owners must still ensure that their chosen recycler adheres to the act’s requirements, which include the following.
Material verification
Recyclers must verify that the materials they accept are intended for recycling and not disposal.
Compliance documentation
Recyclers should provide documentation to demonstrate their adherence to applicable federal, state, and local environmental regulations.
Proper processing facilities
Facilities used for recycling must be equipped to handle materials responsibly and prevent contamination.
By ensuring compliance with the SREA, solar owners can avoid liability for cleanup costs and participate in more responsible recycling efforts.
Solar Owner’s Checklist for Hiring a Qualified PV Recycler
Some recyclers are auto shredders that only recover the metal frame; others may say they’re recyclable certain materials but cannot show proof. To safeguard against risks, solar owners should take the following steps when choosing a solar PV recycler. Download here.
Step 1 Verify Certifications
Confirm that the recycler is certified by recognized organizations, such as the Responsible Recycling (R2) and/or ISO standards. (Please note these are new certifications and are being implemented over the next 36 months)
Step 2 Request Transparency
Ask recyclers for detailed information about their processes, including how materials are handled and what percentage of materials are recovered. Thorough knowledge of the use is always helpful in transparency.
Step 3 Research Compliance History
Look up the recycler’s compliance record with environmental laws and regulations. Use tools like the Environmental Protection Agency’s (EPA) Enforcement and Compliance History Online (ECHO) database to verify the recycler’s compliance status. The online status may take many months to update, so another method can be calling the compliance inspectors assigned to a facility and conducting a brief interview to verify no changes or updates in compliance status are suggested.

Step 4 Assess End Markets
Ensure the recycler has established markets for recovered materials and is not simply landfilling or exporting waste to countries with weaker environmental protections.
Step 5 Understand Liability Protections
Confirm that the recycler’s operations align with the SREA to protect yourself from potential liability.
As solar owners gain a better understanding of end-of-life processes, potential risks, and best practices, they become active participants in raising industry standards for material recovery. By conducting due diligence and familiarizing themselves with the requirements of the Superfund Recycling Equity Act, solar owners can ensure their panels are recycled ethically, sustainably, and in compliance with environmental laws. Following this approach and using the checklist provided helps protect the environment while shielding solar owners from reputational and legal risks. Choosing the right recycler goes beyond financial considerations; it represents a commitment to reducing waste and risk, supporting the solar industry’s efforts to secure necessary materials for domestic manufacturing and long-term growth.
