Universal Waste Regulations: Aligns Perfectly with Comstock Metals' Zero-Landfill Solar Recycling Solution
Proactively planning recycling strategies during procurement and installation phases demonstrates environmental leadership and operational foresight. It’s critical to recycle with a partner with robust storage and growing capacity, establish rigorous compliance auditing program that can certify where panels are going downstream of your project, and partner exclusively with recyclers who guarantee the elimination of heavy metal contamination and who are certified by a third party such as SERI and their R2v3 Appendices A, E, and G protocol.
California has adopted Title 22 of the California Code of Regulations, specifically Division 4.5, Chapter 23, which defines universal waste and its management. Title 22 in requires securely packaging solar panels, clear labeling, rigorous employee training, and partnering with certified recyclers—ensuring streamlined operations and minimized environmental risks. Detailed reporting further boosts transparency and regulatory confidence.
California’s shift to classifying solar panels as universal waste has simplified operational logistics for generators and recylers alike, reducing administrative burdens significantly. Additionally, the upcoming EPA regulatory shift to Universal Waste in 2026 (expected adoption) should enhance interstate logistics, improving cost efficiency and continuity of handling of panels for the entire industry.
Universal Waste Best Practices
Best practices for managing solar panels as universal waste include early planning for end-of-life (EOL) handling during permitting, procurement, and installation.
Facilities can work with their full-service partner like Comstock Metals to support comprehensive training for personnel, to set up programs for ensuring clear labeling of universal waste streams, maintaining secure and weather-resistant storage areas at the project site, and regularly auditing waste management protocols.
Optimal practices involve partnering with certified (R2v3 Appendices A, E, and G) recyclers like Comstock Metals capable of assuring a zero-landfill and no liability solution that removes heavy metal contamination and fully responsible recycling of your photovoltaic (PV) panels so 100% of all useful recovered materials are safe and clean for reuse.
Tip: Always be sure your recycler provider has the most transparent and complete certification in place that includes an auditable record of downstream vendors and offtake buyers, so you know the safe, clean materials from your solar panels have a clear chain-of-custody documentation trail to meet evolving regulatory demands and eliminate risk of liability. Transparency builds trust.
Comstock Metals was recently featured in pv Magazine USA. We talked about our unique delamination processing solution as we gear up to expand to a 100,000 ton per year zero-landfill capacity that can responsibly recycle more than 3.3 million solar panels and meet or exceed California's standards. Read more.
Regulation History and Implications in Califoria
Historically, photovoltaic panels were initially managed as general solid waste until concerns emerged regarding their hazardous material content—particularly lead, cadmium, and selenium.
This realization prompted reclassification as hazardous waste under the Resource Conservation and Recovery Act (RCRA). However, managing solar panels as hazardous waste under RCRA created economic and operational challenges due to stringent storage, transportation, and disposal protocols.
In response, California pioneered regulatory flexibility by classifying solar panels as Universal Waste. This classification significantly streamlined handling processes, reducing barriers to recycling, and promoting broader industry compliance through simplified logistics and reduced costs. The shift from hazardous to Universal Waste has been pivotal in boosting the sustainable recycling of PV panels across California.
As the first full-service solar panel recycler in the U.S. to be R2v3 Appendices A, E, and G /RIOS Certified, Comstock Metals meets or exceeds industry’s safety and environmental protocols while establishing a whole new solar panel recycling standard. Our unique delamination process that eliminates heavy metal contamination is cleaner, auditable, and compliant.
Incoming Regulatory Shifts (EPA) and Importance
The U.S. Environmental Protection Agency (EPA) is currently considering formal federal designation of end-of-life solar panels as universal waste. If enacted, this regulation will harmonize state-level practices nationally, making California a key state in pioneering regulatory frameworks.
Such a designation nationally would facilitate streamlined interstate transportation, increase recycling capacity, reduce administrative complexity, and potentially reduce costs for manufacturers, recyclers, and solar energy producers. The move emphasizes environmental stewardship and promotes a circular economy approach, crucial for sustainable growth of a clean and reliable energy system. As of June 2024, you can read more here: rulemaking and here about universal waste regulations. A final rule is expected in 2026.
More on Current California Bills (2025 Session)
Several bills in the 2025 California legislative session are poised to influence solar panel recycling practices and material management significantly:
- AB 1420 (Solar Panel Recycling Act): This bill mandates manufacturers to establish and finance statewide recycling programs for end-of-life solar panels. Key implications include increasing producer responsibility, incentivizing material recovery, and reducing the burden on local waste management facilities.
- SB 590 (Photovoltaic Recycling Enhancement Bill): This bill proposes enhanced financial incentives and subsidies to recycling facilities utilizing advanced recycling technologies, such as thermal recycling methods, to achieve higher recovery rates of critical materials. It underscores California's strategic direction toward innovative and high-efficiency recycling solutions.
- AB 1627 (Material Transparency and Traceability Act): Aiming for greater transparency in solar panel production, this bill would require manufacturers to disclose materials and chemical content explicitly. It will significantly aid recyclers by providing detailed material data, enhancing recycling accuracy, and improving material safety management.
Stay tuned for updates if these bills become law. No matter the results, Comstock Metals is well-positioned to support the largest utility-scale project owners and operators as the most compliant, transparent, and zero-landfill solution.
