Photovoltaic (PV) Panel Waste Volumes

Summary

Beyond general waste regulations, various approaches have been developed specifically to manage end-of-life PV panel waste. In this series, the financial principles of panel waste management as well as the enabling framework headings are summarized. Germany: Advanced Market with EU-Directed, PV-Specific Waste Regulations

A PV Market and Waste Projection

Germany's projected end-of-life PV panel waste volumes will cumulatively range between 3,500 tons and 70,000 tons by 2016. This stems primarily from installed PV capacity. Figures vary depending on the scenario selected. By 2030 and 2050, during regular loss and early loss scenarios, projections are estimated between 400,000 tons and 1 million tons, and 4.3-4.4 million tons respectively. As explained previously, keeping in mind the uncertainties contained in these projections, it can be said that Germany will be one of the first and largest markets for PV recycling technologies in the coming years (Figure 1). a) Cumulative PV panel waste (million t), b) Normal loss scenario, c) Early loss scenario, d) Cumulative PV capacity, e) Cumulative PV capacity (GW).

National Obligations

The revised EU WEEE Directive (see previous sections) was transposed into German law in October 2015 through the revision of the Electrical and Electronic Equipment Act (Elektroaltgerätegesetz or ElektroG). Therefore, as of this date, new requirements regarding the collection and recycling of PV panels in Germany came into effect. Germany's e-waste management is regulated through the National Register of Waste Electrical Equipment (Stiftung Elektro-Altgeräte Register or Stiftung EAR). Stiftung EAR was established during the application of the original WEEE Directive by manufacturers as a clearinghouse (Gemeinsame Stelle) for the purpose of compliance with ElektroG. Stiftung EAR, which is under the sovereign authority of the Federal Environment Agency (Umweltbundesamt), registers e-waste producers. It coordinates the provision and acceptance of containers at öffentlich-rechtliche Entsorgungsträger (örE, public waste disposal authorities) throughout Germany. However, Stiftung EAR is not responsible for operational tasks such as collection, sorting, dismantling, recycling or disposal of e-waste. These are the responsibility of manufacturers, who have been responsible for e-waste recycling and disposal since March 2005 under the original Electrical and Electronic Equipment Act. Overview of Stiftung EAR Clearinghouse Activities Stiftung EAR is independent in terms of financing and personnel. Its operations are financed through fees and expenses determined by the cost regulation established by the Federal Ministry for the Environment, Nature Conservation and Nuclear Safety (Bundesumweltministerium). The Stiftung EAR clearinghouse performs the following functions for all e-waste producers, including PV panel manufacturers: • Registers producers placing e-waste on the market in Germany; • Collects data on amounts of e-waste placed on the market; • Coordinates the provision of containers and the take-back of e-waste at public waste disposal authorities (örE); • Reports annual material flows to the Federal Environment Agency; • Ensures participation of all registered producers in the establishment of internal rules; • Identifies volunteer contractors and reports them to the Federal Environment Agency.

Implementation of the WEEE Directive

Pursuant to the new WEEE Directive transposed in 2015, Germany has adopted special provisions for PV panel collection, recovery and recycling (Table 1). These determine the amount of financial security that any manufacturer must provide for each new panel sold. The guarantee calculation depends on the financing method chosen by the manufacturer. If the manufacturer selects the joint and several liability scheme for B2C panels sold, the following simplified formula provides understanding of the principle. Cost responsibility = basic amount for registration (tons of PV panels placed on the market) x assumed return rate (%) x assumed disposal costs (EUR/t). For B2B PV panels, the German regulator allows contractual arrangements between manufacturer and asset owner, for example through recycling service agreements, to meet legal requirements. Germany has also created a separate collection category for PV panels and thus ensures separate collection and processing of waste panels at municipal collection points. This means that any PV panel owner wishing to dispose of it can take it to a municipal collection point where it will be accepted free of charge. This is an open disposal route available to private customers with residential PV systems. However, because removal of a PV panel requires professional skills, most end-of-life PV panels are expected to be returned through B2B networks. This is because installers removing roof panels will likely also undertake the disposal process. These PV panels will be returned either directly to B2B e-waste compliance schemes or to collection and recycling systems owned by manufacturers. Before the implementation of Germany's revised ElektroG, there were a number of non-regulatory initiatives organizing the collection and recycling of end-of-life PV panels. These were based primarily on voluntary manufacturer initiatives (such as PV CYCLE). These schemes will either be facilitated or be forced to adapt to the new regulation and register themselves as B2B e-waste compliance schemes.  

National Financing Plans under the WEEE Directive

The most important aspect of the WEEE Directive is the financing of collection, recovery and recycling in the coming years, given the enormous historical installed capacity destined to become waste in Germany. Depending on the type of operation, the German government foresees two different mechanisms based on the WEEE Directive. These are summarized below.

Business-to-Consumer (B2C) Transactions

The new ElektroG requires manufacturers selling e-waste to private dwellings (or those outside private households but with similar demand, i.e., dual-use e-waste) to fulfill their current and future end-of-life obligations. This ensures that manufacturers engage in end-of-life management of PV panels sold to private homes (such as residential roof systems) as they place products on the market. The approach follows accredited producer compliance schemes in a joint and several liability format, as shown in Figure 2, resulting from previous experience (Table 1). The collective producer compliance system creates operations and financing at two levels (Figure 2): • Level 1 covers the costs associated with operating the collection system and immediate collection and recycling of products (including historical products placed on the market before being covered by law). • Level 2 ensures that sufficient financing is available for future collection and recycling of products placed on the market today, that is, after being covered by law. The costs underlying Level 2 financing are the same for the PV equipment category. The average service life, return quota at municipal collection points, treatment and logistics costs are calculated by the regulator. Level 1 costs are covered using a PAYG system for all market participants placing products in a given category (such as PV panels) through B2C transactions. Additionally, before being permitted to enter the market, manufacturers must register with a clearinghouse. They must declare that they have made arrangements to cover Level 2 costs for B2C products placed on the market. At the same time, they must accept responsibility for Level 1 costs based on existing market shares (in other words, accepting responsibility for that of other market participants). The clearinghouse then provides a manufacturer e-waste registration number to be printed on the product and invoices. The manufacturer now decides how to fulfill its Level 1 contribution. For example, it can operate an individual collection and recycling system or participate in a shared system. In either case, the costs associated with collection and recycling of all B2C waste in a given product category are distributed among all registered market participants according to the volume collected. This ensures collection and processing of historical waste or orphaned waste in the case of products manufactured by manufacturers no longer in business. If a manufacturer demonstrates that it has individually collected and recycled its share, these amounts will be deducted from the remainder. If a manufacturer disappears from the market, its market share will be taken over by others along with collection and recycling financing responsibility. Each manufacturer must also ensure that sufficient Level 2 financing is available for B2C products placed on the market today. This naturally occurs if the shared Level 1 system continues to operate. However, if all manufacturers in a given product category disappear, final stage insurance must provide financing. All Level 1 participants pay an annual premium for insurance guaranteeing coverage of costs in the event that all market players disappear. This premium is typically minimal because the likelihood of all market players disappearing is very low.

Business-to-Business (B2B) Transactions

Germany's new ElektroG provides a different way to finance end-of-life PV obligations for manufacturers selling products on a B2B basis solely because of quantity, size, complexity level, etc. Recycling can be organized more efficiently if the end user or installation owner provides this. It is up to contract partners to reach an agreement on end-of-life responsibilities as specified by the WEEE Directive by contracting the manufacturer for collection and recycling or by seeking competitive market offerings. The B2B approach also includes flexibility in reaching agreement on a financing/funding mechanism. For large-scale PV installations, this will likely result in models generating funds for collection and recycling from project cash flows approaching the end of their commercial life. As a result, cost-effective financing will be provided ensuring that pre-agreed (pre-WEEE) end-of-life obligations are fulfilled by contract partners. Thus historical waste volumes will be covered.  

Summary View for Germany

Germany will likely be the first end-of-life PV panel recycling market to achieve profitable economies of scale. Disposal costs set by the regulator reflect the average treatment costs summarized above in Table 1. However, with increasing volumes of waste, these costs should decline after the industry passes through a learning curve. This trend has already been observed in other segments of the e-waste stream. A number of R&D initiatives are currently directing improvements in recycling technologies for different PV technology families. These aim to further reduce recycling costs and increase potential revenue streams from secondary raw materials recovered through the recycling process. In our next article we will continue with the United Kingdom's WEEE targets and financing plans, wishing you healthy days...   Dr. Cemil Koyunoğlu Energy Systems Engineering Faculty of Engineering Yalova University