As part of the ongoing revision of the Waste Electrical and Electronic Equipment (WEEE) Directive and the development of the Circular Economy Act (CEA), the European Union has a unique opportunity to address structural shortcomings in existing Extended Producer Responsibility (EPR) frameworks for solar photovoltaic (PV), which are the basis of well-functioning end-of-life management of solar PV waste.
Current EPR systems for solar PV modules vary significantly across Member States, creating fragmentation in what should be a functioning Single Market. This lack of harmonisation results in free-riding and unequal cost distribution, widely diverging EPR fees, significant administrative burden for producers, barriers to market access, and confusion among end-users and waste holders regarding proper end-of-life management. Existing implementation of EPR schemes varies greatly across Member States, including differing fee structures, reporting obligations, and operational models.
Given the rapid scale-up of solar PV deployment in Europe, it is essential to redesign EPR frameworks to provide a robust, harmonised, and future-proof basis for a Single European market for PV waste, while avoiding disproportionate additional costs or unintended disadvantages for particular technologies. SolarPower Europe, therefore, calls for a true harmonised implementation of the existing minimum requirements for EPR schemes under Article 8a of the Waste Framework Directive. We call for EPR systems that are consistent across Member States, have transparent cost allocation and governance, are smooth to comply with administratively, and are technology neutral, i.e., do not disadvantage one PV technology over another.
SolarPower Europe puts forward the following recommendations:
Categorisation
Remove the distinction between B2B and B2C PV modules
Industry-owned PV collection points
Improve the quality of collected PV modules and reduce the cost of collection by shifting the collection of PV waste modules from municipal waste collection sites to industry-owned drop-off points
Prioritise collective producer responsibility
EPR should be mainly implemented through Producer Responsibility Organisations (PROs) that collect reasonable financial contributions (i.e. recycling fees) at the time of placing modules on the market
Setting reasonable and visible financial contributions
The visible financial contribution should cover the costs of current collection, transportation, and recycling activities, and ensure the PRO can continue to operate for another five years, rather than requiring full coverage of uncertain long-term future costs
Individual producer responsibility
Individual producer responsibility schemes (IPS) should remain an option, as long as they meet the same level of requirements as PROs
Ecomodulation
Ecomodulation options must be carefully designed in a harmonised way across Member States that does not inadvertently disadvantage any PV technology or create disproportionate additional costs
Redesigning Extended Producer Responsibility for Solar PV
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