PV recycling mandate: Industry needs to adapt as new rules take effect
WRITTEN BY JAN CLYNCKE. It’s no longer just a green thing to do: starting in February the collection, transport and recycling as well as its related financing and administration of discarded end-of-life photovoltaic panels is EU law. One of the most significant changes in the European photovoltaic sector in recent years, it’s the result of the new WEEE (Waste Electrical and Electronic Equipment) Directive adopted two years ago by the European Union.
The EU decided to include the PV sector in what has worked well for PV CYCLE and in other industries: the so-called Extended Producer Responsibility. “PV Producers” – all firms or individuals manufacturing, selling, reselling or importing PV modules in an EU-country – are now responsible for disposing and recycling panels in all Member States in which they operate. It’s worth nothing that those obligations are likely to differ significantly from country to country.
The 14 February deadline
The WEEE Directive Recast of 2012 introduced the general norms under which each Member State should regulate the recycling of waste electrical and electronic equipment, including photovoltaic panels, after 14 February 2014.
The United Kingdom was the first Member State to implement this legislation — in advance of the official deadline, no less — followed by Bulgaria, the Netherlands and Luxemburg. (A national law was presented to the British Parliament on 10 December 2013 and came into force on 1 January 2014.)
Although other EU countries may not meet the deadline and it will take them a few more months to get up to speed, WEEE will remain subject to the PV sector in 2014 and onwards.
From voluntary to mandatory
The WEEE legislation brings significant changes as it implies producers of PV modules to mandatorily organize and finance the waste management of their used products. Including PV modules in the Directive has ensured that the entire sector will have to participate in the waste management of PV panels. A novelty for those companies not yet affiliated with a voluntary scheme.
A result of intensive information campaigning of the PV industry, PV producers will not have to bear a share of the costs of other consumer products included within the WEEE regulation, which at the moment are being recycled in much higher numbers than PV modules with their +25-year lifetime. Recycling of panels will grow significantly only in ten or twenty years, when large quantities of new panels installed during the last decade will arrive at the end of their lifespan.
This important achievement, however, does not exclude PV companies to take up a number of other responsibilities connected with WEEE compliance:
- Register in all EU countries in which they are considered to be producer
- Periodically report the PV modules they sell to the national WEEE registers
- Organize and finance the treatment of their PV module waste – individually or via an accredited collective scheme
- Inform the end customers on how they must dispose of their PV modules
- Inform treatment facilities of their product’s composition and the potential use of hazardous materials
- Mark their products with a crossed-out wheelie bin
An important requirement that PV producers need to take into consideration is national WEEE compliance. In most countries, producers will now have to subscribe to take-back and recycling schemes recognised by the national governments in order to put PV modules onto these countries, as is the case in the UK, France, the Czech Republic or Spain.
In France, for example, the transposition of the WEEE directive is expected to be finalised by mid-2014 and PV companies need to register with an accredited scheme. As expected under a legal framework, WEEE sets strict deadlines and mandatory requirements: If producers fail to register with an accredited scheme in due time, they will have to retroactively pay a fee based on the number of PV modules placed on the market between the entry into force of the legislation and their registration. Additional penalties might arise should they not respect the deadline for signing up to a scheme.
Germany and Italy, today’s biggest PV markets in Europe, are expected to allow for both industry-managed and individual take-back and recycling schemes, leading into competition amongst those offering WEEE-compliance services but also a more complex compliance procedure.
The full commentary will be published in the March/April edition of Renewable Energy Focus. To view the article, or to receive our weekly e-newsletter, subscribe online today.
ABOUT THE AUTHOR
Jan Clyncke joined PV CYCLE as Managing Director in April 2008. He has vast experience in setting up voluntary as well as mandatory take-back schemes in Belgium and the Netherlands, especially of packaging, tire, oil, electrical and electronic equipment, glass and photochemical waste.
Clyncke graduated with a Bachelor of Law from the University of Ghent in 1991 and continued his studies at Ehsal and Vlerick Management School. In his early career he worked as Manager Production & Logistics in the meat industry before moving into the waste management sector. He was employed by the Dutch AVR-Van Gansewinkel Group, where he worked as project manager, legal environment and government affairs manager for the Benelux countries.
Prior to joining PV CYCLE, Clyncke was also was responsible for health, safety and environment at AVR-Van Gansewinkel.
Posted 20/03/2014 by Reg Tucker
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