Solar Panel Disposal: Recycling, Reclamation And Risk

Solar panels have an expected life of 25 years. However, at the end of that life, or due to unexpected damage from weather (think golf ball sized hail) or other circumstances, the question of how to dispose of those panels properly comes to the fore. 

As we have several clients with solar farms in multiple states, GZA assessed the current state of solar panel disposal regulations as of November 2022, and have found that how you treat spent panels depends on where they are.

Determine The Scale of Your Waste

Almost all states we surveyed, with the exception of California, have a Conditionally Exempt Small Quantity Generator category, as defined by the Environmental Protection Agency. While most utility scale facilities may not qualify, smaller ones should examine the rules and see if they apply in their situation.

Be Sure Your State Has a Hazardous Waste Exemption

Solar panels only qualify for a hazardous waste exemption when they’re recycled, and not every state has an applicable exemption. Our research found that Arizona, Colorado, Delaware, Maine, Maryland, New Jersey, Pennsylvania, Puerto Rico and Wisconsin currently have no exemption.

Check To Ensure What Kind Of Waste Solar Panels Are Considered

Two states, California and Hawaii, classify panels as universal waste. This streamlines management requirements, as established under 40 CFR part 273, but failure to follow these requirements will see the panels classed as hazardous waste instead. Massachusetts and New York will exempt panels with a state-specific approval, but until that approval goes through, the panels are hazardous waste.

Even When You’re Told They’re Exempt, Check the Regulations

Solar panels are categorically exempt or otherwise excluded from hazardous waste requirements in Connecticut, Florida, Georgia, New Mexico, Nevada, North Carolina, Ohio, Oregon, and Texas. However, that’s generally contingent on the panels being sent to a licensed recycling facility.

On the basis of our research, we recommend the following steps:

• Recycle where possible, and do so through a licensed / legitimate recycler that documents the process for you.
• Develop a waste disposal plan in compliance with state regulations for each solar facility you operate.
• Design a recovery plan in case of extreme events that damage a number of panels, so you can remove them from the site and get back up to full power quickly.
• Designate a storage and documentation plan for damaged panels, so they can be inventoried and recycled quickly.