Solar Photovoltaic Module End-of-Life Waste Management Regulations: International Practices and Implications for the Kingdom of Saudi Arabia

Abstract

This paper examines the end-of-life (EOL) waste management regulations and guidelines of five leading countries—China, USA, India, Japan, and Germany—to identify best practices and lessons that can enhance Saudi Arabia’s EOL waste management strategies. The study delves into China’s regulatory framework, highlighting its import bans on certain wastes, the USA’s manufacturer responsibility requirements for product disposal, India’s engagement of the informal sector in waste collection and recycling, Japan’s take-back system mandating manufacturer responsibility for product recovery and recycling, and Germany’s advanced system promoting the separate collection of EOL products and stringent hazardous waste regulations. By evaluating these diverse regulatory approaches and integrating insights from recent literature, this paper aims to provide a comprehensive perspective to assist Saudi Arabia in developing an effective EOL waste management system. Given the current state and deployment of solar PV systems in Saudi Arabia, the generation of PV solar panel waste is currently minimal. However, future projections indicate a significant increase, and it is worrisome that the KSA currently lacks the necessary systems and infrastructure to handle this waste effectively. To address this challenge sustainably, it is essential to introduce and implement an Extended Producer Responsibility (EPR) policy, develop robust recycling infrastructure, enhance public awareness and education, and foster public–private partnerships. These measures will provide a strong foundation for managing end-of-life PV solar panel waste in Saudi Arabia. Such a system would ensure environmental protection, public health, and economic growth. Moreover, the research findings could serve as a valuable resource for other countries seeking to improve their EOL waste management practices. This study underscores the importance of learning from successful international waste management practices to enhance EOL waste management systems globally.

1. Introduction

Solar photovoltaic (PV) systems have rapidly become an increasingly important source of renewable energy globally. Forecasts suggest that the worldwide capacity for solar photovoltaic (PV) installations is set to expand, potentially hitting 1630 gigawatts (GW) by the year 2030 and could escalate to as much as 4500 GW by the midpoint of the century, as shown in Figure 1 [1,2,3].

This growth in installed capacity will result in an upsurge in the volume of EOL waste produced from PV modules [4]. Estimates suggest that the total volume of EOL trash from solar PV modules will, possibly, range from 8 to 78 million metric tons, from 2030 to 2050, as shown in Figure 2 [5,6].

This figure is “a ticking time bomb”. The increasing adoption of solar photovoltaic (PV) systems across the world has led to a growing need for effective end-of-life (EOL) management practices. This is because, like any other product, solar PV systems have a limited lifespan and eventually reach the end of their usable life [7]. At this point, they must be properly managed to ensure that they are disposed of in an environmentally safe manner, that the materials they contain are recovered and recycled where possible, and that any residual waste is handled appropriately [8,9].

Effective EOL management is not only important for environmental protection but also for social and economic sustainability. For example, recovering valuable materials from discarded solar PV systems can help to offset some of the costs associated with their disposal and reduce the environmental impact of mining new raw materials. Moreover, by properly managing the end of life of solar PV systems, it is possible to reduce the risks associated with improper disposal and minimize the potential for negative impacts on human health and the environment [10].

The end-of-life management of solar PV systems is a complex issue that involves multiple stakeholders, including manufacturers, installers, operators, regulators, and communities. Effective end-of-life management of these systems can minimize negative environmental impacts and maximize the recovery of valuable materials [11,12].

The significance of this study lies in its comprehensive evaluation of international end-of-life (EOL) waste management practices and their potential application in Saudi Arabia. As Saudi Arabia aims to diversify its energy mix and expand its solar PV capacity in line with Vision 2030, understanding and implementing effective EOL waste management strategies is crucial. This initiative aligns with the United Nations Sustainable Development Goals (SDGs), particularly Goal 7 (Affordable and Clean Energy) and Goal 12 (Responsible Consumption and Production), as given in Figure 3, by promoting sustainable energy sources and efficient resource use. Integrating these global objectives with the Kingdom’s Vision 2030 renewable energy targets highlights the dual commitment to environmental sustainability and economic diversification.

This study addresses the gap in policy research related to EOL waste management and provides insights that can help Saudi Arabia develop a robust framework. The findings can ensure environmental protection, public health, and economic benefits by promoting sustainable practices. Additionally, the lessons learned can serve as a valuable resource for other countries facing similar challenges, contributing to global sustainability efforts and reinforcing the interconnection between local actions and global environmental goals.

This research article provides an overview of the end-of-life waste management of solar PV systems, highlighting existing policies, regulations, and guidelines in leading countries such as China, USA, India, Japan, and Germany. By examining these practices, the article aims to provide insights and lessons learned that can inform the growth of actual end-of-life waste management strategies for Saudi Arabia. The article is likely to be of interest to policymakers, industry professionals, and researchers working in the field of renewable energy and sustainability.

1.1. Literature Survey

In the context of managing end-of-life (EOL) solar photovoltaic (PV) module waste, the recent literature reveals a growing body of research addressing various aspects of waste recycling. Over the past five years, from 2019 to 2024, a total of 200 papers have been published on solar PV waste recycling, as given in Figure 4, encompassing a diverse range of topics. These include technological advancements in recycling processes, strategies for improving recycling efficiency, and comprehensive reviews of global trends and future perspectives.

As illustrated in Figure 4, the distribution of research publications over the years highlights the increasing attention to solar PV waste management, yet it underscores a significant gap in the exploration of regulatory frameworks. This gap is further detailed in

Table 1. Research articles published on solar PV EOL waste recycling policies and regulation (2019–2024).

S. No.	Paper Title	Journal	Year of Publication
1.	Solar Photovoltaic Recycling Strategies [13]	Solar Energy	2024
2.	Policies and Regulations for Solar Photovoltaic End-of-life Waste Management: Insights from China and the USA [3]	Chemosphere	2023
3.	End-of-life Management of Solar PV Waste in India: Situation Analysis and Proposed Policy Framework [14]	Renewable and Sustainable Energy Reviews	2022
4.	Assessing the Relation Between Waste Management Policies and Circular Economy Goals [15]	Waste Management	2022
5.	Global Challenges and Prospects of Photovoltaic Materials Disposal and Recycling: A Comprehensive Review [16]	Sustainability	2022
6.	A State-of-the-Art Review On End-of-Life Solar Photovoltaics [17]	Journal of Cleaner Production	2022
7.	Challenges of Electronic Waste in Nigeria: Implications for Policy Planning [18]	International Journal of Innovations in Engineering Research and Technology	2021
8.	Recycling of solar PV panels- product stewardship and regulatory approaches [11]	Energy Policy	2021
9.	Solar Energy Policy Directions for Safer and Cleaner Development in Nigeria [19]	Energy Policy	2021
10.	A Scientometric Review of Trends in Solar Photovoltaic Waste Management Research [20]	Solar Energy	2021
11.	Conception and Policy Implications of Photovoltaic Modules End-of-life Management in China [21]	WIREs Wiley Interdisciplinary Review	2020
12.	An Overview of Solar Photovoltaic Panels’ End-Of-Life Material Recycling [7]	Energy Strategy Reviews	2020
13.	Global Review of Policies & Guidelines For Recycling of Solar PV Modules [22]	International Journal of Smart Grid and Clean Energy	2019

, which lists the thirteen key papers that specifically address policies and regulations related to the end-of-life management of PV modules. The scarcity of focused research on this topic indicates an urgent need for comprehensive policy analysis and development to support sustainable PV waste management practices, particularly for countries like the Kingdom of Saudi Arabia, which are expanding their solar energy infrastructures.

1.2. Research Methodology

1.2.1. Research Design

This study adopts a comparative policy analysis approach to examine the EOL waste management regulations for solar PV modules in five leading countries—China, USA, India, Japan, and Germany. The aim is to extract best practices and lessons that can inform and enhance Saudi Arabia’s EOL waste management strategies, aligning with the environmental, social, and economic objectives of Saudi Arabia’s Vision 2030.

1.2.2. Data Collection

Data were collected from a range of primary and secondary sources. Primary data included legal documents, government regulations, and standards pertaining to EOL waste management in the target countries. Secondary data were sourced from academic articles, industry reports, and policy reviews that discuss the implementation and outcomes of EOL regulations.

1.2.3. Analytical Framework

The study utilized a qualitative content analysis method to identify, analyze, and compare the core components of EOL waste management frameworks in the studied countries. The analysis focused on the regulatory mechanisms, stakeholder responsibilities, compliance measures, and the recycling and disposal processes prescribed in each country’s framework.

1.2.4. Criteria for Analysis

The regulations were evaluated based on several criteria crucial for effective EOL waste management:

• Comprehensiveness: the scope and depth of regulations covering the life cycle of solar PV modules.
• Stakeholder Engagement: the involvement of manufacturers, consumers, and recyclers in the EOL process.
• Enforcement and Compliance: mechanisms in place to enforce regulations and ensure compliance.

1.2.5. Link to Objectives and Research Questions

This methodology directly addresses the research objectives by detailing the mechanisms through which various countries manage solar PV EOL waste and identifying actionable strategies that can be applied in Saudi Arabia. The study aims to answer the following research questions:

• What are the best practices in solar PV EOL waste management among leading countries?
• How can these practices be adapted to fit the Saudi context under Vision 2030?
• What are the potential benefits of implementing these international practices in Saudi Arabia?

1.2.6. Inclusion and Exclusion Criteria

Inclusion Criteria:

• The policy document must address solar photovoltaic (PV) end-of-life waste management, with a focus on recycling, reuse, and disposal of PV components.
• The policy document must be accessible to the public and written in English.
• The policy document must have been published by 2024.

Exclusion Criteria:

• The policy document does not pertain to solar PV end-of-life waste management.
• The policy document is not publicly accessible or is written in a language other than English.

Evaluation Criteria:

The gathered policy documents were assessed based on criteria established specifically for this research, concentrating on the following key aspects:

• Legal Framework: evaluation of the legal and regulatory structures governing solar PV end-of-life waste management in each country.
• Policy Goals: analysis of the objectives outlined in the policies concerning solar PV end-of-life waste management.
• Policy Tools: review of the instruments utilized to achieve the goals related to solar PV end-of-life waste management.
• Implementation: examination of the effectiveness of policy implementation regarding solar PV end-of-life waste management.
• Policy Effectiveness: assessment of how successful the policies have been in managing solar PV end-of-life waste.
• Stakeholder Engagement: Analysis of the involvement of key stakeholders, including industry and civil society, in the development and execution of solar PV end-of-life waste management policies.

This structured approach ensures a thorough examination of international EOL waste management practices, providing a robust foundation for recommendations tailored to enhance Saudi Arabia’s regulations and practices in line with its strategic goals. Figure 5 presents a diagram that outlines the steps followed in the research methodology.

2. Solar PV Module Waste Composition

The increased use of solar PV technology has raised concerns regarding the recycling of solar PV waste due to its complicated recovery of valuable materials and the safe disposal of hazardous components [23]. The potential environmental impacts associated with solar PV waste are as follows:

Composition of Solar PV Waste

Solar PV waste comprises a diverse array of materials, such as glass, metals, plastics, and semiconductors. The research detailed in References [24,25,26,27,28,29,30,31] indicates that a typical silicon-based solar panel is primarily composed of 68% glass (front glass), 20% aluminum (frame), plastics and adhesives (junction box and cables), 5.5% ethylene-vinyl acetate (EVA) encapsulant, and 1% polyvinyl fluoride (PVF) back sheet, and a mixture of silicon, aluminum, copper, silver, tin, and lead in the solar cells, accounting for the remaining composition, as shown in Figure 6. It is important to note that these compositions can vary depending on the type of solar module and its manufacturer.

The manufacture of solar PV panels demands substantial quantities of raw materials, such as silicon, silver, copper, and aluminum. These materials are heavily featured in Figure 6, and after glass, they show significant percentages. The extraction and processing of these materials can lead to their depletion. Without adequate recovery, this depletion is exacerbated. According to References [32,33], these materials are critical because of their limited availability and importance in other high-tech products. Inadequate recovery of these materials from decommissioned solar PV panels could lead to scarcity, driving up costs and impacting other industries.

3. Countries Generating Higher Solar PV End-of-Life Waste Volumes

Forecasting the countries that will produce the largest amounts of solar PV module EOL waste poses challenges because of variables like solar PV system deployment rates, system longevity, and recycling facility access. Nevertheless, observing existing patterns suggests that countries with extensive solar PV setups and established solar industries, including China, the United States, Japan, India, and Germany, are expected to contribute notably to EOL waste volumes in the future, as illustrated in Figure 7 [5].

It is worth pointing out that solar panels are meant to last for a long time, and they can continue to operate for 20–25 years, or even more. So, even though we might see more EOL waste in the future because we are installing more of these panels, this waste will also be distributed over numerous decades.

These nations represent a fraction of those anticipated to produce considerable volumes of end-of-life (EOL) waste in upcoming years. Highlighting the necessity of efficient disposal and recycling practices for solar photovoltaic panels is crucial for reducing environmental harm from EOL waste and facilitating the recovery and repurposing of precious materials.

4. China

For many years, China has led the global arena as the foremost market for solar photovoltaic (PV) system deployments. The expansion of China’s solar PV sector has been remarkable, with the National Energy Administration reporting an escalation from a solar PV installed capacity of 43.2 gigawatts GW in 2015 to 253 GW by 2020’s close, reaching 392.6 GW in 2022, as shown in Figure 8 [34]. This surge is the result of multiple factors, such as governmental incentives boosting solar energy investments, technological advancements reducing solar panel costs, and a growing pursuit of renewable sources to cut down on carbon footprints.

China stands at the forefront of solar photovoltaic (PV) technology innovation and implementation, holding one of the highest solar PV capacities globally. Yet, the country currently lacks dedicated and explicit regulations for the disposal and recycling of solar PV system waste at their life’s end. The creation of specialized legislation for the management of end-of-life solar PV modules waste is critical to maintain the environmental integrity and viability of this clean energy source [21], although China does enforce the “National Solid Waste Law”, which offers an outline for solid waste management.

4.1. National Solid Waste Law

Under the revised Solid Waste Law, “solid waste” is characterized in Article 124 as follows:

• The new Solid Waste Law stipulates that “solid waste” refers to items and substances that are in a solid, semi-solid, or gaseous state, contained in containers, and are generated from various activities such as production, daily life, and other activities. These items and substances have lost their original usefulness, are discarded or abandoned, despite potentially still having value.
• In the new Solid Waste Law, “solid waste” refers to objects and substances that are subject to management under laws and administrative regulations, except for waste that has undergone treatment to reduce its volume and hazardousness, meets national product quality standards, and does not pose a risk to public health or the environment. Additionally, any items that do not meet the standards and procedures for solid waste identification are not classified as solid waste.

In addition, the law requires that the disposal of solid waste be carried out in an environmentally sound manner, in accordance with relevant national standards. This includes ensuring that the hazardous are recycled and disposed of in a way that minimizes the release of hazardous substances [35,36].

Moreover, the regulation mandates environmentally responsible solid waste management, aligned with national guidelines. This encompasses the recycling and disposal of hazardous materials in methods that substantially reduce the emission of harmful substances.

The following is an overview of the provisions related to solid waste management in this law.

• Producers’ Responsibility: the law requires producers of products to establish a sound EOL management system and to bear the primary responsibility for the collection, transportation, and disposal of EOL waste generated by their products.
• Collection and Disposal: Producers of products are required to set up collection points for EOL waste generated by their products and to ensure the proper disposal of such waste. In addition, producers are required to publish information about the EOL waste management system on their websites and in product manuals.
• Environmental Protection: Producers are responsible for ensuring that the disposal of EOL and it does not cause harm to the environment or human health. This includes proper handling and disposal of hazardous materials, such as lead, cadmium, and other toxic substances, which may be present in the panels.
• Reporting and Record-Keeping: producers of products are required to submit annual reports on the EOL waste management activities and to maintain records of the EOL waste collected and disposed of.
• Public Information: the law requires producers of products to provide information to the public about their EOL waste management activities and to promote public awareness of the importance of proper EOL waste management.
• Penalties: Companies that violate the provisions of the National Solid Waste Law, including those related to the management of EOL solid waste, may face fines and other penalties. The amount of the fine will depend on the severity of the violation and the extent of any environmental damage caused.

In summary, the National Solid Waste Law of China requires producers of products to take responsibility for the EOL waste generated by their products and to establish a sound EOL management system, including collection, transportation, and proper disposal. Producers must also provide information to the public and keep records of their EOL waste management activities. Failure to comply with these requirements may result in administrative penalties and fines.

China enforces the “Solid Waste Law” to administer the handling of both hazardous and solid substances. In a move to enhance this, the country introduced the national standard GB/T 38785-2020 in 2021 [37], targeting the reprocessing and recycling of thin-film photovoltaic modules for architectural utilization. Complementing this, several related national standards outlined in the annexes of GB/T 38785-2020, which detail the procedures for the transport, processing, storage, recycling, and elimination of hazardous and solid substances, are summarized in

Table 2. List of national standards in China for managing solid waste, including solar photovoltaic systems.

Regulation Code	Regulation	Implementation Year	Current Status
GB/T 38785-2020 [37]	Guidelines for Recycling and Reusing Thin-Film PV Modules in Building Applications	2021	Active
GB 18599-2020 [38]	Regulations for the Control of Pollution from Storage and Landfill of Nonhazardous Industrial Solid Waste	2022	Active
GB/T 23685-2009 [39]	Technical Specifications for the Recovery of Electrical and Electronic Waste	2021	Active
GB/T 20861-2007 [40]	Definitions Related to Waste Product Recovery	2007	Active

. These protocols are likely relevant to the management of solar photovoltaic waste, given its classification as both solid and hazardous material.

4.2. Specifications for Recycling and Reusing Thin-Film Solar Panels in Construction Applications (GB/T 38785-2020)

This regulation details the technical protocols for repurposing and recycling thin-film solar panels within the construction sector. Specifically designed for thin-film solar technologies, it addresses key procedures including the following [37]:

• Strategies for the collection, transit, and processing of discarded panels, extraction, and refinement of valuable components, alongside secure management and elimination of toxic substances;
• Establishes benchmarks for assessing the environmental repercussions of recycling and repurposing thin-film solar panels, alongside recommendations for the architectural and manufacturing phases to enhance recyclability and reusability;
• Seeks to advance the photovoltaic sector’s ecofriendly growth by advocating for the conscientious disposal of waste panels and effective resource utilization.

4.3. Regulations for the Control of Pollution from Storage and Landfill of Nonhazardous Industrial Solid Waste (GB 18599-2020)

This regulation establishes standards for the handling of harmless industrial solid waste storage and landfill operations, focusing on promoting safe and environmentally friendly practices. The objective is to minimize the impact on water and soil quality while protecting public health [38].

Highlights of GB 18599-2020 include the following:

• Comprehensive guidelines for the design, construction, operation, and closure of nonhazardous industrial solid waste storage and landfill sites;
• Criteria for site selection, groundwork, sludge management, gasses emission control, and overall site supervision to avoid pollution;
• Directions on acceptable waste categories for these sites, detailing procedures for waste reception, processing, and transportation;
• Requirements for continuous monitoring, documentation, and emergency response plans to efficiently identify and address environmental risks;
• Emphasizes community engagement in waste management processes and outlines methods for effective communication with local communities and stakeholders.

4.4. Technical Guidelines for the Recycling of Electrical and Electronic Equipment Waste (GB/T 23685-2009)

This regulation provides a framework for the efficient recycling and processing of waste electrical and electronic equipment (WEEE), focusing on improving the efficiency of resource use, reducing environmental impact, and ensuring public health through the responsible management of WEEE [39].

Key features of GB/T 23685-2009 are as follows:

• Detailed procedures for the gathering, storing, transport, and dealing of WEEE, including the design and operational standards for collection facilities and safe handling practices for hazardous components;
• Guidelines for the extraction and purification of valued materials from WEEE, like metals and plastics. It contains techniques for material separation, reprocessing processes, and the potential reutilization of components;
• Standards for assessing the environmental effect of WEEE recycling activities, considering energy consumption and greenhouse gas emissions, to promote sustainability in recycling practices;
• The importance of community awareness and education regarding the proper management of WEEE, including recommendations for educational campaigns and community engagement efforts;
• Encouragement of the advancement of a healthy market for recycled materials to support a circular economy and decrease the waste generation.

4.5. Definitions Related to the Recuperation of Waste Products (GB/T 20861-2007)

This standard introduces a comprehensive glossary specific to the waste material recovery. Its aim is to encourage consistency and clarity in the discourse surrounding the recuperation and recycling of waste, contributing to the sector’s expansion in China [40].

The highlights of GB/T 20861-2007 are as follows:

• Offers a detailed compilation of definitions and terms relevant to the recovery of waste materials, encompassing aspects like sorting, collection, transportation, and processing of waste;
• Covers a wide range of terms related to the recovery and recycling operations for various waste materials, including plastics, metals, paper, and glass;
• Introduces vocabulary related to the environmental and economic advantages of waste recovery, emphasizing efficient resource use, principles for carbon footprint assessment, and circular economy;
• Objectives for standard harmonization to facilitate waste recovery global collaboration and communication;
• Highlights the reputation of exact and uniform terminology to enhance mutual cooperation and understanding between shareholders in waste recycling and recovery industries.

4.6. Observations

China is the world’s leading manufacturer and consumer of photovoltaic (PV) panels, witnessing rapid growth in solar PV installations. This surge in the adoption of solar PV technology has resulted in a substantial volume of panels reaching their end of life (EOL), necessitating effective management strategies to mitigate the environmental impact.

To address the challenges associated with EOL PV panel waste, the Chinese government has implemented a series of regulatory measures and policies designed to promote the proper disposal and recycling of these panels. These initiatives include the National Solid Waste Law, which controls the quality and type of waste entering the country, and the Producer Responsibility Extension System, which mandates that manufacturers design recyclable products, establish take-back programs, cover recycling costs, and maintain comprehensive records.

Despite these regulatory efforts, China faces significant challenges in the efficient disposal and recycling of EOL PV panels. Many recycling entities lack the necessary skills and advanced technologies required to handle EOL PV panels effectively. This technological deficit hampers the country’s ability to process the increasing volume of solar panel waste adequately. Moreover, the recycling sector has experienced limited growth due to the absence of substantial economic incentives, which discourages investment and innovation in recycling infrastructure.

While China’s regulatory framework for EOL solar PV waste management offers certain advantages, it also encounters several critical obstacles that need to be addressed. The fragmented nature of the recycling sector and the lack of uniform standards further complicate effective waste management. Therefore, it is imperative for both governmental bodies and industry stakeholders to collaborate closely to enhance waste management practices. This collaboration should focus on fostering technological advancements, establishing economic incentives, and developing a robust infrastructure to support the recycling and disposal of EOL PV panels.

Enhancing public awareness through educational campaigns and promoting industry best practices are also essential components of a comprehensive EOL waste management strategy. By adopting a multifaceted approach that integrates regulatory measures, technological innovation, and public engagement, China can improve its management of EOL PV panel waste, ultimately safeguarding the environment and contributing to the sustainability of its solar energy sector.

5. The United States of America (USA)

The Solar Energy Industries Association (SEIA) reports that the solar photovoltaic installation sector in the United States has seen notable growth from 2015 to 2021. Initially, in 2015, the overall capacity stood slightly above 20 gigawatts (GW). The SEIA anticipates that by the conclusion of 2021, this capacity may exceed 100 GW, as illustrated in Figure 9, marking an increase of five times over a span of seven years. The upward trajectory of this growth is anticipated to persist as advancements in solar PV technology make it increasingly cost-effective and readily available to the market.

The handling of solar photovoltaic end-of-life waste is becoming an increasingly pressing issue in the US as the deployment of PV systems grows. The regulatory framework for solar PV waste disposal in the USA involves a layered approach that includes federal, state, and local guidelines, along with industry protocols [41,42,43,44].

At the national level, waste management practices, especially for hazardous materials, are primarily guided by the Resource Conservation and Recovery Act (RCRA). This act provides the foundation for hazardous waste handling standards. Beyond federal directives, state and municipal governments often enact their own rules and standards that could augment the management of PV system waste. Certain states have initiated specialized recycling initiatives targeting PV system waste, whereas others have outright prohibited the landfilling of such waste. Municipal regulations may further specify local practices for the disposal and recycling of PV materials.

5.1. National Legislation: Resource Conservation and Recovery Act (RCRA)

Enacted in 1976, the Resource Conservation and Recovery Act (RCRA) serves as the foundational legislative framework for managing solid and hazardous wastes in the United States [45]. In a significant move in 2019, the U.S. Environmental Protection Agency (EPA) revised the RCRA to support the handling of harmful waste from solar photovoltaic systems [46]. These revisions effectively exempt end-of-life solar modules from being classified as harmful waste under certain situations, simplifying the process for recycling used solar modules without the stringent requirements typically associated with hazardous waste. Additionally, the revisions introduced a new class for generators of used solar modules and provided specific exclusions for some solvents used in their production, with the overarching aim of encouraging solar PV module recycling and easing the industry’s compliance load.

Significant amendments to the Resource Conservation and Recovery Act (RCRA) have been made concerning the disposal of solar photovoltaic panel end-of-life (EOL) waste in the United States, encompassing several pivotal aspects, as follows:

• Solid Waste Definition Clarification: A new guideline was established to delineate when discarded PV panels are considered as solid waste, exempting them from RCRA mandates under certain conditions. This clarification aids the solar sector in navigating EOL waste management with reduced regulatory ambiguity;
• Hazardous Waste Regulation Adjustments: a conclusive regulation now omits specific PV panel types from being treated under hazardous waste guidelines, alleviating the solar industry’s regulatory obligations and fostering the recycling and repurposing of PV panels;
• PV Panels Conditional Exclusion: a conditional exclusion has been formulated for PV panels managed under specific criteria, enabling their recycling in a manner that is both environmentally responsible and exempt from the RCRA’s stringent regulations;
• Recycling Standards for PV Panels: the EPA has set forth standards for the recycling processes of PV panels, ensuring their environmentally sound management and recycling practices;
• National Recycling Capacity Assessment for PV Panels: An analysis to gauge the United States’ recycling industry’s capacity to handle PV panel waste was conducted. This assessment is instrumental in shaping future policy directions for PV panel waste management.

5.2. Overview of State-Level Regulations for Managing End-of-Life Waste from Solar PV Systems in the U.S.

By February 2023, numerous states within the United States had established distinct policies and guidelines governing the disposal and handling of end-of-life waste from solar PV systems.

Table 3. Regulatory framework and guidelines for solar photovoltaic end-of-life waste across various U.S. states.

State	Regulation Initiative	Description
California	CalRecycle Guidance (2021)	Guidance deals with the handling of EOL solar photovoltaic waste, emphasizing best practices for gathering, transport, and recycling, including labeling and tracking recommendations [47].
	DTSC Regulations (2019)	Regulations detailing with the requirements for solar photovoltaic EOL waste handling, with gathering, transport, storing, and processing. A permit application process for solar PV manufacturers is also established [48].
	Title 22 Hazardous Waste Standards (2015)	Standards for treating, storing, and disposing harmful waste from solar photovoltaic modules, mandating proper hazardous waste management by manufacturers [49].
	SB 489 Solar PV Recycling Program (2015)	Legislation mandating solar panel producers to initiate a gathering and recycling program for solar photovoltaic modules sold in California, including progress reporting [50].
Washington	Solar Modules Recycling Program (2021)	A program offering resources on proper PV panel handling and recycling for businesses and individuals [51].
	Universal Waste Rule (UWR) (2013)	A rule facilitating the management of certain hazardous wastes, including PV panels, as universal waste to lessen regulatory impacts [52].
	Electronic Waste Recycling Act (EWRA) (2006)	A regulation requiring electronic device producers, including solar modules, to contribute in a state-approved recycling program [53].
	Regulations on Hazardous Waste under Dangerous Waste Regulations (1983)	This set of regulations requires businesses to properly tag, stock, and dispose of hazardous supplies, including those found in some PV panels, such as cadmium or lead [54].
New York	NYS Solid Waste Management Regulations (2020)	Updated guidelines for hazardous waste management, including electronic waste disposal requirements [55].
	NYSERDA PV Panel Recycling Guidelines (2014)	Guidelines by the New York State Energy Research and Development Authority (NYSERDA) for solar photovoltaic panel disposal and component recycling [56].
	Electronic Equipment’s Recycling and Reuse Act (2010)	Necessitates producers to launch and maintain a gathering and recycling program for electronic waste, including solar photovoltaic modules, facilitating proper disposal and recycling efforts to reduce environmental harm [57].
	DEC Hazardous Waste Program Oversight (1976)	It administers state harmful waste regulations, which include the managing of harmful waste from generation to disposal, ensuring that such waste, including from solar PV panels, is handled in an environmentally responsible manner [58].
Minnesota	Electronic Waste Program MPCA (2007)	A program well-known for the management of electronic waste, including solar PV panels, outlining appropriate management, recycling, and disposal requirements [59].
	Statutes on Electronics Waste Recycling (section 115A.1310, 2007)	Enacted to require producers of electronics devices, with solar photovoltaic modules, to launch and withstand gathering and recycling programs for their products. This statute aims to reduce electronic waste in the state by ensuring that manufacturers play a direct role in the recycling process, thereby promoting environmental sustainability [60].
	Rules for Hazardous Waste Generator (1976)	Detailed guidelines are provided for the managing of harmful waste produced by industries and governments, including the dumping of electronic waste. These rules aim to ensure that hazardous materials, potentially including components of solar PV panels, are handled in a manner that minimizes environmental impact and promotes public and environmental health [61].
Oregon	E-Cycles Program (2009)	A manufacturer-required gathering and recycling program for electronics waste, including solar photovoltaic modules [62].
	Administrative Rules (OAR) 340-104 (1986)	These guidelines provide detailed directions on the managing of harmful waste within the state, including the appropriate dumping of electronic waste, to ensure environmentally responsible handling practices [63].
	DEQ Hazardous Waste Program (1985)	The Department of Environmental Quality’s program offers comprehensive guidelines for the appropriate managing and dumping of harmful waste, including electronic waste, reinforcing Oregon’s commitment to environmental stewardship and public health protection [64].
Vermont	Vermont E-Cycles Program (2011)	A state program mandating manufacturer participation in electronic waste collection and recycling, including solar PV panels [65].
	Vermont Statutes, Title 10, Chapter 159 (2011)	This legislation obligates producers of electronic devices, such as solar photovoltaic modules, to launch and uphold gathering and recycling programs for electronics waste, underscoring the state’s commitment to environmental sustainability [66].
	Regulations Hazardous Waste Management (1986)	Provides comprehensive guidelines for the managing and dumping of harmful waste, including electronic waste. These guidelines aim to safeguard the safe handling, storage, and disposal of harmful materials to protect the environment and public health [67].
Colorado	Electronics Recycling Jobs Act (2010)	Legislation requiring electronic device manufacturers to launch and uphold recycling programs for electronic waste within the state [68,69].
	Colorado Universal Waste Regulations (1996)	Rules providing alternate managing standards for certain harmful wastes, including electronics waste, to simplify handling [70].
	CDPHE Hazardous Waste Commission Regulations (1993)	Governs hazardous waste management, including electronic waste, with updated regulations over time [70].
	Colorado Hazardous Waste Regulations (1979)	These rules have been in enacted for several years, with updates and amendments as required. They offer guidance for the proper managing and dumping of harmful waste, including electronics waste.
Connecticut	Regulations Hazardous Waste Management (2020)	These regulations, last updated in 2020, offer directions for the appropriate management and dumping of harmful waste, including electronics waste. They have evolved since their inception in 1981, aiming to ensure the safe management of hazardous materials within the state [71].
	E-Waste Recycling Program (2007)	Initiated in 2007, this program mandates electronic device manufacturers, including solar photovoltaic module producers, to launch and withstand gathering and recycling programs for electronics waste generated within Connecticut. It promotes responsible waste management practices and supports the reduction of electronic waste in the state [72].
	Universal Waste Regulations (2007)	Decreed in 2007, these guidelines introduce alternate standards for managing specific types of harmful waste, such as electronic waste, offering streamlined management approaches. They aim to simplify the management and dumping of harmful materials while ensuring environmental protection and compliance with state regulations [73].
Rhode Island	E-Waste Recycling Program (2008)	Enacted in 2008, this program mandates producers of electronics devices, including solar photovoltaic modules, to create and uphold gathering and recycling programs for electronic waste generated within Rhode Island. It underscores the state’s commitment to responsible waste management and contributes to the reduction of electronic waste accumulation [74].
	Universal Waste Regulations (1995)	Enacted in 1995 and subsequently revised, these guidelines introduce substitute managing standards for certain types of harmful waste, including electronics waste. They provide streamlined approaches to managing hazardous materials, promoting efficiency and compliance while ensuring environmental protection and safeguarding public health [75].
	DEM Hazardous Waste Management Regulations (1995)	Decreed in 1995 and revised over time, these guidelines offer directions for the appropriate managing and dumping of harmful waste, including electronic waste. They ensure adherence to regulatory standards and promote environmentally responsible practices for the management and dumping of harmful materials within Rhode Island [76].
Maryland	Clean Energy Jobs Act of (2019)	Enacted in 2019, this act mandates the establishment of a program by the Maryland Energy Administration to recycle or reuse solar panels. Emphasizing job creation, the program aims to foster sustainable practices and reduce environmental impact while promoting the growth of the clean energy sector in Maryland [77].
	Environmental Service Hazardous Waste Regulations (2015)	Endorsed in 2015, these rules provides directions for the proper managing and dumping of harmful waste, including electronics waste, within Maryland. They ensure compliance with regulatory standards and promote environmentally responsible practices for the management and dumping of harmful materials throughout the state [78].
	Electronic Waste Recycling Program (2005)	Initiated in 2005, mandates electronic device producers, including solar photovoltaic modules, to launch and uphold gathering and recycling initiatives for electronics waste generated within Maryland. This program aims to promote responsible waste management practices and reduce electronic waste accumulation in the state, contributing to environmental sustainability [79].

aggregates information on a selection of states, detailing their specific regulations and standards associated to solar photovoltaic waste management, as well as additional pertinent details regarding these policies.

5.3. Observation

In the United States, a comprehensive framework of federal regulations and standards has been established to address the management of end-of-life (EOL) waste from solar photovoltaic (PV) modules. In addition to these federal guidelines, many states have implemented their own programs focusing on hazardous waste, universal waste, and electronic waste recycling to ensure the proper management of solar PV modules once they reach the end of their operational life.

However, there is a notable disparity in regulations and standards across different states, resulting in variations in how different types of solar PV modules are treated and the specific management protocols for EOL panels. This inconsistency can lead to challenges in uniformly managing solar PV waste across the country. Despite these variations, the overall regulatory landscape underscores a growing recognition of the importance of responsibly and sustainably managing solar PV module waste to mitigate potential environmental and human health hazards.

Federal regulations, such as the Resource Conservation and Recovery Act (RCRA), provide a foundational framework for hazardous waste management, including the disposal of solar PV modules. However, states have the autonomy to develop and implement additional regulations that may be more stringent or tailored to specific local needs. For instance, certain states have introduced specific recycling initiatives and bans on landfilling PV waste, reflecting a proactive approach to managing this waste stream.

The current regulatory landscape in the United States represents a positive stride toward the responsible management of EOL PV modules. However, there is still significant room for improvement to ensure comprehensive management of all EOL PV modules, including those from smaller residential and commercial installations. Enhancements are needed to address the full life cycle of PV modules, from production to disposal, ensuring that all types of installations are covered by robust regulations.

Furthermore, ongoing research and development efforts are crucial to advancing cost-effective and environmentally sustainable recycling and disposal methods for PV modules. Innovations in recycling technologies and processes can help reduce the environmental impact of EOL PV modules, making it easier and more economical to recover valuable materials and minimize waste.

6. Japan

From 2015 to 2022, Japan experienced significant growth in solar photovoltaic (PV) installations. According to the Japan Photovoltaic Energy Association, the total installed capacity of solar PV systems in Japan increased from approximately 34.15 gigawatts (GW) in 2015 to 74.2 GW in 2021 as depicted in Figure 10, more than doubling over the seven-year period. This growth was fueled by the country’s Feed-in-Tariff (FIT) system, which guaranteed a fixed price for solar power generation for a set period of time. In addition, the government’s efforts to encourage renewable energy development and reduce dependence on fossil fuels also played a role in driving the growth of solar PV installations.

In Japan, the guidelines leading the end-of-life (EOL) waste management of solar photovoltaic systems are primarily established under the Act on Promotion of Effective Utilization of Resources. This law requires the proper disposal of EOL solar panels to prevent environmental pollution and promote the recycling of valuable resources [80].

Under the Act, manufacturers, importers, and sellers of solar panels are required to take responsibility for the collection and recycling of EOL panels. They must establish systems for the collection and transportation of EOL panels to appropriate treatment facilities, and cover the costs associated with this process.

The Ministry of the Environment also issues guidelines on EOL waste management for PV systems, which provide more specific details on how to properly handle and dispose of EOL solar panels. These guidelines cover topics such as the proper labeling of EOL panels, the appropriate treatment methods for different types of panels, and the necessary documentation and reporting requirements.

In addition, Japan has established a voluntary system for the recycling of EOL solar panels, called the Japan Photovoltaic Recycling Association (PVRA). PVRA provides a platform for manufacturers, importers, and sellers of solar panels to collaborate on the collection and recycling of EOL panels, and offers technical assistance to ensure that the recycling process is conducted in an environmentally sound and economically viable manner.

Overall, Japan has taken steps to establish a comprehensive regulatory framework for the management of EOL solar panels in order to ensure that these systems are properly disposed of and recycled and that the valuable resources they contain are recovered and reused.

In

Table 4. PV waste recycling regulations in Japan.

Regulation	Implementation Year	Current Status
Waste Management and Public Cleansing Law	1970	Active
The Resource Recycling Act	2013	Active
Promotion of Recycling of Small Waste Electrical and Electronic Equipment (Small Appliance Recycling Act)	2013	Active
Japan Photovoltaic Energy Association (JPEA) Recycling Guidelines	2014	Active
Ministry of the Environment’s Guidelines for the Sound Material-Cycle Society	2018	Active

, a list of some of the key regulations linked to solar photovoltaic EOL waste management in Japan are summarized, and a detailed explanation for each regulation is given after the table.

6.1. Waste Management and Public Cleansing Law (1970)

The Waste Management and Public Cleansing Law in Japan, which was first enacted in 1970 and has been revised several times since then, is a comprehensive law that governs the managing and dumping of waste materials in Japan [81,82]. While the law does not specifically focus on the management of end-of-life (EOL) solar photovoltaic (PV) panels, it provides a legal framework for the proper managing of all kinds of waste materials, including EOL PV panels [83].

Under the Waste Management and Public Cleansing Law, local governments are responsible for the collection and disposal of waste materials, including PV panels’ EOL, within their jurisdictions. The act sets standards for the gathering, transport, and dumping of waste materials and requires that waste be disposed of in a safe and environmentally responsible manner [84].

In addition to the Waste Management and Public Cleansing Law, there are other laws and regulations in Japan that specifically address the management of PV panels EOL, including the Resource Recycling Act and the Act on the Promotion of Recycling of Small Waste Electrical and Electronic Equipment (Small Appliance Recycling Act), as well as the voluntary guidelines developed by the Japan Photovoltaic Energy Association (JPEA) and the Ministry of the Environment.

6.2. The Resource Recycling Act (2013)

Resource Recycling Act in Japan was enacted in 1991 with the aim of promoting the effective utilization of resources, reducing waste, and ensuring the proper disposal of waste materials [85]. In 2013, the act was amended to include specific regulations for the management of EOL solar PV panels and other products containing photovoltaic cells [86].

Under the amended act, manufacturers and importers of solar PV panels are obligatory to establish a system for the gathering and disposal of their products upon reaching their operational lifespan. They are also required to take responsibility for the proper treatment of EOL waste materials, including the proper collection, transportation, and disposal of waste products [87].

The Resource Recycling Act also sets out penalties for noncompliance, including fines and suspension of business operations. In addition, the act provides for the establishment of a system for the certification of recycling companies, which must meet certain standards and criteria to be eligible for certification.

6.3. Promotion of Recycling of Small Waste Electrical and Electronic Equipment (Small Appliance Recycling Act) (2013)

The Act on the Promotion of Recycling of Small Waste Electrical and Electronic Equipment, also known as the Small Appliance Recycling Act, was enacted in Japan in 2013 [88]. The act was introduced to promote the proper disposal and recycling of small electrical and electronic equipment, including consumer electronics, as well as solar panels and batteries [88].

Under the Small Appliance Recycling Act, manufacturers and importers of small electrical and electronic equipment are obligatory to establish a system for the gathering and disposal of their products upon reaching their operational lifespan. They are also required to take responsibility for the proper treatment of EOL waste materials, including the proper collection, transportation, and disposal of waste products [89].

The act also requires local governments to establish collection systems for EOL small electrical and electronic equipment and to ensure the proper disposal of these materials. The government provides financial support for the establishment and operation of collection systems, as well as for the promotion of public awareness and education about the importance of proper waste management.

6.4. Japan Photovoltaic Energy Association (JPEA) Recycling Guidelines (2014)

The Japan Photovoltaic Energy Association (JPEA) Recycling Guidelines were not enacted as a law or act, but were developed by the JPEA as a set of voluntary guidelines for the proper recycling and disposal of end-of-life (EOL) photovoltaic (PV) panels in Japan [90].

The guidelines were first issued in 2004 and updated in 2014 to reflect changes in technology and best practices for the management of EOL PV panels. The JPEA Recycling Guidelines provide recommendations for the collection, transportation, and disposal of EOL PV panels, and outline the responsibilities of various stakeholders, including manufacturers, importers, and recycling companies.

• Some of the key recommendations in the guidelines include the following:
• Manufacturers and importers of PV panels should establish a system for the collection and disposal of their products at the end of their useful life;
• Recycling companies should be certified by the government and follow appropriate safety and environmental regulations;
• PV panels should be dismantled and recycled to the extent possible, with materials such as glass, aluminum, and copper separated and sent for recycling;
• Hazardous materials contained within PV panels, such as lead and cadmium, should be managed and disposed of properly.

The JPEA Recycling Guidelines are not legally binding but are widely followed by JPEA members and other stakeholders in the PV industry in Japan to ensure the proper and environmentally responsible treatment of EOL waste materials. The guidelines serve as a framework for best practices in the management of EOL PV panels and contribute to the development of a more sustainable and environmentally responsible society in Japan.

6.5. Ministry of the Environment’s Guidelines for the Sound Material-Cycle Society (2018)

The Ministry of the Environment’s Guidelines for the Sound Material-Cycle Society, also known as the Sound Material-Cycle Society Promotion Plan, were not enacted as a separate law or act but rather were developed by the Ministry of the Environment as a set of recommendations for the promotion of a sound material-cycle society in Japan [91].

The guidelines were first issued in 2000 and updated in 2018 to reflect changes in technology and best practices for the promotion of a sound material-cycle society [92]. The guidelines provide recommendations for the appropriate managing of waste materials, including PV EOL.

Under the guidelines, the proper management of EOL PV panels is seen as a key component of the promotion of a sound material-cycle society. The guidelines provide recommendations for the gathering, transport, and recycling of PV EOL, and outline the responsibilities of various stakeholders, including manufacturers, importers, and recycling companies.

6.6. Observations

Japan has established a comprehensive and forward-thinking set of regulations and guidelines for managing end-of-life (EOL) solar photovoltaic (PV) waste, underscoring the nation’s commitment to sustainability and environmental stewardship. These regulations and guidelines create a structured framework for the efficient collection, transportation, and recycling of EOL PV modules, while also addressing the management of hazardous materials contained within these modules.

A central component of Japan’s strategy is the use of voluntary guidelines, such as the Japan Photovoltaic Energy Association (JPEA) Recycling Guidelines. These guidelines promote best practices and encourage industry stakeholders, including manufacturers, importers, and recycling companies, to take responsibility for the proper management of their products at the end of their useful life. Although these guidelines are not legally binding, they are widely adopted across the industry, serving as a benchmark for environmentally responsible management of EOL PV modules.

In addition to voluntary guidelines, Japan has enacted several key laws and regulations to govern the management of EOL PV waste. The Resource Recycling Act is a pivotal piece of legislation that sets forth specific requirements for the collection, transportation, and recycling of EOL PV modules. It also includes provisions for the proper handling of hazardous materials embedded within these modules. Complementing this, the Act on the Promotion of Recycling of Small Waste Electrical and Electronic Equipment, commonly known as the Small Appliance Recycling Act, provides additional regulatory oversight for smaller electronic waste, ensuring comprehensive coverage of EOL PV waste management.

Japan’s regulatory framework is characterized by its dual approach of combining voluntary guidelines with legally binding regulations. This approach not only ensures compliance with environmental standards but also fosters a culture of proactive environmental responsibility within the industry. The voluntary guidelines set a high standard for industry practices, while the binding regulations ensure that there is a legal foundation supporting these practices.

Furthermore, Japan’s holistic approach to EOL PV waste management includes robust public awareness campaigns and educational initiatives aimed at promoting recycling and responsible waste management practices among consumers and businesses. These initiatives play a crucial role in ensuring widespread participation in recycling programs and adherence to environmental guidelines.

7. India

The growth of solar PV installations in India from 2015 to 2021 has been remarkable. According to data from the Ministry of New and Renewable Energy, India’s total installed solar capacity has increased from 5.4 GW in 2015 to nearly 50 GW by the end of 2021, as depicted in Figure 11, a growth of more than 620%. This impressive growth can be attributed to several factors, including favorable government policies and incentives, decreasing costs of solar panels, and an increased awareness of the benefits of renewable energy. In addition, India’s solar industry has also seen a significant increase in investments, from both domestic and international sources, which has helped to fund the construction of new solar projects across the country. With India’s commitment to increasing its renewable energy capacity, the growth of solar PV installations is expected to continue in the coming years, helping to address the country’s energy needs while also reducing its carbon footprint.

Solar energy has become an important part of India’s renewable energy mix in recent years, with the country setting ambitious targets for solar energy generation. However, the rapid progress of PV industry has also led to an upsurge in the volume of EOL waste produced by PV modules [93]. Proper management of EOL solar PV waste is crucial to prevent environmental pollution and ensure that valuable resources are recovered and reused [94].

In India, the Ministry of New and Renewable Energy (MNRE) has developed a National Programme on Solar PV Waste Management to address the issue of EOL solar PV waste. The program aims to provide a framework for the management of EOL solar PV waste in a sustainable and environmentally friendly way.

The Central Pollution Control Board (CPCB) is the regulatory body responsible for overseeing the management of EOL solar PV waste in India. Solar PV manufacturers are required to submit a plan for EOL waste management to the CPCB and obtain authorization. The plan should include details on how the EOL modules will be collected, transported, stored, and disposed of, and it should ensure that the waste is managed in an environmentally sustainable way.

Furthermore, the MNRE has also proposed a mechanism to create a corpus fund for the safe disposal of EOL solar PV waste. This fund will be used to finance the collection, transportation, treatment, and disposal of EOL solar PV waste in a sustainable and environmentally friendly way.

In

Table 5. PV waste recycling regulations in India.

Regulation	Implementation Year	Current Status
The National Programme on Solar PV Waste Management provides a framework for managing EOL solar PV waste	2020	Active
The E-waste (Management) Rules	2016	Active
CPCB guidelines on the environmentally sustainable management of EOL solar PV waste	2018	Active

a list of some of the key regulations linked to solar photovoltaic EOL waste management in India are summarized, and a detailed explanation for each regulation is given after the table.

7.1. The National Programme on Solar PV Waste Management Provides a Framework for Managing EOL Solar PV Waste (2020)

India’s National Programme on Solar PV Waste Management was indeed enacted in January 2020, with the aim of addressing the issue of end-of-life (EOL) solar PV waste. The program was developed by the Ministry of New and Renewable Energy (MNRE) in collaboration with the International Finance Corporation (IFC), a member of the World Bank Group [14].

The program provides a framework for the sustainable and effective management of PV EOL waste, including the establishment of a regulatory framework, capacity building, and awareness-raising activities. The program is also designed to promote the development of a circular economy for solar PV waste, which includes the reuse, recycling, and recovery of valuable materials [95].

The key objectives of the National Programme on Solar PV Waste Management include:

• Developing a comprehensive regulatory framework for the managing of PV EOL;
• Establishing a mechanism for the collection, transportation, and storage of PV EOL waste;
• Creating a system for the environmentally sound disposal of EOL solar PV waste;
• Promoting research and development in the area of solar PV waste management;
• Building capacity for the management of EOL solar PV waste;
• Creating awareness among stakeholders about the importance of sustainable solar PV waste management.

The National Programme on Solar PV Waste Management is an important step toward ensuring that India’s growing solar energy sector is sustainable and environmentally responsible. By implementing the program’s objectives, India can minimize the environmental impact of EOL solar PV waste and promote the development of a circular economy for solar photovoltaic waste management.

7.2. The E-Waste (Management) Rules (2016)

The E-waste (Management) Rules, 2016, enacted by the Ministry of Environment, Forest, and Climate Change in India, cover the management of electronic waste, including end-of-life (EOL) solar PV waste. The rules were introduced to address the issues of e-waste, which is a rapidly growing problem in India, and to establish a regulatory framework for the management of e-waste, including EOL solar PV waste [96].

Under the E-waste (Management) Rules, 2016, producers of electronic and electrical equipment are responsible for collecting and managing their own e-waste, including EOL solar PV waste, through authorized collection centers and recyclers. The rules also prescribe environmentally sound management practices for the handling, transportation, storage, and disposal of e-waste and establish penalties for noncompliance [97].

The E-waste (Management) Rules, 2016, also mandate that the Central Pollution Control Board and State Pollution Control Boards oversee the implementation of the rules and establish e-waste management programs to promote awareness and capacity building among stakeholders. The rules also require the establishment of e-waste management standards and best practices, as well as the development of procedures for the management and disposal of harmful waste.

7.3. CPCB Guidelines on the Environmentally Sustainable Management of EOL Solar PV Waste (2018)

The Central Pollution Control Board (CPCB) in India has issued guidelines on the environmentally sustainable management of end-of-life (EOL) solar photovoltaic (PV) waste. The guidelines were issued in May 2018, and they aim to provide a framework for the safe and sustainable disposal of PV EOL waste in India [98].

The CPCB guidelines require the collection, storage, transportation, and disposal of EOL solar PV waste in an environmentally sustainable manner. The guidelines also require that EOL solar PV waste be treated as hazardous waste and handled accordingly. The guidelines specify that the EOL solar PV waste must be collected and stored in designated hazardous waste storage facilities before being transported to authorized recyclers for processing.

The CPCB guidelines also require the implementation of a tracking system to monitor the movement of EOL solar PV waste from the point of collection to the final disposal site. This system should track the quantity of EOL solar PV waste generated, the transportation and storage of the waste, and the recycling process.

The guidelines also call for the establishment of a monitoring and evaluation system to ensure that the handling, storage, and disposal of EOL solar PV waste is being carried out in an environmentally sustainable manner. The system should include regular inspections and audits of the collection and disposal facilities, as well as the authorized recyclers.

7.4. Observations

India’s regulatory framework for managing end-of-life (EOL) solar photovoltaic (PV) waste is comprehensive and designed to ensure the safe and sustainable handling of PV modules that have reached the end of their operational life. This framework includes various rules and guidelines that provide detailed protocols for the collection, transportation, recycling, and disposal of EOL PV modules. However, despite the robustness of these regulations, several challenges and shortcomings remain that need to be addressed to achieve a fully effective EOL PV waste management system.

One of the primary challenges is the lack of awareness and understanding among stakeholders, including manufacturers, consumers, and waste management entities, about the importance and procedures of EOL PV waste management. This lack of awareness can lead to improper disposal practices which, in turn, can result in environmental contamination and health risks.

Another significant challenge is the inadequate infrastructure for managing EOL PV waste. The existing infrastructure for collecting, transporting, and recycling PV modules is often insufficient to handle the increasing volume of waste generated by the rapidly expanding solar energy sector. This shortfall necessitates substantial investment in the development of specialized facilities and the deployment of advanced technologies for efficient waste processing.

Enforcement of EOL PV waste management regulations is also a critical issue. Despite the presence of comprehensive guidelines, ineffective enforcement mechanisms mean that many stakeholders do not comply with the prescribed protocols. Strengthening regulatory oversight and ensuring strict adherence to waste management rules are essential steps to mitigate this issue.

8. Germany

Over the past six years, Germany has continued to be one of the world leaders in the deployment of solar photovoltaic (PV) installations. In 2015, Germany had already reached an impressive installed solar capacity of approximately 40 GW. However, the country did not slow down, and by 2021, it had installed over 58 GW of solar PV capacity, as depicted in Figure 12. This remarkable increase in solar PV installations can be attributed to a combination of factors, including generous feed-in tariffs, supportive government policies, and decreasing costs of solar PV technology.

Germany is a leader in the solar energy sector and has developed comprehensive regulations and procedures for the managing of end-of-life (EOL) solar photovoltaic waste. The country has taken a positive approach to sustainable waste management, and the regulations and guidelines provide a framework for the safe and sustainable disposal of EOL solar PV waste [99].

In Germany, solar PV EOL waste management is governed by a set of regulations and guidelines that aim to ensure the safe and sustainable managing of PV EOL waste.

In

Table 6. PV waste recycling regulations in Germany.

Regulation	Implementation Year	Current Status
The Electrical and Electronic Equipment Act (ElektroG)	2015	Active
The Waste Electrical and Electronic Equipment Directive (WEEE)	2012	Active
The German Solar Association (BSW)	1978	Active

, a list of some of the key regulations linked to solar photovoltaic EOL waste management in Germany are summarized, and a detailed explanation for each regulation is given after the table.

8.1. The Electrical and Electronic Equipment Act (ElektroG) (2005)

Germany’s Electrical and Electronic Equipment Act (ElektroG) was enacted in 2005 to provide a framework for the environmentally sound management of end-of-life electrical and electronic equipment, including solar photovoltaic (PV) modules [100,101]. The law aims to reduce the environmental impact of waste electrical and electronic equipment (WEEE) and promote the sustainable use of resources [102].

Under the ElektroG, producers of electrical and electronic equipment, including solar PV modules, are responsible for ensuring the safe and sustainable disposal of their products. Producers must ensure the collection, treatment, and recycling of their EOL products to reduce environmental pollution, conserve resources, and promote circular economy principles. Additionally, producers must register with the German government and report their compliance with the regulations.

8.2. The Waste Electrical and Electronic Equipment Directive (WEEE) (2012)

WEEE is an important European Union directive that sets out rules for the management of waste electrical and electronic equipment, including solar PV modules [103,104].

The WEEE Directive was first introduced in 2002 and was revised in 2012 to strengthen the existing legislation. The directive aims to prevent the generation of WEEE; encourage reuse, recycling, and other forms of recovery of such waste; and ensure that WEEE is managed in an environmentally sound manner. The directive applies to all electrical and electronic equipment sold within the EU, including solar PV modules.

The WEEE Directive places responsibility on producers of electrical and electronic equipment to ensure that their products are properly managed at the end of their life. Producers must finance and organize the collection and treatment of their products, either individually or through collective schemes, and ensure that they are appropriately recycled or disposed-off.

The directive also requires member states to establish collection targets for WEEE and to deliver information to consumers on how to properly dispose of their products. Member states are also required to monitor compliance with the directive and to take measures to prevent illegal exports of WEEE.

In Germany, the WEEE Directive is implemented through the Electrical and Electronic Equipment Act (ElektroG), which places the responsibility for the environmentally sound management of WEEE on producers. The ElektroG establishes a producer responsibility system, whereby producers must register with the German government and report their compliance with the regulations. Producers must ensure the collection, treatment, and recycling of their EOL products to reduce environmental pollution, conserve resources, and promote circular economy principles.

8.3. The German Solar Association (BSW)

The German Solar Association (Bundesverband Solarwirtschaft, or BSW) is a trade association representing the solar industry in Germany. The BSW was founded in 1978.

The BSW is actively involved in promoting the development and deployment of solar energy in Germany, and it advocates for policies and regulations that support the growth of the solar industry. The association is also engaged in research and development activities related to solar energy, and it provides information and education to the public on the benefits of solar energy [105,106].

In addition to its work on promoting the development of solar energy, the BSW is also involved in efforts to promote the sustainable management of end-of-life solar PV modules. The association supports the development of recycling technologies and processes for PV waste, and it advocates for policies and regulations that promote the responsible management of PV waste.

The BSW also offers a certification program for solar PV installers, which includes training on the proper handling and disposal of end-of-life PV modules. The program includes guidelines for the environmentally responsible management of PV waste and emphasizes the importance of recycling and resource conservation in the solar industry.

8.4. Observations

Germany’s framework for managing end-of-life (EOL) solar photovoltaic (PV) waste is highly developed and comprehensive, reflecting the country’s commitment to promoting sustainable practices in the disposal and recycling of PV modules. The regulatory landscape is designed to ensure that EOL PV modules are managed in an environmentally responsible manner, mitigating potential adverse effects on the environment and public health. However, despite the robustness of Germany’s regulations, several challenges and shortcomings persist that must be addressed to enhance the effectiveness and sustainability of EOL PV waste management.

One of the primary challenges is the need for improved tracking and monitoring systems for EOL PV products. Effective tracking mechanisms are essential to ensure that PV modules are disposed of or recycled in compliance with existing regulations and guidelines. Enhanced tracking would facilitate better data collection on the life cycle of PV modules, enabling more precise monitoring and enforcement of compliance.

Additionally, there is a pressing need for greater harmonization of waste management regulations across the European Union (EU). While Germany has established stringent national regulations, the lack of uniformity in EOL PV waste management policies across EU member states can lead to inconsistencies in implementation. Harmonized regulations would ensure a more cohesive and standardized approach to managing PV waste across Europe, thereby enhancing the overall effectiveness of EOL PV waste management practices.

Germany’s regulatory framework is anchored by key legislation such as the Electrical and Electronic Equipment Act (ElektroG) and the Waste Electrical and Electronic Equipment (WEEE) Directive. These regulations mandate the separate collection of EOL PV modules, the safe disposal of hazardous materials, and the promotion of recycling and resource recovery. The deposit–return systems for electronic products further incentivize the return of EOL products, facilitating their proper management and recycling.

Despite these strengths, Germany faces challenges in ensuring comprehensive compliance with these regulations. The decentralized nature of waste management, combined with varying levels of enforcement across different regions, can result in gaps in compliance. Strengthening regulatory oversight and enhancing coordination between regional authorities are crucial steps toward addressing these issues.

Furthermore, the dynamic nature of the solar PV industry necessitates ongoing adaptation and refinement of EOL waste management policies. As new technologies and materials are introduced, regulations must evolve to address emerging challenges and opportunities. This includes fostering innovation in recycling technologies and processes to improve the efficiency and sustainability of PV module recycling.

Public awareness and education also play critical roles in Germany’s EOL PV waste management strategy. Educating consumers and industry stakeholders about the importance of proper disposal and recycling practices is essential for ensuring widespread participation and compliance. Initiatives aimed at raising awareness and promoting best practices can significantly enhance the effectiveness of EOL PV waste management.

9. Global Concern about Solar PV End-of-Life Waste Recycling and Management

The proliferation of solar photovoltaic (PV) systems globally, spurred by the rapid advancement of renewable energy technologies and policies supporting sustainable development, raises critical concerns regarding the management of end-of-life (EOL) waste. As the adoption of solar PV systems aligns with the United Nations Sustainable Development Goals (SDGs), particularly Goal 7 (Affordable and Clean Energy) and Goal 12 (Responsible Consumption and Production), the life cycle impacts of these systems, including waste management and recycling at their EOL, become increasingly significant.

The exponential growth in solar PV installations, forecasted to have an installed capacity of over 1630 GW by 2030, as shown in Figure 1, implies a parallel increase in waste generation as early installations reach their end of life. Estimates suggest that by 2050, solar PV waste could exceed 78 million tons globally, as depicted in Figure 2.

9.1. Challenges in Recycling Solar PV Waste

Recycling solar PV waste presents several unique challenges that complicate the recovery of valuable materials and the safe disposal of hazardous components.

9.1.1. Technological and Economic Barriers

The recycling of solar PV panels is technologically challenging due to the complex integration of various materials within a single module. Separating these materials, such as glass, metals, and different types of plastics and semiconductors, requires sophisticated recycling technologies that are not yet widely available or economically viable. The costs associated with setting up and operating recycling plants capable of processing solar PV waste can be prohibitively high, discouraging investment in necessary infrastructure.

9.1.2. Regulatory and Logistical Issues

There is a lack of uniform regulatory frameworks across regions concerning the disposal and recycling of solar PV waste. This inconsistency can lead to significant disparities in recycling practices and standards, complicating global efforts to manage solar PV waste effectively. Additionally, the logistics of collecting and transporting end-of-life solar panels to recycling facilities pose another hurdle, especially in regions where such facilities are sparse or nonexistent.

9.2. Potential Environmental Impacts

Environmental impacts of solar PV waste are primarily categorized into resource depletion, pollution, and health and safety risks.

Disposing of solar PV waste can release harmful substances into the environment, causing pollution and potentially negative effects on both ecosystems and human health. PV modules contain hazardous elements, such as lead, cadmium, and other heavy metals, that can leach into soil and water systems if not properly managed [107,108,109]. The risk of environmental contamination increases if these modules are not disposed of or recycled correctly, leading to potential module breakage and degradation, which can release toxic substances. The leaching of these substances can harm local ecosystems and pose health risks to wildlife and humans through processes like bioaccumulation and biomagnification [110,111].

Furthermore, disposing of solar PV waste through incineration can lead to air pollution. Incinerating PV modules that contain hazardous materials at high temperatures can emit toxic gases, including dioxins and furans, which are detrimental to human health and degrade air quality [112,113].

10. The Kingdom of Saudi Arabia

In 2023, Saudi Arabia ranked as the world’s second-largest producer of crude oil, trailing only the United States, with its daily production reaching 11.13 million barrels per day, which represents approximately 11% of global production, as shown in Figure 13. This substantial contribution to the global oil market underscores the significance of Saudi Arabia’s strategic shift toward reducing its dependency on oil-derived revenues [114].

The Kingdom is well-positioned to capitalize on renewable energy sources due to its expansive and sun-drenched deserts, which are ideal for solar power generation. The KSA Solar Radiation Atlas highlights Saudi Arabia’s exceptional solar energy potential, marked by direct normal irradiance (DNI) levels ranging from a minimum of 24 MJ/m²/day to a maximum of 30 MJ/m²/day, as shown in Figure 14. This positions the country as a prospective leader in solar technology on a global scale [115,116].

Saudi Arabia’s Vision 2030 reflects a decisive move toward diversifying its energy sources and economic activities by focusing on alternative and sustainable energy forms, particularly solar photovoltaic (PV) technologies. This strategic pivot is part of a broader global trend toward creating more diverse and sustainable energy portfolios, aligning with international efforts to promote environmental sustainability and economic stability, by setting an audacious goal to produce 58.7 gigawatts of renewable energy by 2030, of which 40 gigawatts are expected to come from solar PV, as indicated in Figure 15.

The Kingdom of Saudi Arabia has been rapidly expanding its renewable energy capacity, more specifically solar PV, in recent years. Figure 16 shows the RE large-scale power plant locations’ allocations including solar PV.

With the increased deployment of solar PV systems, the country also faces the challenge of managing end-of-life (EOL) waste generated from these systems. However, the Kingdom of Saudi Arabia has implemented several initiatives and policies to promote renewable energy and reduce the environmental impact of the energy sector.

10.1. Saudi Arabia Waste Management Law

Saudi Arabia unveiled its pioneering “Waste Management Law” on 15 September 2021. This legislation is designed to oversee the proper handling, separation, conveyance, storage, as well as the exportation and importation of waste, among other related procedures. The statute mandates that organizations adhere to secure waste disposal and recycling practices, employing ecofriendly techniques as per the article number 11, 14, 16, 18, and 19 as given in

Table 7. Saudi Arabia Waste Management Law.

Article No.	Description
11	Producers of waste are required to minimize their waste output, repurpose items, and keep them in specified locations to safeguard resources and materials.
14	This law establishes the comprehensive accountability of both importers and domestic producers regarding their goods, aiming to foster economic resilience within the waste management industry and promote the concept of a circular economy. The specific protocols and guidelines will be outlined in the law’s implementing regulations.
16 and 18	Guidance was provided on the varied duties and functions of entities involved in waste management, for instance: Entities tasked with waste disposal are required to implement disposal practices as prescribed by the National Waste Management Center (NWMC); Carriers of hazardous materials must comply with NWMC regulations, which include affixing cautionary signs, utilizing suitable vehicles, and ensuring all necessary paperwork accompanies the hazardous waste throughout its transit.
19	The law bans the entry of hazardous waste into the Kingdom of Saudi Arabia without official permission. Furthermore, it restricts the introduction of recycled and second-hand products, alongside waste materials, devices, and equipment, unless authorized.

[117].

10.2. Observations

The management of end-of-life (EOL) waste for solar photovoltaic (PV) panels in Saudi Arabia is an emerging issue, reflecting the country’s expanding commitment to renewable energy sources. While the challenge of EOL PV waste management is still in its developmental stages, the Saudi government is proactively taking steps to address this problem through the establishment of new standards and the creation of a comprehensive national e-waste management system.

As the deployment of solar energy systems continues to accelerate in Saudi Arabia, driven by the country’s ambitious Vision 2030 goals, it becomes increasingly critical to ensure that EOL waste from solar PV panels is managed effectively. This proactive management is essential to mitigate potential environmental and health impacts associated with improperly disposed EOL PV panels.

11. Lesson Learned for the KSA

The management of end-of-life (EOL) waste is a significant issue globally, including in Saudi Arabia. This challenge poses major environmental and public health risks due to the toxic components involved and the complexities associated with their safe disposal.

To address EOL waste management effectively, Saudi Arabia should consider the regulations and guidelines established by leading countries such as China, the USA, India, Japan, and Germany. By analyzing and adopting best practices from these nations, Saudi Arabia can formulate a comprehensive and efficient EOL waste management system.

The following

Table 8. Solar PV EOL waste recycling policy approaches in top five leading countries.

Country	Key Practices	Description
China	Banning of EOL Waste Imports and Exports	Implement strict regulations to control the quality and type of waste entering the country.
	Extended Producer Responsibility (EPR)	Require manufacturers to design recyclable products, set up take-back programs, cover recycling costs, and maintain records.
	Mandatory Recycling Targets	Set national recycling targets to ensure high rates of recycling and material recovery.
	Development of Recycling Infrastructure	Invest in specialized recycling facilities for solar PV waste.
	Public Awareness Campaigns	Launch campaigns to educate the public about recycling and waste management.
USA	Extended Producer Responsibility (EPR)	Mandate product stewardship programs and financial responsibility for manufacturers.
	State-Level Regulations and Incentives	Develop localized policies and offer incentives for recycling.
	Public–Private Partnerships (PPPs)	Foster partnerships to develop recycling infrastructure and services.
	Public Education and Engagement	Implement nationwide educational campaigns about EOL waste management.
Germany	Separate Collection of EOL Products	Develop systems for separate collection and establish dedicated recycling centers.
	Strict Hazardous Waste Regulations	Implement strict regulations for hazardous waste management and enforce compliance.
	Deposit Systems for Electronic Products	Introduce deposit–return systems to incentivize the return of EOL products.
India	Involvement of the Informal Sector	Integrate informal waste collectors into the formal system and provide training.
	National Programme on Solar PV Waste Management	Develop a national program with regulatory frameworks and financial mechanisms for safe disposal and recycling.
	Public Awareness and Education	Launch educational campaigns and community programs to involve residents in recycling efforts.
Japan	Take-Back Programs	Mandate manufacturers to establish take-back programs for EOL products.
	Public–Private Collaboration	Encourage partnerships for effective EOL waste management strategies.
	Public Awareness and Education	Develop educational programs to inform the public about recycling and waste management.

provides a summary of the key policies from these countries, and Figure 17 outlines a proposed policy recommendation for Saudi Arabia, based on the most prevalent policy elements used internationally.

A common thread among the policies of these leading countries includes the following three key components:

• Extended Producer Responsibility (EPR): mandating that manufacturers take responsibility for the entire life cycle of their products, including the design, take-back programs, and covering recycling costs.
• Public Awareness and Education Campaigns: launching initiatives to educate the public about the importance of recycling and proper waste management practices.
• Public–Private Partnerships (PPPs): fostering collaborations between the government and private sector to develop and operate recycling facilities and waste management programs.

In addition to these three common points, it is also crucial to emphasize the development of robust recycling infrastructure. Therefore, the initial policy recommendation for Saudi Arabia includes the following:

• Extended Producer Responsibility (EPR): implement policies that require manufacturers to manage the life cycle of their products, ensuring they are recyclable and facilitating take-back programs.
• Public Awareness and Education Campaigns: develop and execute campaigns to raise public awareness about EOL waste and encourage community participation in recycling efforts.
• Public–Private Partnerships (PPPs): encourage partnerships to invest in and manage recycling infrastructure and waste management programs effectively.
• Development of Recycling Infrastructure: invest in specialized facilities and technologies to handle the anticipated increase in solar PV waste.

By incorporating these elements, Saudi Arabia can establish a sustainable and effective EOL waste management framework, ensuring environmental protection, public health, and economic growth.

12. Conclusions and Policy Implications

The forthcoming challenge of managing end-of-life (EOL) photovoltaic (PV) solar panel waste is poised to become a significant global issue due to the rapid increase in solar PV panel production and deployment. This type of waste, if not managed properly on time, has the potential to cause serious environmental, economic, and social problems. Unlike other waste streams, EOL PV panels require specific attention to prevent these issues.

Despite the growing use of PV panels, recent research, as highlighted by Xu et al. [118], predominantly focuses on enhancing the efficiency of PV panel and manufacturing processes. There is a noticeable lack of studies addressing the policies and regulations necessary for the dismantling and recycling of PV panels at their end of life.

This study aims to fill this gap by being the first academic investigation to analyze the policies and regulations related to the recycling of EOL PV panels in five leading countries, as follows: China, the USA, Japan, India, and Germany. While significant progress has been made in managing EOL waste in these countries, there is still a need for improvement in others. The challenges associated with EOL waste management are complex and require a multistakeholder approach, including collaboration between policymakers, industry players, and other stakeholders.

By examining these international approaches, this research provides a foundation for developing an effective EOL PV panel recycling policies in the Kingdom of Saudi Arabia.

Based on the lessons learned from the five countries examined, it is clear that Saudi Arabia should consider developing a comprehensive regulatory framework for managing solar PV EOL waste. This framework should address issues such as collection, transportation, treatment, and disposal of EOL waste, as well as measures to promote the reuse and recycling of solar PV components. In addition, Saudi Arabia should prioritize stakeholder engagement, including public awareness campaigns and collaboration with industry players, to ensure the success of the EOL waste management program.

Furthermore, the research identifies several gaps and directions for future research, including the following:

• Detailed policy analysis to support the development of robust EOL waste management regulations.
• Exploration of advanced technological solutions for recycling and disposal.
• Strategies for effective stakeholder engagement and public awareness.
• Economic assessment of EOL waste management practices to ensure sustainability.

Overall, the research findings underscore the importance of proactive and strategic planning for managing solar PV EOL waste. By adopting best practices and lessons learned from other countries, Saudi Arabia can develop an effective and sustainable EOL waste management program that not only protects the environment but also supports the growth of its solar PV industry.