Solar panel recycling in the US: state laws, EPA's pending rule and how much panel waste is coming

Ledger of state and federal solar panel end-of-life laws and rules

Checked after each state legislative session and each Unified Agenda release, against statute text and agency pages. Last checked 2026-11-05. Entries are neutral records of public data; each links to its source record.

Solar panel recycling laws: nine states have acted, and only Washington requires producer takeback

The ledger above records each enacted measure with its citation and date. Most states regulate old panels only through general waste law; the nine that went further split into five types, and only four reach beyond studies or rules for recyclers.

Washington is the only state with producer takeback. RCW 70A.510 requires manufacturers to fund collection and recycling of modules sold after July 1, 2017, at no cost to the last owner. Plans are due January 31, 2030, and from January 31, 2031 no manufacturer, distributor, retailer or installer may sell a panel whose maker lacks an approved plan. Ecology asked for the most recent delay because some manufacturers stopped selling in the state rather than comply.

California and Hawaii use the universal waste route. DTSC rules effective January 1, 2021 let hazardous PV modules be handled, stored and shipped under lighter universal waste standards, and Hawaii added solar panels to HAR chapter 11-273.1 effective June 7, 2021 (EPA authorization notice). These rules make compliant handling easier; they do not require recycling.

North Carolina and Maine tie recycling to decommissioning. Under S.L. 2023-58, owners of ground-mounted projects of 2 MW AC or more must reuse or recycle components practicably capable of recycling, including PV modules, with registration and plan rules effective November 1, 2025. Maine's 35-A MRSA §3491, as amended in 2023, defines decommissioning to include recycling of recyclable components for projects on 3 or more acres (Maine DEP).

New Jersey's S3399, approved January 12, 2026 as P.L.2025, c.211, requires owners to remove and recycle or refurbish solar facilities after use, with compliance due 180 days after the state environmental agency finds recycling facilities accessible (bill summary; Resource Recycling). The official legislature text could not be retrieved for this report, so the entry is marked as corroborated rather than agency record.

Texas regulates the recyclers instead: HB 3229, effective September 1, 2025, requires facilities that take solar, wind and battery components to report inventory each January 15 and hold financial assurance equal to 100% of an engineer's cost estimate, with penalties up to $500 a day.

Universal waste: A federal and state category of hazardous waste, such as batteries and lamps, that may be collected and stored under simpler rules than other hazardous waste, provided it goes to a proper recycler or disposal site.

EPA's universal waste rule for solar panels is still unproposed, 36 months after it was announced

Federal law treats a discarded panel as solid waste, and as hazardous waste only if it fails the toxicity test. EPA has promised a simpler universal waste pathway since 2023, but the proposal keeps slipping.

Under RCRA, a panel becomes solid waste when it is discarded; it is also hazardous waste if lead or cadmium leach above toxicity limits in the TCLP test, and EPA says some panels pass while others fail, even within the same model and manufacturer (EPA, updated September 30, 2026).

On October 23, 2023, EPA announced a rule to add hazardous waste solar panels to the universal waste regulations, responding to a November 19, 2021 industry petition (EPA rulemaking page). The Spring 2025 Unified Agenda set the proposal for February 2026 (reginfo.gov); the 2026 edition moved it to August 2026 (reginfo.gov).

A Federal Register search on November 5, 2026 returned 0 documents for RIN 2050-AH32 (Federal Register API). Until a rule is final, and then adopted by each authorized state, generators must make their own hazardous waste determination outside California and Hawaii.

US solar panel waste: 0.17 to 1 million tonnes by 2030, 7.5 to 10 million by 2050

The EPA and DOE pages that quote a US tonnage both cite one 2016 IRENA and IEA-PVPS model. Its two scenarios differ by a factor of 5.9 in 2030, and NREL warns the model's deployment path is already too low.

IRENA's regular-loss scenario assumes a 30-year life and gives 170,000 tonnes of cumulative US waste by 2030 and 7,500,000 by 2050; the early-loss scenario, which adds early failures, gives 1,000,000 and 10,000,000 (IRENA/IEA-PVPS 2016, Table 6). EPA and DOE both cite this model (DOE SETO).

NREL estimated in 2021 that modules already installed would eventually yield 7.6 million to 9.5 million tonnes, at 80 to 100 tonnes per MW, and noted industry reports that real volumes run ahead of the IRENA path because of repowering at 10 to 12 years and storm damage (NREL/TP-6A20-74550).

For scale, NREL researchers project 54 million to 160 million tonnes of PV module waste worldwide by 2050, the upper figure a worst case (NREL, 2023), and North Carolina found that landfilling every panel in the state at once would equal less than 10% of one year of its municipal landfill tonnage (NC DEQ, 2021).

522.0 MW of utility-scale panels turn 25 by 2035, then the volume climbs steeply

Using generator install years in Form EIA-860 2025, ECW counts utility-scale PV by cohort and converts it to module mass. The first 25-year cohort is small and concentrated; each later cohort is several times larger.

Utility-scale generators installed in 2010 or earlier total 522.0 MW DC, or 41,760 to 52,200 tonnes of modules at NREL's 80 to 100 t/MW. Adding the 2011 to 2015 cohort gives 1.26 million to 1.57 million tonnes reaching 25 years by 2040, and all capacity installed through 2025 implies 15.9 million to 19.9 million tonnes eventually (EIA-860 2025).

The 2021 to 2025 cohort is 262.2 times the 2010-and-earlier cohort. Thin-film CdTe makes up 36.8% of the oldest cohort, which matters because at least one US manufacturer runs dedicated recycling for thin-film modules (EPA), and 2.2% of that cohort has already retired.

California alone holds 109.1 MW DC of the oldest cohort (20.9%), and California, Nevada, New Jersey, Florida and Colorado together hold 68.2%. By 2040 the map widens to 35 states, led by California, North Carolina and Arizona.

Recycling recovers mostly glass and aluminum and costs 3 to 15 times more than landfill

By weight a panel is mostly glass and aluminum, which existing recyclers already take. The economics are the barrier: published federal-lab figures put recycling well above landfill fees.

A crystalline silicon module is 77% glass, 10% aluminum, 3% silicon and 9% polymers by weight, with under 1% copper, silver and tin and under 0.1% lead; CdTe modules are 80-85% glass (NREL, 2023). EPA notes that many recyclers recover glass, aluminum and copper and may incinerate the cells (EPA).

NREL reported recycling at $15-45 per module in 2021. At $26 to $89 per US ton, a 33 to 50 lb module costs $0.43 to $2.23 to landfill as nonhazardous waste and up to $4.38 at a $175 hazardous waste landfill, ECW calculations that reproduce NREL's figures (NREL/TP-6A20-74124). Even the low recycling price is 15 times the nonhazardous landfill bound and 3 times the hazardous one.

Europe, where producers must fund recycling, reports costs as low as $0.70 per module and recycling rates up to 95%, according to the same NREL survey. DOE still describes US recycling as generally more expensive than landfill disposal.

What the rules mean for installers, roofers and system owners

Who handles an old panel, and under which rule, depends on the state and the size of the system. This section summarizes the published requirements; it is not legal advice.

• Residential removals and reroofs: outside Washington's future takeback program and New Jersey's pending rules, no law in the ledger requires a homeowner's panels to be recycled. EPA tells homeowners to check with state or local recycling agencies.
• Hazardous waste determination: a contractor or owner discarding panels is the waste generator and must determine whether the panels are hazardous waste, by testing or knowledge, unless a state rule such as California's or Hawaii's applies.
• Utility-scale work: in North Carolina (2 MW AC or more) and Maine (3 acres or more), decommissioning plans must route recyclable components, panels included, to recycling.
• Washington sales from January 31, 2031: distributors, retailers and installers may not sell or install panels whose manufacturer lacks an approved stewardship plan, and the state can warn installers directly.
• Reuse: EPA notes secondary-market reuse faces interconnection, fire, building and electrical code questions, which must be checked before panels are reinstalled.

Removing modules involves energized DC conductors even when the inverter is off, because panels generate voltage in daylight. Removal and reinstallation should be done by a licensed electrician or a qualified solar contractor; this report does not describe the procedure.

Related ECW data: install prices are in average cost of solar panels, credits in solar tax credit, export rules in net metering by state, battery prices in solar battery cost, installer pay in solar installer salary, and trade coverage in EV, solar and low voltage.

Counts from the ledger

Get the calculations (CSV)

The numbers that matter

1. As of November 5, 2026, the Federal Register lists 0 documents for RIN 2050-AH32, EPA's planned rule to add solar panels to the universal waste regulations.^[6]
2. EPA's proposed-rule target moved 6 months, from February 2026 in the Spring 2025 Unified Agenda to August 2026 in the 2026 edition.^[4][5]
3. Washington's RCW 70A.510 requires manufacturers to file takeback plans by January 31, 2030 and bars sales of panels without an approved plan from January 31, 2031.^[8]
4. Washington's sales ban was delayed 5.6 years, from July 1, 2025 to January 31, 2031, by a 2025 act effective June 30, 2025.^[8][9]
5. Washington's stewardship plans must reach a combined reuse and recycling rate of at least 85% of collected module weight, with penalties up to $10,000 per sale.^[8]
6. California has managed hazardous end-of-life PV modules as universal waste since January 1, 2021; Hawaii added solar panels to its universal waste rules effective June 7, 2021.^[10][7]
7. North Carolina requires owners of solar projects of 2 MW AC or more to reuse or recycle components including PV modules at decommissioning, effective November 1, 2025.^[18][19]
8. New Jersey's P.L.2025, c.211, approved January 12, 2026, gives facility owners 180 days to comply once DEP finds recycling facilities accessible.^[15][16]
9. IRENA/IEA-PVPS projects cumulative US end-of-life PV panel waste of 170,000 to 1,000,000 tonnes by 2030 and 7,500,000 to 10,000,000 tonnes by 2050.^[28]
10. NREL estimated in 2021 that modules installed in the US by 2020 will eventually produce 7.6 million to 9.5 million tonnes of end-of-life mass.^[30]
11. ECW estimate: utility-scale PV installed through 2025 (198,646.6 MW DC in EIA-860 2025) implies 15.9 million to 19.9 million tonnes of modules, 2.09 times NREL's low 2021 estimate.^[33][30]
12. California holds 20.9% of the 522.0 MW DC of utility-scale PV installed in 2010 or earlier; five states hold 68.2%.^[33]
13. NREL reports US recycling costs of $15-45 per module, against less than $1 at a nonhazardous landfill and less than $5 at a hazardous waste landfill.^[29]
14. A crystalline silicon module is 77% glass, 10% aluminum, 3% silicon and 9% polymers by weight, with under 0.1% lead (NREL, 2023).^[31]

In short

• No federal law requires solar panel recycling. Panels are solid waste when discarded and hazardous waste only if they fail the toxicity test (EPA, 2026).
• EPA announced on October 23, 2023 that it would propose adding solar panels to the universal waste rules; as of November 5, 2026 no proposal has been published, and the agenda target has slipped from February 2026 to August 2026.
• Nine states have enacted a solar panel end-of-life measure. Washington is the only state with producer takeback, now delayed to January 31, 2031.
• North Carolina (from November 1, 2025, projects of 2 MW AC or more) and Maine (projects on 3 acres or more) require recycling when large solar projects are decommissioned; New Jersey's January 12, 2026 law requires recycling once DEP finds facilities accessible.
• IRENA projects 0.17 to 1 million tonnes of cumulative US panel waste by 2030 and 7.5 to 10 million tonnes by 2050; NREL says the 2016 model already understates today's fleet.
• ECW estimate from EIA-860 2025: utility-scale modules turning 25 grow from 41,760 to 52,200 tonnes by 2035 to 1.26 million to 1.57 million tonnes by 2040.
• NREL reports recycling at $15-45 per module against less than $1 at a nonhazardous landfill, which is why fewer than 10% of US end-of-life modules are recycled.

Common questions

Keep reading

• Average cost of solar panels
• Solar tax credit
• EV, Solar and Low Voltage guide
• Solar tax credit 2026: the federal credit has ended, and this is who claimed it by state and income
• Transformer Shortage: Prices, Lead Times, Imports and Policy in Federal Data, 2019 to 2026
• Whole House Generator Cost in 2026: List Prices, Price per kW, Permits and Safety Records
• All electrical contractor data

How we built this report

Selection: the ledger includes state statutes and agency rules that address PV module end of life through stewardship, universal waste, recycling at decommissioning, recycling mandates, recycler regulation or study mandates. Each entry was checked against statute text or an agency page opened on November 3 to 5, 2026. Decommissioning-bond laws with no recycling or waste element, local ordinances and bills not enacted are excluded from the count and noted separately.

Evidence levels: 'agency record' means a statute, rule or agency page; 'own statement' means a sponsor or agency announcement; 'corroborated' means a bill tracker summary confirmed by trade press. New Jersey's 2026 law is corroborated only, because the official legislature site timed out during this check.

Federal status comes from EPA's rulemaking page, two Unified Agenda editions for RIN 2050-AH32 and a Federal Register API query by RIN on November 5, 2026.

Projections are quoted as published. IRENA and NREL report metric tonnes; EPA and DOE write tons when restating IRENA. Where sources conflict, both values are shown side by side rather than averaged.

ECW estimate: utility-scale PV generators (1 MW AC and larger) from Form EIA-860 2025 final data (released September 10, 2026), operable plus retired units, grouped by operating year. DC net capacity is used, with AC nameplate for the 9 units missing DC, 8 of them installed in 2010 or earlier. Mass = MW DC x 80 to 100 t/MW (NREL/TP-6A20-74550); a 61.2 t/MW sensitivity uses the Minnesota study's 3,000 panels per MW at 45 lb. A 25-year life is assumed. The code is in scripts/eia_cohorts.py and build_data.py.

Limitations: rooftop and small systems are excluded from the state estimate because Berkeley Lab's Tracking the Sun data could not be downloaded; cost figures are anecdotal 2019 to 2020 ranges from NREL's 2021 survey; no newer federal cost study was found.

This page was last updated 2026-11-05. The ledger is rechecked after each state legislative session and each Unified Agenda release. Nothing here is legal, tax or safety advice.

This report presents published data with its limitations. It is not legal, financial or investment advice.

Sources by tier

Tier 1: primary and official sources (29)

• [1] U.S. Environmental Protection Agency. End-of-Life Solar Panels: Regulations and Management (last updated September 30, 2026). Page as of 2026. Accessed 2026-11-03.
• [2] U.S. Environmental Protection Agency. Solar Panel Recycling. Page as of 2026. Accessed 2026-11-03.
• [3] U.S. Environmental Protection Agency. Improving Recycling and Management of Renewable Energy Wastes: Universal Waste Regulations for Solar Panels and Lithium Batteries (last updated July 31, 2026). Rulemaking status page. Accessed 2026-11-03.
• [4] Office of Information and Regulatory Affairs, reginfo.gov. RIN 2050-AH32, Spring 2025 Unified Agenda entry. Spring 2025 agenda. Accessed 2026-11-03.
• [5] Office of Information and Regulatory Affairs, reginfo.gov. RIN 2050-AH32, latest Unified Agenda entry (edition labeled 2026). 2026 agenda. Accessed 2026-11-03.
• [6] Office of the Federal Register. Federal Register API: documents associated with RIN 2050-AH32. Queried 2026-11-05. Accessed 2026-11-05.
• [7] U.S. EPA, Federal Register. Hawaii: Final Authorization of State Hazardous Waste Management Program Revisions (FR Doc. 2022-09430). Published 2022-05-03. Accessed 2026-11-05.
• [8] Washington State Legislature. RCW 70A.510: Photovoltaic module stewardship and takeback program. Current through 2025 c 126. Accessed 2026-11-03.
• [9] Washington State Department of Ecology. Solar panels (PV module stewardship program). Page as of 2026. Accessed 2026-11-03.
• [10] California Department of Toxic Substances Control. Photovoltaic Modules (PV modules): Universal Waste Management Regulations (Internet Archive copy, January 23, 2026). Rules effective 2021-01-01. Accessed 2026-11-03.
• [11] California Legislative Information. AB-2 Recycling: solar photovoltaic modules, bill history (Internet Archive copy, September 20, 2025). 2023 to 2024 session. Accessed 2026-11-03.
• [12] Hawaii Department of Health. Hawaii Administrative Rules chapter 11-273.1, Standards for Universal Waste Management. Compiled July 7, 2025. Accessed 2026-11-05.
• [13] New Jersey Department of Environmental Protection. Solar Panel Recycling Commission (Internet Archive copy, January 19, 2026). Page as of January 2026. Accessed 2026-11-05.
• [17] North Carolina Department of Environmental Quality and Environmental Management Commission. Final Report on the Activities Conducted to Establish a Regulatory Program for the Management and Decommissioning of Renewable Energy Equipment (S.L. 2019-132). Due January 1, 2021. Accessed 2026-11-05.
• [18] North Carolina General Assembly. Session Law 2023-58 (Internet Archive copy, August 5, 2025). Became law 2023-06-26. Accessed 2026-11-05.
• [19] North Carolina General Assembly. G.S. 130A-309.240 (Internet Archive copy, May 31, 2025). Statute text. Accessed 2026-11-05.
• [20] Maine Legislature, Revisor of Statutes. Title 35-A, §3491: Definitions (Chapter 34-D, Solar Energy Development Decommissioning). Current statute. Accessed 2026-11-05.
• [21] Maine Department of Environmental Protection. Solar Decommissioning. Page as of 2026. Accessed 2026-11-05.
• [22] Maine Legislature, Revisor of Statutes. Title 38, §1306: Prohibition. Current statute. Accessed 2026-11-05.
• [23] Maine State Law and Legislative Reference Library. LD 826 (131st Legislature): An Act to Prohibit the Disposal of Certain Solar Panels in the State. Introduced 2023-02-21. Accessed 2026-11-05.
• [24] Minnesota Pollution Control Agency. Reuse and recycling of solar installations at the end of life: Report to the Legislature (February 2025). February 2025. Accessed 2026-11-05.
• [25] Illinois General Assembly. 20 ILCS 4118/15, Renewable Energy Component Recycling Task Force: duties and report (Internet Archive copy, September 2, 2025). P.A. 102-1025. Accessed 2026-11-05.
• [26] Texas Legislature Online. HB 3229 (89th Legislature, Regular Session) bill history. Effective 2025-09-01. Accessed 2026-11-05.
• [27] Texas Legislature Online. HB 3229 enrolled text. Enrolled 2025. Accessed 2026-11-05.
• [29] National Renewable Energy Laboratory (now National Laboratory of the Rockies). Solar Photovoltaic Module Recycling: A Survey of U.S. Policies and Initiatives (NREL/TP-6A20-74124). March 2021. Accessed 2026-11-05.
• [30] National Renewable Energy Laboratory (now National Laboratory of the Rockies). A Circular Economy for Solar Photovoltaic System Materials (NREL/TP-6A20-74550). Revised April 2021. Accessed 2026-11-05.
• [31] National Laboratory of the Rockies (formerly NREL). Photovoltaic Toxicity and Waste Concerns Are Overblown, Slowing Decarbonization (news, November 14, 2023). 2023 study, page updated 2026-04-28. Accessed 2026-11-05.
• [32] U.S. Department of Energy, Solar Energy Technologies Office. End-of-Life Management for Solar Photovoltaics. Page as of 2026. Accessed 2026-11-05.
• [33] U.S. Energy Information Administration. Form EIA-860 Annual Electric Generator Report, 2025 final data (Schedule 3_3 Solar), released September 10, 2026. Generators as of end of 2025. Accessed 2026-11-05.

Tier 2: trade bodies, market research, company data (2)

• [14] New Jersey Senate Democrats. Smith, Greenstein Bill to Establish New Jersey Solar Panel Recycling Commission Signed into Law (Internet Archive copy). Released 2019-08-12. Accessed 2026-11-05.
• [28] International Renewable Energy Agency and IEA PVPS. End-of-Life Management: Solar Photovoltaic Panels (IRENA and IEA-PVPS Task 12). Published June 2016, projections to 2050. Accessed 2026-11-05.

Tier 3: journalism and expert commentary (2)

• [15] BillTrack50. NJ S3399 (2024 to 2025): Requires end-of-life recycling of solar and photovoltaic energy generation facilities. Approved 2026-01-12. Accessed 2026-11-05.
• [16] Resource Recycling. S3399 signals a shift in how states are tackling solar panel waste. Published 2026-04-06. Accessed 2026-11-03.