Solar Panel Frequent Questions
On this page:
- Can solar panels be managed as a universal waste?
- Are solar panels analogous to spent circuit boards when managed under the Resource Conservation and Recovery Act (RCRA)?
- Is transportation of waste solar panels from offshore territories of the United States (American Samoa, Guam, the Northern Mariana Islands, Puerto Rico and the U.S. Virgin Islands) to the mainland United States considered importation?
- Are solar panels hazardous waste?
- Do waste solar panels need a manifest in transit?
- Can solar panels be recycled using the transfer-based exclusion found in Title 40 of the Code of Federal Regulations (CFR) section 261.4(a)(24)?
Can solar panels be managed as a universal waste?
- Solar panels are not a federal universal waste and generally cannot be managed as universal waste. However, some states have added solar panels as state-only universal waste. To view which states have adopted universal waste for solar panels, please visit the State Universal Waste Programs webpage.
- EPA received a petition to add solar panels as a federal universal waste and is initiating a proposed rulemaking effort to add solar panels as a federal universal waste.
Are solar panels analogous to spent circuit boards when managed under RCRA?
- No. Solar panels are not analogous to circuit boards. Solar panels are not covered by the shredded circuit board exclusion to the definition of solid waste and EPA has not found that solar panels contain sufficient metals to be considered scrap metal for the purpose of exclusion or exemption from hazardous waste regulation.
Is transportation of waste solar panels from offshore territories of the United States (American Samoa, Guam, the Northern Mariana Islands, Puerto Rico and the U.S. Virgin Islands) to the mainland United States considered importation?
- No, this is not considered importing of hazardous waste.
Are solar panels hazardous waste?
- Some solar panels are hazardous waste, and some solar panels are not hazardous waste, depending on the leachability of RCRA toxic materials present in the solar panel. EPA cannot say definitively if all solar panels are or are not hazardous waste. It is the responsibility of the generator of the solar panel waste to determine if solar panels are hazardous by performing the appropriate tests or by using generator knowledge.
- Solid waste, including solar panels, is hazardous waste if it exhibits any of the four characteristics of hazardous waste (toxicity, ignitability, reactivity, corrosivity). The most common reason that solar panels would be determined to be hazardous waste is if they meet the characteristic of toxicity. Heavy metals like lead and cadmium may leach at such concentrations that waste panels would fail the toxicity characteristic leaching procedure (TCLP), a test required under RCRA to determine if materials are hazardous. If the generator of the solar panels knows from previous experience that the material would fail the TCLP test, they can determine that the waste is hazardous without the need for testing.
- Solar panel waste that fails TCLP must be managed as hazardous waste.
- For information about the requirements that apply to international shipments of solar panels that are hazardous waste, please visit the webpages on the RCRA hazardous waste export and import requirements.
- Homeowners with solar panels on their houses should contact their state/local recycling agencies for more information on disposal/recycling.
Do waste solar panels need a manifest in transit?
- If solar panels are hazardous waste (e.g., TCLP was performed, and the solar panels failed the test for lead), then they would need to be transported under a manifest.
- Solar panels that are not hazardous waste (e.g., TCLP was performed, and the solar panels did not fail for lead or any other toxic contaminants), they do not need to be transported under a manifest. However, state rules may be more stringent.
- Other regulations from the U.S. Department of Transportation (DOT) may apply to solar panel waste in transport. For more information on DOT regulations, please contact the Pipeline and Hazardous Materials Safety Administration.
Can solar panels be recycled using the transfer-based exclusion found in 40 CFR section 261.4(a)(24)?
- Solar panels can be recycled using the transfer-based exclusion if the state(s) in which the solar panel waste is generated and recycled have adopted the 2015 or 2018 Definition of Solid Waste (DSW) Rule and the requirements found in section 261.4(a)(24) are followed. For information on where the 2015 or 2018 DSW rules are in effect, please visit the DSW State Adoption Webpage.