Do You Need to Worry About Hazardous Waste When Selling or Donating Solar Panels? Best Practices for Safe Solar Reuse

When dealing with used solar panels, whether from an upgrade, damage, or a transition to new technology, the ideal scenario is to extend their life by selling or donating them. Reuse supports environmental goals, conserves valuable materials, and reduces waste. However, it comes with responsibilities that must be understood to avoid legal, financial, and reputational risks.

Reuse as the preferred option under certain circumstances

Good panels deserve to have an extended life. Reuse is the ideal way to stretch the life of a working module. Before reuse, panels should be tested thoroughly to ensure they’re operable and safe. Performance testing, including flash tests and electroluminescence (EL) tests, can identify issues like micro-cracks that might not be immediately visible but could cause problems later. Panels should also be examined for any damage that could lead to fire hazards, ensuring they are safe for continued use.

Proper handling and transportation are equally crucial. Panels are delicate, and rough handling can introduce damage en route to their new home that shortens their life span. Companies should follow best practices for packing, using solid pallets, even stacking, and secure wrapping to prevent movement or cracking during transit.

Domestic reuse over overseas export

While extending a panel’s life through reuse is ideal, however where those panels are sent matters significantly. Panels reused domestically are preferable because there are adequate recycling facilities and infrastructure to recover all panels, including potentially hazardous panels. Many of the countries where panels are often shipped lack the recycling facilities or capacity to manage them at the end of their second life. When panels become damaged, non-operational, or reach the end of their usable life, they often end up in makeshift e-waste facilities in countries like Ghana, Vietnam, or India. These facilities typically lack safety controls, resulting in environmental contamination, exposure to hazardous waste, and poor recovery of materials.

For panels being sold or donated domestically or internationally, choosing reputable buyers and ensuring proper environmental practices on the receiving end is vital. Keeping detailed records of the panels’ condition at the time of transfer and documenting recipient details can also help reduce liability.

Hazardous waste risks and regulations

When modules have reached the end of their life, a waste determination must be made, and panels must be classified as hazardous or non-hazardous in order to know the protocol to follow. Panels that cannot be reused or fail performance standards may become classified as waste. The determination of whether panels are hazardous waste depends on their condition and material makeup. Solar panels contain valuable and may also sometimes contain hazardous materials, such as lead, cadmium, and selenium. If mishandled, these substances can contaminate soil and groundwater, posing potential environmental risks.

The Resource Conservation and Recovery Act (RCRA) governs hazardous waste management in the U.S. Panels sold or donated remain the liability of the original owner if mishandling occurs, even after the transfer. This is especially critical when panels are sent abroad to regions with weaker environmental protections. Poor handling, transport, or disposal can result in contamination and mirroring issues observed in unregulated electronic waste sites.

Risks of improper solar panel management

The consequences of mishandling solar panels are far-reaching. Improper transport, disposal, or processing can lead to regulatory penalties, lawsuits, and reputational damage for manufacturers, installers, and original owners. With the growing popularity of solar technology, agencies like the Environmental Protection Agency (EPA) are increasing their scrutiny of waste practices in the industry.

Solar panels categorized as hazardous waste under EPA guidelines can expose companies to severe fines if panels with hazardous materials like lead or cadmium are not managed properly. This risk escalates with overseas shipments to regions lacking adequate disposal infrastructure.

Best practices to mitigate risk

To manage solar panels responsibly and reduce liability.

  1. Ensure Safety & Operability
    Conduct thorough testing to verify the panels are fully functional before sale or donation. Techniques such as flash testing and electroluminescence (EL) can detect hidden micro-cracks, ensuring panels do not prematurely fail. Proper testing not only extends panel life but also reduces liability.
  1. Handle and Pack Securely
    Panels are delicate and prone to damage if mishandled. Use robust packaging methods, including stacking panels on solid pallets, wrapping securely, and avoiding excessive movement during transit. Following proper handling protocols can prevent hidden cracks that might render panels non-functional.
  1. Vet Buyers and Recipients
    Only work with reputable buyers or donors who adhere to proper environmental standards. Confirm their capacity to responsibly manage panels throughout their lifecycle, particularly if they’re located in regions with less stringent environmental regulations.
  1. Keep Detailed Records
    Document the condition of panels at the point of sale or donation, along with buyer or recipient details. Comprehensive records serve as evidence that appropriate precautions were taken, protecting companies from liability in case of improper handling downstream.

Extending the life of solar panels through reuse is a commendable first step in their lifecycle, but it doesn’t absolve the original owner from responsibility. Panels damaged during their second life or improperly disposed of may still be classified as hazardous waste when a waste determination is made. This may create environmental and legal challenges. Handling solar waste responsibly protects overseas reuse markets and business interests.

In some cases, recycling panels is the most responsible decision. As solar panel prices fall dramatically, overseas buyers are more attracted to new panels with a full lifespan and warranty rather than used modules. When reuse is the goal, having a trusted partner with a verified and documented process is key. When reuse isn’t feasible, having a trusted partner ensures panels are recycled responsibly, which makes the most sense.

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