This week, CALSSA published a fact sheet detailing how to comply with the California Department of Toxic Substances Control’s (DTSC) new regulations on handling “end-of-life” PV modules. The regulations apply to panels that are damaged, inoperable, or decommissioned. If you are an installer, manufacturer, operations and maintenance company, distributor, or practically any business that touches end-of-life modules, you will need to follow the new regulations.
The suite of regulations is the result of the DTSC allowing end-of-life modules to be managed as universal waste. Previously DTSC regulations called for end-of-life PV modules to be managed as hazardous waste, which required the industry to follow onerous requirements, though they were rarely enforced. While the universal waste regulations are less stringent than the previous hazardous waste regulations, we expect the DTSC may increase enforcement and assess fines to those not in compliance.
The regulations remove barriers to recycling end-of-life PV modules, but more policy change is needed for PV recyclers to open shop in California. While CALSSA continues to advocate for policies that enable a healthy recycling market in the state, we strongly encourage companies to recycle modules, if they cannot be reused, with one of CALSSA’s recycling member companies in Nevada and Arizona. For more information on reusing and recycling, please see FAQ #1 in the fact sheet.