The last few years have witnessed a major global shift towards renewable and sustainable modes of energy generation. With increasing focus on solar energy and subsequent capacity addition, the PV solar sector is growing rapidly. In India, solar energy and its implementation was first addressed during the 6th Five Year Plan (1980-85). However, solar energy in India did not receive the desired momentum until recently when the National Solar Mission was launched as one of the several measures under the National Action Plan on Climate Change in 2010. The mission was launched initially with a target of 20 GW by 2022 which was later revised to 100 GW. Under the revised targets, the ground mount solar systems of 60 GW and 40 GW of solar systems on rooftops are proposed to be installed by the year 2022. By the end of 2019, India has installed around 35 GWAC of solar PV capacity on ground and rooftops across the country.

As everywhere else in the world, the uptake of PV technology in India will generate waste. Solar PV modules are durable and long-lasting products and are expected to last 30 years or even longer. Thus currently, PV module waste generation as a result of end-of-life has very limited effects in the short and medium term, considering the fact that majority of PV systems has been installed after 2010. However, PV waste is not only generated once the expected end-of-life stage of the PV module is reached but also during transportation, installation and operation of the PV system. It is therefore important to carry out an assessment of PV waste generation over the next decades to provide solutions for a sustainable energy economy and to prevent adverse environmental impacts which could arise from the wrong practices of disposal of end-of-life PV modules and their components. The report, “PV Waste Management in India: Comparative Analysis of State of Play & Recommendations” developed in cooperation among the EU India Technical Cooperation Project, SolarPower Europe, PV CYCLE and National Solar Energy Federation of India provides key insights on this theme. It compares the EU and Indian regulatory settings and main policy drivers; analyses the PV module waste market in India, including the amount of waste generated, current waste treatment practices; and provides policy recommendations. The article provides an extract of the report…

Regulation framework in the EU and in India

Thereport highlights that there are important similarities and differences between both regions for waste treatment regulations relevant for waste generated from PV systems. In both regions, PV modules are considered as “one product, one equipment” – one does not apply a waste law to “components” of an equipment.

Whereas PV modules and inverters are under the scope of the EU WEEE Directive, the Indian E-Waste (Management and Handling) Rules are not applicable to PV modules and inverters because these rules only apply to two categories of electrical and electronic equipment that do not include PV products. In contrast, in the EU there is a so-called “open scope” whereby each electrical and electronic equipment falls under the scope of the WEEE Directive since August 2018.

Both the European WEEE Directive and the Indian E-Waste Rules are based on the Extended Producer Responsibility (EPR) principle, foresee mandatory collection targets and are mainly focused on consumer electronic waste.

There are comprehensive Industrial Solid Waste Rules in place in India, but they do not include solar PV within their scope, whilst the European Union has its Waste Framework Directive which settles the basis requirements for each waste type irrespective of EPR legislation or other specific legislation which might come on top.

C-si PV modules are not considered as hazardous waste under the Indian Hazardous and Other Waste Rules. While in 2019, the MNRE issued a draft blueprint addressing the potential issue of antimony leaching from landfilled solar glass, leaching of antimony from solar glass would occur only in a worst-case end-of-life management scenario in which modules are dumped in an uncontrolled landfill and the solar glass is completely crushed. However, even in this scenario antimony concentration would be significantly below the threshold set by the Hazardous and Other Waste Rules. A ban on landfilling PV modules would virtually eliminate the risk of leaching of antimony and other substances. Looking at the current policy framework around end-of-life PV products in India, the report recommends the following measures:

  • Impose a landfill ban for all equipment originating from a PV system.
  • Implement a legislative framework for voluntary or mandatory EPR for equipment coming from the renewable energy industry whereby the industry proposes through a five-year management plan its objectives and how to achieve these under supervision of the MNRE and/or MOEF.
  • Create a self-standing EPR legislation for PV modules separately from the E-Waste Rules. As PV technology, which is outside the scope of the E-Waste Rules, will become the cornerstone of the energy transition, it is recommended to set out a separate legislation instead of adapting rules from the E-Waste Rules legislation.
  • Allow the Indian PV industry to propose a sustainable and long-term solution for the waste generated by a PV system taking into account that PV modules have a very long lifetime and today’s generated waste is by far not attractive to enable big industrial waste treatment capacity for PV modules.
  • The development of such a legislation can be supported by the current study taking into economic, technological, social and environmental characteristics of India, including technologies of material recovery, market price of recyclables, collection and recycling business models (deposit systems, subsidy systems etc), recycling fees and cost implications for electricity costs and Indian solar businesses, and an implementation roadmap.
  • Once this preparatory study has been conducted, a separate piece of Indian legislation for the end-of-life management of PV modules should be developed. The new legislative framework should include the scope inverters and other PV system components. While it is too early to determine whether inverters and other PV components should be part of the same legislation for PV modules or rather be part of the E-Waste Rules, it will be key to ensure synergies across the different pieces of legislation and to optimise the economic, social and environmental dimensions in waste collection and treatment.

PV waste scenarios in India

Looking at the PV capacity annually installed in India from 2010 to 2020, it can be noted that the PV market effectively started in 2012, and boomed only in 2017. Compared to current installation levels, the annual PV market is expected to grow significantly across all three scenarios investigated in the study. By 2030, the cumulative installed capacity experiences a multifold growth across all scenarios. Under the Low and Medium scenarios cumulative capacity reaches 187 GW and 287 GW respectively, up from 40 GW in 2020. The High scenario capacity reaches 400 GW by 2030, in line with government ambition. Assuming that PV systems installed in 2020-2030 have a lifetime of at least 30 years, any capacity installed during this period will reach the end-of-life stage not before 2050.

Given that ground-mounted solar constitutes the vast majority of PV capacity, and that the residential segment is only a fraction of rooftop installations, it can be concluded that the greatest bulk of end-of-life PV waste will be deriving from B2B relations.

According to the analysis carried out in the context of this study, by the year 2030 India will generate a cumulative mass of PV module waste of 11 kilo tonnes (kt) in the Low scenario, 21 kt in the Medium scenario, and 34 kt in the High scenario. The waste generated due to the end of life of the PV modules would start accumulating only around after the year 2040 and will become rapidly the most relevant waste source.

In India there is no policy in respect to dealing with the waste generated by PV modules as they are neither included in e-waste, nor in hazardous waste regulations. Presently the module waste is treated in the following ways:

In this process approximately 50 per cent of the total material is revived back today from recycling. The treatment facilities classify the PV module waste (or its components) as hazardous waste or e-waste in India. In general, around 20 per cent of the waste is recovered and the remaining part is treated by TSDFs upon payment of disposal fees. This results in cost implications to the owner or holder of the PV modules waste. A few holders or owners of PV modules waste having their internal environment management system, follow an informal practice to manage the PV modules waste.

However, the fee for dumping and disposing the waste in India is not properly defined and due to the lack of rules and inspection, the PV modules waste have a risk ending up in uncontrolled landfills or in open land.

Possible business models for PV waste management in India

Overall, this study recommends the EPR approach as the best one for the Indian context, as it constitutes the most effective means to perform sound PV waste management. It is advised to implement an EPR law for PV modules which sets the principle of a producer responsibility for PV modules and – where required – other products of a PV system, such as inverters and batteries.

Several EPR policy instruments and measures are available to governments to help them meet their stated goals and objectives: product take-back, deposit/refund, advanced disposal fees, product/material taxes, combined upstream tax and subsidy and minimum recycling requirements. Policymakers should review these different instruments to identify which might best meet their particular needs. An instrument’s applicability depends on policy goals, or the influence or pressure necessary to reduce environmental impacts of concern. Several types of supportive measures can be used to enhance the effectiveness of an EPR policy.

Such measures should be selected in light of the policy goals. Selection criteria can help policy makers select an EPR policy instrument that best suits their needs. These criteria are environmental effectiveness; economic efficiency; political acceptability; ease of administration; and innovative advancement.

Governments need to select the responsibility model and assign precise physical and financial responsibility. The level or degree of producer responsibility for the EPR program is a crucial decisional point in EPR policy design. Decisions on the allocation of responsibility should be made in view of the policy goals, product characteristics, market dynamics, actors in the product chain and resources needed to implement the policy. The national government, state and local authorities, the retailer, the consumer and the final owner of the waste all play important roles under EPR therefore measures should take into account all these stakeholders. In several cases, a producer responsibility organisation (PRO) could be a useful option for managing and collecting products in lieu of each producer establishing its own separate system.

It is plausible that complete removal of free rider behaviour – the one of actors in an EPR system who do not pay for the benefits they receive – may not generate sufficient environmental benefits to justify the administrative costs to minimize free riders. Policymakers and PROs need to analyse the incentives they create for the various actors operating in an EPR system through different pricing structures and legal liabilities, to ensure (as far as possible) that these are consistent with the ultimate goals and objectives of the EPR program and with overall economic efficiency. Under mandatory EPR programs, government enforcement against free riders may be needed to assure fairness to producers that carry out their EPR responsibilities.

Decisions with regard to orphan and existing products must be also taken. Most EPR schemes cover partly or fully the net costs for the management of waste that has been separately collected, as well as administrative, reporting and communication costs relative to the operation of collective schemes. For photovoltaic modules, the administrative costs shall be similar as in each EPR-environment. The challenge is the operational costs, where almost no waste occurs whilst the fixed administrative costs exist. The creation of provisions or funding for future waste management is crucial in order to be able as solar industry to manage the upcoming waste environmentally sound in the (near) future. A draft financing model for an Advanced and Visible Disposal Fee is therefore recommended. Following are the recommendations for the setting of an EPR system:

  • Set up a five-year management plan. The plan should define the strategical vision and contain information including prevention, communication, sensitize and financial plans.
  • Do not set any collection target in the first phase of the EPR system. As PV modules are an investment product instead of a consumer product, a collection target can be set later on.
  • Set clear, realistic and appropriate treatment targets. It is recommend to have a target of 70 per cent, of which preparation for reuse and recycling of 55 per cent.
  • The visible fee approach seems the best fit to the Indian context. It drastically limits free riders, saves the cash of the producers/importers and puts the financial responsibility on the polluter whilst the legal responsibility remains on the producer/importer.
  • Ensure neutrality to competition. Lifting regulatory barriers to entry will decrease costs.
  • All PV modules sold in the Indian market should be within the scope of the EPR, irrespective of the size of the PV system.
  • Promote R&D on product design and material substitution. One way forward to stimulate this is through R&D funding programs towards the industry and the academic world, under the responsibility of the Indian government.
  • Encourage competition in the waste management sector. Lack of competition can lead to high costs for collection, sorting and treatment.
  • Boost consumer participation. A communication plan will help to inform the purchasers of PV modules and PV systems of their roles and responsibilities under the program.
  • Use life cycle analysis. Such analysis can help increase the acceptance of a program and lead to products’ environmental optimisation.
  • Establish monitoring systems. Governments and industry should cooperate to establish an effective, adequately resourced monitoring system, possibly through an independent body
  • Take into account the operational waste management infrastructure. The EPR program should not hinder the operation of existing efficient recycling programs.
  • Ensure dialogue among stakeholders. A specific dialogue mechanism must be established which shall solve contentious relationships among stakeholders.
  • Implement measures to enhance environmental effectiveness. Target setting and proper enforcement are among the approaches to do so.
  • Ensure strong transparency. Mandatory EPR systems should be required to report regularly on the technical and financial aspects of their operations, audits should be regularly conducted, while reporting should be harmonised.
  • Define a clear framework for possibility of reuse. Stakeholders should know upfront when and how a PV module can be “prepared for reuse” and under which conditions such a “prepared for reuse PV module” can be sold again as a second-hand product.

The full report can be read by clicking here