Solar Developers: How to Meet Investor ESG Goals and Tackle Solar Panel Recycling with Your EPCs
The question of who is responsible for recycling broken and end-of-life solar panels on large-scale installation projects is becoming clearer. In most cases, the responsibility is shared. Financially, it falls on the project owners, as they are the ones who must approve change orders. Operationally, the task of recycling is typically handled by the EPC or O&M teams executing the work.
Here, we’ll explore two key aspects of solar panel recycling efforts for Developers and EPCs. First, we’ll examine scenarios where recycling occurs without pre-existing contracts, provide guidance on integrating recycling clauses into agreements, and offer tips on selecting recyclers that align with ESG goals, as not all PV recycling is equal. Second, we’ll highlight specific ESG considerations to make PV recycling that can improve compliance, metrics, and reporting.
Solar PV recycling might seem like a checkmark on a list of to-dos that you can confidently place on an ESG report, but the truth is that there are various levels of recycling, some of which range from downcycling to hardly recycling all the way to maximum materials are being recovered from your end of life panels. Investors will ultimately care about how well the panels were recycled and managed. Having a plan of what value you want to get back from your panels and what contribution you want your company to make all depends on the plan you determine, which can be reflected in your ESG reporting.
Part 1
Scenario 1 – Adding solar panel recycling to newly drafted contracts
Solar panel recycling as a contract clause between Owners, Developers, and EPCs is now becoming more commonplace. Just like the waste management clause of the contract helps direct the EPC in how to handle waste, the end-of-life (EOL) Solar Panel Recycling clause of a contract should lay out some basic parameters. For new contracts where EPCs will be held to an additional responsibility of recycling EOL PV, a few points can make the process smoother for all.
Contract consideration clauses can include the following:
Scope of recycling responsibility. Define the EPC’s responsibility for recycling PV panels, including handling transportation, logistics, and coordination with a reputable recycling vendor.
Selection of recyclers. Require that recyclers meet specific standards, such as certification under R2, e-Stewards, or equivalent programs, to ensure responsible and compliant recycling.
Compliance with regulations. Specify that recycling must adhere to local, state, federal, and international regulations, including RCRA, CERCLA, and WEEE (if applicable).
Certification and documentation. Mandate that the EPC provides certificates of recycling or destruction detailing the proper handling of materials, quantities recycled, and traceability of components.
Transparency and reporting. Require the EPC to provide regular updates and final reports on the recycling process, including ESG metrics and environmental impact assessments.
Material recovery goals. Include language that uses recyclers who maximize material recovery, such as silicon, glass, and metals, to enhance environmental value and ESG reporting.
Liability for improper disposal. Clarify liability if panels are not recycled properly, ensuring the EPC is accountable for any environmental violations or associated penalties.
Costs and budget allocation. Define who bears the financial responsibility for recycling, whether it’s included in the EPC’s budget or requires a separate change order.
Timeframe for recycling. Establish timelines for when panels must be removed and recycled, aligning with project milestones or decommissioning schedules.
Vendor approval process. Allow the owner/developer to approve the chosen recycling vendor, ensuring alignment with project-specific ESG and compliance goals.
Decommissioning coordination. Integrate the recycling clause with decommissioning plans to ensure seamless execution when panels reach the end of their life.
Third-party audits. Consider adding a provision for third-party audits to verify compliance with recycling standards and ESG requirements.
Recycling of non-operational panels. Include specific provisions for recycling broken or damaged panels during installation, testing, or commissioning phases.
Termination and breach clauses. Define consequences if the EPC fails to meet recycling obligations, including potential penalties or contract termination.
Scenario 2 – The Developer & EPC contract does not already address solar panel recycling
In scenarios where a contract has already been signed and executed, the solar recycling clause was not added to the contract, it’s important not to discount the moment, as there is still an opportunity to work with your EPC to make arrangements for solar panel recycling. This is a common scenario happening today as many contracts have already been executed but lack a recycling clause.
In this situation, taking a collaborative approach with your EPC is the best bet. Work with a facility that will guide and instruct the EPC toward best practices. Here is a sequence of actions you can take to help your EPCs take responsible action for recycling panels, even if there isn’t a clause in your agreement to do so.
Be prepared for change orders. Anticipate the need for a change order to include panel recycling in the project scope. Be ready to negotiate terms and allocate a budget for this adjustment.
Navigate cost-minimizing options. Explore cost-effective recycling solutions, such as bulk transportation or partnering with nearby projects, to reduce the financial burden on both parties.
Provide a list of approved recycling vendors. Supply the EPC with a vetted list of reputable recycling facilities that meet industry certifications like R2, e-Stewards, or equivalent, ensuring compliance and responsible recycling practices.
Support palletizing and loading efforts. Offer guidance or assistance to the EPC team on how to properly palletize and load PVs for safe transport to recycling facilities, reducing the risk of damage and streamlining the process.
Meet with the EPC team. Hold a meeting with the EPC team to understand their perspective, capabilities, and concerns regarding panel recycling. This helps build rapport and aligns expectations.
Offer support to streamline the process. Ask the EPC what measures, such as additional resources, logistical support, or training, you can provide to make the recycling process smoother and more efficient.
Leverage recycling as a competitive edge. Encourage the EPC to view panel recycling as a marketable advantage, showcasing their commitment to sustainability and ESG goals, which could differentiate them from competitors.
Educate on ESG benefits. Highlight the positive ESG implications of recycling and how it can contribute to enhanced reporting, investor confidence, and overall project reputation.
Share industry best practices. Provide the EPC with insights into industry standards and best practices for panel recycling, emphasizing the long-term benefits for both parties.
Establish a recycling timeline. Work with the EPC to create a feasible timeline for panel recycling, ensuring it aligns with project schedules and minimizes delays.
Collaborate with local partners. Explore partnerships with local recyclers or organizations that can facilitate the recycling process, potentially reducing costs and logistical challenges.
Incorporate recycling into future contracts. Use this opportunity as a learning experience and ensure that all future contracts include clear recycling clauses to avoid similar situations.
Engage third-party experts. Consider involving recycling consultants or third-party experts to guide the EPC on compliance, logistics, and cost-effective recycling solutions.
Promote a collaborative approach. Promote a collaborative atmosphere with the EPC, emphasizing shared responsibility and mutual benefits rather than assigning blame for the lack of initial planning.
Highlight regulatory risks. Inform the EPC about potential regulatory risks and liabilities associated with improper disposal, underscoring the importance of compliance with waste management laws.
Provide data and case studies. Share examples of successful recycling efforts from other projects to inspire confidence and show that recycling is feasible and beneficial.
Encourage reuse opportunities. If panels are still functional, explore reuse options with the EPC, such as donating them to community projects or refurbishing them for secondary use.
Monitor progress and outcomes. Stay actively involved in the recycling process, tracking progress and ensuring that materials are responsibly handled and documented.
Scenario 3 – Choosing a recycler – scrap metal to full scope
These days, you have to know what to look for in a recycler (use this qualifying checklist). Receiving a recycling certificate or a certificate of destruction for your solar panels doesn’t tell the entire story of where the individual materials like glass, aluminum, copper, silver, silicon, antimony, and other items went. When you are paying for recycling, you want to get the most out of the arrangement. So, when your EPC is narrowing down a choice of vendors, here are the many PV recycler scenarios you will run into.
Scrap metal or auto shredder recyclers. These recyclers often only extract the aluminum frames from solar panels while discarding the remaining components, such as glass, plastic, and silicon, into landfills. This approach fails to address the full recycling potential of the panels.
Downcycling solar glass into cement. Some recyclers specialize in breaking down solar panel glass to be used as an additive in cement production. While this keeps materials out of landfills, it results in a lower-value product that doesn’t maximize material recovery.
PV recycling brokers. Brokers are important; they are the movers and shakers that help keep solar panels moving and get recycled. Make sure if you’re using a broker, they are choosing downstream partners with proper infrastructure and processes to ensure responsible recycling.
Facilities without transparency. Beware of recyclers claiming to recycle entire panels but lacking transparency. Certain recyclers advertise full-panel recycling but cannot provide proof of where materials, like glass, end up. Often, a significant portion of these materials is sent to landfills, undermining claims.
Recyclers shipping panels overseas. Some recyclers follow responsible handling standards but rely on shipping solar panels to other countries for processing, raising concerns about transparency and the environmental impact of long-distance transport, even with R2 compliance.
Solar recyclers focused on R2 Standards and innovation. These recyclers prioritize advancing their recycling processes through R&D to improve material recovery rates. They aim to keep materials within North America, supporting domestic manufacturing and aligning with circular economy principles. They’re also focused on maintaining stands like R2.
Part 2. PV recycling considerations for ESG reporting
For renewable energy projects, having thorough ESG Reporting will require working with future-proof PV recycling vendors. Developing a comprehensive ESG strategy is essential for solar developers aiming to attract investors, meet regulatory requirements, and ensure sustainable operations. Whether you’re repowering, recommissioning, decommissioning, or commissioning solar projects, you will want to stay adaptable. This means being proactively prepared to handle end-of-life materials responsibly and understanding what a valuable ESG report will be for your needs. Let’s talk about getting the most out of your solar project panel recycling. We wanted to share some factors to consider when implementing solar panel recycling efforts into your ESG strategies and reporting.
Environmental metrics beyond recycling
Recycling metrics are an important part of ESG strategies, but solar developers must account for broader environmental impacts. Transportation emissions, for instance, play a significant role. Studies show that transporting materials long distances can drastically increase carbon emissions. For example, shipping solar panels from the U.S. to other countries worldwide for processing accounts for 1.6% of total embodied emissions. It is essential to verify where recyclers send processed materials. Are they partnering with local, modern facilities, such as smelters powered by renewable energy, or relying on outdated coal-fired plants? This downstream transparency is crucial to reducing lifecycle emissions.
Adopting lifecycle assessments ensures that panels are manufactured, installed, and decommissioned with minimal environmental impact. Ensuring that recyclers employ advanced recovery technologies that reclaim up to 95% of a panel’s materials is critical to reducing waste. Supply chain transparency is equally important. According to the International Renewable Energy Agency (IRENA), recyclers should provide detailed documentation of where recovered materials, such as silica or rare earth metals, are processed.
Social responsibility in solar recycling
ESG isn’t just about environmental metrics; social considerations in recycling operations and labor practices are equally critical. Verify whether recyclers adhere to SA 8000 standards, which cap working hours at 60 per week and ensure workers are paid a living wage. Exploitative practices, such as excessive overtime or below-minimum-wage pay, should raise red flags. Additionally, ensure that downstream operations do not exploit vulnerable populations, including prisoners or children. The U.N. International Labour Organization (ILO) warns that e-waste programs in some regions have historically relied on child labor for informal recycling.
Legitimate reuse practices are another critical consideration. Some facilities claim to refurbish and resell panels but instead operate as fronts, selling defective equipment to unregulated markets. Verifying their processes and partnerships for reusing panels is essential. Reports from R2-certified recyclers show that legitimate facilities have clear relationships with buyers and detailed testing procedures for reused panels (R2 Certification Standards). Evaluating the social impact of your recycler’s operations on the local community is also important. Are they creating jobs and economic opportunities, or are they contributing to exploitative practices?
Governance, transparency and accountability
Solar developers should partner with recyclers that demonstrate clear, auditable processes. Certifications like R2, e-Stewards, or ISO 14001 guarantee adherence to environmental and social standards. Transparency in ESG reporting is critical for building trust with investors. According to the Solar Energy Industries Association (SEIA), recyclers must provide comprehensive reports on emissions, recovered materials, and downstream operations. Regularly updating investors on ESG progress using metrics such as tons of recycled materials, emissions reductions, and compliance with labor practices showcases alignment with sustainability goals.
Investor considerations and the role of ESG in financing
Investors increasingly prioritize ESG factors when evaluating solar projects. According to PwC, ESG-focused institutional investments are seen soaring 84% to US$33.9 trillion in 2026. A strong ESG framework not only ensures compliance but also opens doors to green financing and institutional investors. Demonstrating leadership in ESG metrics can differentiate your company in a competitive market.
By integrating these considerations into your ESG strategy, solar developers can better meet investor expectations and contribute to meaningful single and double materiality for their organizations. A thorough approach to ESG ensures long-term sustainability, reduces risks, and enhances stakeholder trust, positioning your project’s protocols as leadership and competitive edge moves.