The Urgent Guide for O&Ms and EPCs to Manage End-of-Life Solar Panels
The solar industry’s commitment to sustainability goes beyond energy generation. When solar modules and their associated components reach the end of their lifecycle, project owners face the challenge of managing these solar materials responsibly. We must prepare for this line item; whether upgrading systems, handling damaged panels, or managing early retirements, addressing used solar components effectively means minimizing legal, reputational, and environmental risks.
We’re dedicated to helping solar O&Ms and EPCs navigate the complexities of used solar component management. By implementing a structured and responsible approach, you can protect your business while reducing risks and taking advantage of the recycling panel opportunities.
Why managing used solar components matters
Solar panels and all their related equipment and materials are made with valuable materials like aluminum, copper, and silver, which can be recovered for reuse or recycled. However, if mishandled, these components can also contain hazardous substances, such as lead and cadmium, that pose significant environmental and health risks. Failing to properly manage solar waste can create serious liabilities for project owners, who will look to their O&Ms and EPCs for answers. Non-compliance with regulations, such as the Resource Conservation and Recovery Act (RCRA), can result in steep fines, costly remediation efforts, and long-term legal consequences. Improper disposal practices can also harm the industry’s reputation and the company’s involved reputation, damaging relationships with investors, customers, and business partners who expect adherence to sustainable practices.
The risks go beyond immediate penalties. Failure to determine whether solar waste is hazardous or treating hazardous waste as non-hazardous can lead to future liabilities that may surface years later. Improperly disposed solar materials can cause environmental contamination, trigger civil litigation, and cause long-term financial burdens for developers. The O&M and EPCs involved can be held accountable for cleanup costs. These risks demonstrate the importance of taking proactive steps to properly assess, handle, and recycle used solar components to protect both the environment and your organization’s standing in the industry.
Steps to responsibly recycle and manage used PVs and their components
1. Develop a comprehensive plan
Evaluate your company’s risk tolerance and create a plan for managing used solar components. This should include storage, transportation, recycling, and reuse processes, ensuring compliance with federal, state, and local regulations. Contact us if you need a tailored plan created for managing your projects used solar components.
2. Prioritize proper handling and storage
If the panels are from a repower or can possibly be reused, you’ll want your team to prevent any further damage. You’ll want to ensure wood pallets are in good condition and consider protective corners to secure components during removal and transport. For panels designated for recycling, ensure no glass or hazardous materials spill during handling. When consolidating shipments, consider using a flatbed for all components if panels do not fill an entire truckload, making the most of a single haul.
Download guide: PV Packaging Instructions for Recycling & Value Recovery Solar eWaste Solutions
Download guide: First Solar PV Packaging Instructions for Recycling & Value Recovery Solar eWaste Solutions
3. Direct components to appropriate facilities
For inverters, wiring, and racking local metal scrap yards are often the best destination. Solar panels should always be sent to a vetted, trusted solar panel recycling partner. Be sure the recycler complies with certifications like R2 or e-Stewards to ensure safe and responsible handling.
4. Make sure your recycler is testing panels for reuse
If panels are intended for reuse, detailed inspections should be performed to detect defects like microcracks or other damage that could be dangerous down the line if reused. Even panels that appear intact may have hidden issues that could compromise long-term performance.
5. Vet and audit recycling vendors
Partner only with certified vendors that specialize in solar and eWaste recycling. Conduct regular audits to ensure compliance with regulations and verify their ability to manage waste responsibly. Missteps here can lead to significant financial and environmental consequences. Confirm documentation, ensure panel traceability, and make sure you have a “trust but verify” partnership with your recycler where important transparency items are shared with your compliance team.
6. Understand hazardous classifications
Conduct proper waste determinations to classify materials correctly as hazardous or non-hazardous. Misclassification can lead to regulatory penalties.
Pop quiz: If panels are RoHS compliant, are they clear from being hazardous? No, RoHS compliance does not mean the panel is free from lead or fluorine.
7. Ensure Insurance Coverage
Review your recycler’s insurance policies to confirm coverage for risks associated with transportation, disposal, and environmental liabilities related to solar waste. Proper coverage can mitigate unexpected costs and protect your company.
Best practices for responsible management
Planning for long-term compliance is essential when managing used solar components. Waste management and recycling should be integrated into the lifecycle planning of your solar projects from the beginning. By considering these processes early on, you can ensure smoother transitions when components reach the end of their life while avoiding unnecessary risks and costs.
Educating employees is another critical component of responsible management. Teams trained on safe handling techniques, regulatory compliance, and sustainable disposal practices minimize risks and ensure proper protocols are followed. Providing this knowledge empowers your workforce to handle solar waste responsibly and efficiently.
Maintaining transparency is key to building trust with clients, stakeholders, and regulators. Clear and detailed record keeping of waste handling and recycling activities should be kept at every stage. These records demonstrate compliance and reassure investors, customers, and partners that your organization prioritizes environmental responsibility.
Participating in better, verifiable recycling and end-of-life solutions helps promote industry-wide advancements, setting a higher standard for managing solar waste.
The bigger picture
Managing used solar components responsibly should focus on mitigating risks. By adopting proactive measures and vetting your solar recycling partner (here’s how), your company can reduce its liability and environmental footprint, strengthen its reputation, and contribute to a circular economy within the solar industry.
Stay tuned for part two of this series, where we’ll explore how to implement comprehensive waste management programs tailored to your organization’s needs.
Resources
https://www.epa.gov/rcra
https://www.nrel.gov/docs/fy21osti/76196.pdf
https://www.irena.org/publications/2016/Jun/End-of-life-management-Solar-Photovoltaic-Panels
https://www.nrel.gov/docs/fy21osti/78738.pdf
https://www.energy.gov/eere/solar/articles/photovoltaics-end-life-action-plan
https://www.epa.gov/hw/hazardous-waste-recycling
https://www.seia.org/initiatives/solar-pv-recycling
https://www.nrel.gov/docs/fy21osti/77669.pdf
https://iea-pvps.org/key-topics/end-of-life-management-of-pv-panels
https://dtsc.ca.gov/photovoltaic-modules-universal-waste-management