October 15, 2021

End-of-Life: Solar Panels

In 2020, solar energy accounted for about 40% of new United States electric generation capacity, and overall, 3.3% of electricity in the United States was produced from solar energy. As the solar photovoltaic (PV) market grows, so does the volume of end-of-life solar panels. It is estimated that by 2030 the United States will expect to see at least 1 million tons of solar panel waste. There is more information on the solar panel waste projections in the International Renewable Energy Agency report on end-of-life solar panel management.

When a solar panel will be disposed of, it becomes a solid waste. The generator is then required by §262.11 to determine whether the solar panel is a hazardous waste. In general, solar panels may be characteristically hazardous, depending on what materials were used to manufacture the solar panels. If materials like cadmium or lead are at high enough concentrations to fail the toxicity characteristic leaching procedure (TCLP), the panels will be hazardous waste when sent for disposal. The U.S. Department of Energy (DOE) has a web page on the types of solar panels and what materials are used in their manufacture, which is helpful when making hazardous waste determinations. EPA recommends homeowners with solar panels contact their state/local recycling agencies for more information on disposal and recycling.

If you decide to recycle your solar panels, one of the recycling exclusions may apply. If you can qualify for one of these exclusions, your solar panels may not be solid waste when recycled. Even if you cannot qualify for one of the recycling exclusions, you may still recycle your solar panels, but they must be managed as solid, and potentially hazardous, waste. As with all recycling determinations, it is prudent to check with your state before proceeding.

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Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.

This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.