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ESG Update – Draft guideline for storage and handling of waste solar photo-voltaic modules or panels or cells.

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Introduction:

The Central Pollution Control Board (CPCB) has prepared a draft guideline for storage and handling of waste solar photo-voltaic modules or panels or cells. The management of E-Waste in India is presently regulated under E-Waste (Management) Rules, 2022. The CPCB has invited comments/ suggestions on the guidelines for storage and handling of Solar PV waste  panels or cells (if any) to be communicated by June 25, 2025.[1]

The Ministry of Environment Forest & Climate Change (MoEFCC), Government of India, has notified E-Waste (Management) Rules, 2022 for the effective management of the E-Waste in the country. The rules encompass the management of waste electrical and electronic equipment (EEE), including their components, consumables, parts and spares including solar photo-voltaic modules or panels or cells, whole or in part discarded as waste, as well as rejects from manufacturing, refurbishment and repair processes. Accordingly, the rule describes a total of 106 categories of electrical and electronic equipment including solar photovoltaic panels/cells/modules, (As described in Schedule-I of the rules) which has been categorized as CEEW 14 in terms of EEE Code.

Applicability:

The management of solar photo-voltaic modules or panels or cells are covered under the Chapter- V of the E-Waste (Management), Rules, 2022, where the manufacturers, producers and the recyclers of solar photo-voltaic modules or panels or cells have been assigned responsibilities to ensure the compliance with the said rules through registration, storing the waste solar photo-voltaic modules or panels or cells up to the year 2034-35, filing annual returns on the portal, and ensuring compliances with the guidelines and standard operating procedure (SOP) laid down by CPCB.

These guidelines are intended to provide technical guidance to transport, handle and store the waste generated from Solar photo-voltaic panels or modules or cells including their components, consumables, parts and spares (hereinafter will be referred as Solar Waste) in an environmentally sound manner which shall protect the health and environment. The guidelines shall be applicable to the producers, manufacturers and recyclers of solar photo-voltaic panels or modules or cell.

Environmental and Health Risks of improper solar waste disposal:

While renewable energy generation and in particular, solar energy installations are crucial for a sustainable future, we face a significant challenge in management of end-of-life solar photovoltaic (PV) modules. Improper disposal of these panels may have following environmental risks, while sustainable recycling offers a multitude of benefits:

  • Heavy metal contamination: Lead, Cadmium, Arsenic, etc. may contaminate soil/leach into water bodies.
  • Air Pollution: Burning of such waste in unscientific manner can release toxic fumes into the environment.
  • Health concerns: Handling of such waste in an unscientific manner may cause adverse health impact.

Benefits of recycling end of life solar panels:

On the other hand, scientific and proper recycling of such waste prevent from damage to environment and can generate substantial amount of recovered material which can be further used as raw material thus reducing the need to extract new raw material conserving the energy and earth’s resources.

Material Composition of solar panels:

Solar panels consist of recyclable and non-recyclable materials such as:

  1. Glass
  2. Aluminium frame
  3. Silicon wafers
  4. Metals (copper, silver, lead, cadmium, tellurium, gallium, arsenic and tin)
  5. Plastics

The Guidelines for Transportation, Handling, and Storage of Solar Photovoltaic Modules, Panels, or Cells Waste:

These guidelines lay down procedures to ensure safe, environmentally responsible management of solar waste. Solar waste must never be dumped in open areas or sold to unauthorized entities, as improper disposal can release toxic chemicals and pose serious environmental hazards. Producers and manufacturers are required to assess storage needs and establish a collection mechanism, which may include take-back schemes facilitated through dealers or other stakeholders. It is also essential that the details of these collection systems, such as take-back schemes and designated collection points, are publicly communicated.

Furthermore, producers must provide consumers and bulk consumers with relevant details of their take-back system. This includes the link to the company website containing the system’s information, a contact number for queries and grievances, details of collection points or pick-up vans linked to collection centres, and names of authorized recycling facilities. Producers are also encouraged to maintain a database of consumers and site details at the time of sale to facilitate future collection efforts.

Transportation of solar waste must be done using covered trucks, and where possible, those authorized to transport hazardous waste should be used. When waste is being transported for final disposal, all relevant provisions of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 must be followed.

Guidelines for the storage and handling of solar waste:

The guidelines emphasize that solar waste should be stored in a manner that prevents breakage and is safe for workers. Sharp objects and collisions must be avoided to protect the internal components of the modules. Storage should not compromise the potential for reuse, refurbishing, or recycling, and must not cause harm to the environment or human health.

Storage areas must be covered, dry, and well-ventilated, with impervious, non-leachable flooring to prevent contamination from metals such as antimony, cadmium, arsenic, lead, and selenium. Stacking should not exceed 20 layers or 2 meters in height, whichever is less. The area should also be equipped with fire protection systems, clearly marked emergency exits, and a comprehensive Emergency Response Plan (ERP).

Each storage container or rack must be clearly labelled with the type of solar waste it holds to facilitate identification during recycling. Regular inventory checks and inspections should be carried out to record and monitor any potential damage. Lastly, the required space for storage of solar PV modules, panels, or cells, categorized under CEEW 14 e-waste, should be at least 19.5 cubic meters per tonne.

Conclusion:

By placing an emphasis on the safe transportation, handling, collection and storage of solar PV panels, the guidelines are a significant step towards ensuring there is now a framework in place for the formal management solar PV waste. However, the guidelines overlook the crucial role that informal waste recyclers can play in the management and recycling of solar PV waste.  To ensure inclusivity and efficiency, future iterations of these guidelines should actively consider strategies to train, formalize, and integrate informal workers into the broader framework for managing solar PV waste. This will not only strengthen compliance but also foster equitable and sustainable growth in the renewable energy sector


[1]https://cpcb.nic.in/openpdffile.php?id=UmVwb3J0RmlsZXMvMTc0NV8xNzQ5MDM0NjU5X21lZGlhcGhvdG8xMTY0Ni5wZGY=