Solar Waste Management – The Need For A Policy On Recycling Of Pv Material

September 2022

“As distributed renewable energy sources such as solar PV and energy storage penetrate deep into the Indian electricity sector it is necessary to prepare for managing the waste generated from these technologies. In addition to being environmentally benign, the ‘reduce, reuse, and recover’ approach offers multiple socio-economic co-benefits” (A. Tyagi CEEW 2020).

Solar Energy & PV Waste In India – An Outlook:

Solar Energy plays a critical role in India’s quest towards clean energy transition. The exponential rise in solar power plant installations over the past five years has rocketed to reach a cumulative capacity of more than 50 GW. However, as everywhere in the world, this rapid penetration of PV technology is also expected to create issues around recycling and waste management, even though PV modules are durable, long-lasting products with shelf-lives of 25 years or even longer.

The International Renewable Energy Agency (IRENA) estimates that the global PV waste will touch 78 million tonnes by 2050, with India being one of the top five PV waste creators. The study envisages that India will generate a cumulative mass of PV module waste of 11 kilo tonnes (kt) by the year 2030 in the low scenario, 21 kt in the medium scenario, and 34 kt in the high scenario.

These figures include PV waste streams generated only during transportation, installation and operation of the PV system and not from modules reaching their expected end of life. Notably, majority of PV systems have been installed after 2010 and the end-of-life waste would start accumulating only around the year 2030-35.

Also considering that ground-mounted solar constitutes majority of installed PV capacity compared to the residential segment, which is only a fraction of rooftop installations, we can safely assume that greatest bulk of end-of-life PV waste will be derived from the business-to-business (B2B) market. Additionally, some of the prevalent issues that may result in the short life of PV modules are variable structural tilt in the adjacent tables – which leads to accelerated degradation due to temperature difference between shaded and unshaded modules, the salinity of the ground beneath – which at high concentration corrodes the frames and unstable structures due to weak tightening of nuts and bolts (PV Diagnostics 2020) and damages due to natural calamities.

Responsible PV module waste management and efficient recovery of different component is therefore necessary to prevent adverse environmental impacts which could arise from wrong practices of disposal of PV modules and their components.

Responsible Recycling Of PV Waste:

Broadly, PV module recycling is a multistep process involving dismantling, delamination (disintegration of the laminated structure) and metal recovery. Dismantling involves removal of externalities like metal frames from the laminated structure. This could be either done manually or be automated. Following this, Delamination of the laminated structure is done – which involves separating the glass layer, encapsulant, and the back sheet from the solar cells. This is one of the most cumbersome steps in the recycling process and uses techniques such as mechanical, thermal, or chemical processing, or a combination of these. The last step is metal Recovery, one of the most valuable parts of the recycling process. It involves a variety of chemical and electrolytic processes to recover precious metals. Several techniques are used to recover the intrinsic components in the PV modules. Some of these, like chemical delamination, yield undamaged solar cells, which could be reused directly or with little refurbishing. Mechanical and combustion delamination, on the contrary, yields damaged solar cells that are treated electrochemically or metallurgically to recover the metals

International Regulation Around Solar Waste Management:

Many countries have started appreciating that Solar PV module waste is likely to create problems in the future and have taken steps to manage the waste in effective and environment-friendly ways.

The European Union (EU) Waste Electrical and Electronic Equipment (WEEE) directive provides guidelines for all electrical and electronic waste management in the EU member states. The EU was also the first to modify its existing E Waste regulations in 2012 to include PV panels as one of the 10 categories of electronics waste. This Directive follows an Extended Producer Responsibility (EPR) principle, which is “an environmental policy approach in which a producer’s responsibility for a product is extended to the post-consumer stage of a product’s life cycle”.

As per the EPR principle, the producer is responsible for taking back, recycling, and disposing of the modules they sell in the EU member countries. The consumers return their waste modules via different collection schemes, free of charge, to a responsible entity as appointed by the state, such as a municipality or distributor, who passes it on to a producer for further disposal/recycling.

Except for the EU, most countries do not have a regulation to manage waste PV modules and their components. Though, globally, the PV industry is leading the collection and recycling of PV waste, most of these initiatives are facilitated by a third party that collects and recycles the waste PV modules using the funds collected by the member companies who have appointed such third party.

Finance is also a major concern towards PV recycling. Two financing options however are prevalent globally for financing PV recycling activities viz pay-as-you-go (PAYG) and pay-as-you-put (PAYP). In the PAYG model, the producer arranges for waste management costs when the waste occurs whereas the PAYP approach involves charging an additional payment, as per the estimated value of collection and recycling, when a product is brought in the market.

India’s Eye On Solar Waste Management:

In India the E Waste is regulated through the E Waste regulation crafted in 2011. This legislation came into force from 1st May 2012. These Rules apply to the two e-waste categories as defined in Schedule I of the Rules viz (i) information technology and telecommunication equipment and (ii) consumer electrical and electronics. Surprisingly, PV modules, whose sole purpose is to generate electricity, are not listed as e-waste in this regulation. Hence, as of now none of the prevalent Indian waste management regulations covers the PV waste modules. However, taking cognizance of the increasing proliferation of Solar Panels and related (futuristic) waste creation, Ministry of Environment, Forest and Climate Change brought in draft E Waste Management Rules in May 2022 wherein PV waste has been categorised as E Waste along with inclusion of EPR clause. As and when and it comes into force, the same will be applied to PV waste also. Following is the summary of important proposals of the draft regulations which would get applied to Solar Waste:

• Companies have to ensure that at least 60% of their electronic waste (by weight) is collected and recycled by 2023 with targets to increase them to 70% and 80% in 2024 and 2025, respectively.
• Companies will have to register on an online portal and specify their annual production and e-waste collection targets.
• The rules bring into effect a system of trading in certificates, akin to carbon credits, that will allow companies to temporarily bridge shortfalls.
• The rules lay out a system for companies securing EPR certificates.
• These certificates certify the quantity of e-waste collected and recycled in a particular year by a company and an organisation may sell surplus quantities to another company to help it meet its obligations.
• Companies that don’t meet their annual targets will have to pay a fine or an ‘environmental compensation’, but the draft doesn’t clarify the quantum of these fines.
• The Central Pollution Control Board (CPCB) will be the main organisation in charge of coordinating EPR certificate transactions and ensuring that companies fulfil their targets.
• The overall execution of these rules will be overseen by a steering committee led by the Chairman of the CPCB.
• State Governments will be responsible for establishing steps to protect the health and safety of workers working in e-waste dismantling and recycling facilities, and earmarking industrial space for e-waste dismantling and recycling facilities.

Though the regulations have been drafted with a lot of fervour and optimism, they appear quite challenging if not completely unrealistic, especially with regards to PV waste recycling, for the following reasons:

• Large-scale recycling of e-waste is still in its infancy in India leave alone the PV waste.
• Most of the recycling of valuable material in India is still carried out within the informal sector using inefficient and unsafe technologies.
• A target to recycle 60% of the PV-waste generated in 2022-23 is impossible considering that no frameworks or SoPs are developed for collection and aggregation of the Solar Waste including PV.
• Draft is silent on regulating the collectors, dismantlers, and producer responsibility organisations.
• Experience from European countries suggests that regulators would find it difficult to monitor and enforce the recycling targets compared to collection targets.
• The regulation also does not specify whether the recycling target would apply to every component of an e-product, or it applies to its aggregate weight. The technological complexity and cost will vary by component.

The draft regulations therefore require careful deliberation not only with all the relevant stakeholders but also with science/academia and civil society organizations before they are finalized.

The Road Ahead Towards Responsible PV Recycling:

To deal with this impasse, the Council on Energy, Environment and Water (CEEW) in one of its research papers have come out with some logical suggestions as enlisted below:

• Impose a ban on damaged modules being dumped in landfills to prevent their adverse impact on the environment.
• Conceptualise business models to include future waste disposal costs in the prices of their products. Besides disposal, these prices could also cover administration, collection, logistics, and treatment costs. They can choose from some of the prevalent models like pay-as-you-put, pay-as-you-go, or a joint liability scheme. Of course, the developers are likely to embed these increased costs within the Power Purchase Agreements.
• Use a design-to-disassembly approach to simplify the module design which can minimise the process and energy invested in recycling.
• Reduce its generation at the source itself. This can be achieved by promoting the second-life use of damaged or sub-performance modules. Such modules can be used where electricity is not generated for earning revenue.
• The solar industry should promote research around developing efficient recycling technologies by collaborating with institutes and companies and conducting pilot demonstrations.

The Need To Implement A PV Waste Management Policy:

India is now in the midst of a clean energy transition, and this is the right time to bring in strong and effective policies and set up process for PV module waste management. The policy should clearly state the responsibility both physical and financial, of different stakeholders across the PV supply chain. Decisions on the allocation of responsibility should be made keeping in view the policy goals, product characteristics, market dynamics, stakeholders in the product chain and resources needed to implement the policy. The government should also set realistic targets for every stage of waste management like collection, recycling, and recovery; introduce innovative business models and incentive mechanisms and provide appropriate and adequate guidelines for the handling and safe disposal of different waste categories.