Developing circular economy policies to accelerate solar deployment

SolarPower Europe Position Paper

6 November 2025

This paper serves as SolarPower Europe's consultation response on the EU's Circular Economy Act.

SolarPower Europe welcomes the European Commission’s initiative to advance the Circular Economy Act, recognising its strategic relevance for the solar PV sector. As the EU prepares for increasing PV waste volumes in the 2030s, it is essential to define circular economy policies now, which will enable the efficient handling of solar PV waste and the recovery of strategic and critical raw materials. Achieving EU energy security and decarbonisation goals continues to be a top priority. Therefore, circular economy policies should be developed in a way that do not hinder the deployment of solar technologies. 

 

Please see our full response in the following position paper and questionnaire.

SolarPower Europe's recommendations are summarised below:

Single Market

To unlock economies of scale and reduce recycling costs, the Circular Economy Act should establish a single European market for waste, and create the enabling conditions for trans-regional recycling hubs. This can be supported through 
facilitating intra-EU cross-border waste transportation for the purpose of recycling and recovery. Solar PV panels should also be classified as non-hazardous waste across all Member States. In addition, the European Commission must establish a level-playing field for recycling and Member State-wide harmonisation.

1

Build support

Beyond an efficient single market for waste the EU should take additional measures to support the development of the European circular economy. For this we strongly encourage the EU to develop public awareness campaigns on the benefits of PV recycling a lack of information and often misinformation is prevalent among consumers. Furthermore, Member States should support licensing and infrastructure development for PV recycling operations at the national level to encourage the establishment of PV recycling hubs.

2

Critical Raw Materials

Developing diversified and resilient supply chains for secondary raw materials within the European Union starts at enabling and encouraging the recovery of strategic and critical raw materials from high-potential waste streams. Within the scope of the Waste Electrical and Electronic Equipment (WEEE) revision, the European Commission should set realistic and feasible collection and recycling targets for solar PV panels and inverters based on material value, technological feasibility and strategic importance, not weight alone. Furthermore, any further commitments aimed at improving material recyclability must be developed in close collaboration across the entire value chain. The Circular Economy Act and the WEEE revision should be also carefully aligned with the upcoming Ecodesign Regulation.

3

Our paper builds on our 2023 position for the Waste Electrical and Electronic Equipment (WEEE) Directive and outlines our updated recommendations for the Circular Economy Act.

 

We reaffirm the following three principles from our 2023 submission: 

 

  1. Alignment with EU Legislation
  2. Harmonisation across Member States
  3. Material-specific targets for solar PV
A future-proof end-of-life framework for solar PV

Aligned and coherent framework with relevant EU legislation. Address lack of harmonisation. Apply tailored provision.

Read the paper
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