R2v3 solar panel recycling is recycling verified against Appendix G, the section of the R2v3/RIOS standard written specifically for PV modules, rather than a general electronics certification stretched to cover solar. Comstock Metals became the first solar panel recycler in North America certified to R2v3/RIOS under Appendix G in May 2025, covering its Silver Springs, NV facility.
R2v3 is the ANSI-accredited responsible-recycling standard for electronics, managed by SERI (Sustainable Electronics Recycling International). In January 2024, R2v3 added Appendix G, a section written specifically for photovoltaic (PV) modules, after a multi-year, multi-stakeholder drafting process. A recycler certified under Appendix G has been independently audited specifically on how it processes solar panels, not just electronics in general, which makes accreditation to R2v3 Appendix G for solar panel recycling a significant claim, as opposed to standard e-waste recycling qualifications.
R2v3 solar panel recycling is recycling verified against Appendix G, the section of the R2v3/RIOS standard written specifically for PV modules, rather than a general electronics certification stretched to cover solar. A certification reflects one scheduled audit, not everyday operations, and a facility can prepare for a visit it knows is coming. That's why it is worth seeing a recycler's partner site in person, ideally on short notice. Comstock Metals welcomes short-notice site visits, so a compliance team can see the process firsthand. For a compliance team, that certification is the difference between a vendor's word and an independently audited record. Comstock Metals became the first solar panel recycler in North America to be certified to R2v3/RIOS under Appendix G in May 2025, covering its facility in Silver Springs, NV, which uses proprietary technology specifically built for PV module processing.
Compliance teams are being asked to certify how panels are disposed of, yet there is no settled answer regarding which waste category they fall into. Whether a retired panel counts as hazardous waste under the Resource Conservation and Recovery Act (RCRA) depends on the Toxicity Characteristics Leaching Procedure (TCLP) test. The TCLP test evaluates panels under mimicked landfill conditions for leachable metals such as lead and cadmium. If those levels exceed EPA limits, the panel is then classified as hazardous.[4] Because panel composition varies, some modules pass this test and some fail. So, without detailed knowledge of a given panel's makeup, the company responsible for it has to run the TCLP test itself to make that determination.
The stakes of getting this wrong are real. Under the RCRA, the generator bears cradle-to-grave liability that cannot be transferred to a hauler or recycler, meaning misclassified panels can expose a company long after they leave its site.
Layered on top of that regulatory gap is a vendor problem. Collecting panels isn't the same as recycling them, and most recyclers can't document what actually happened to the material after pickup. Mechanical disassemblers strip the aluminum frame and shred the rest without delamination, leaving plastic and heavy metals in the output. E-waste collectors often run an arbitrage model, reselling usable panels at a premium and landfilling the rest. Neither approach produces the documented, auditable trail a compliance team needs, and neither guarantees the panels avoided the landfill at all, the opposite of solar panel recycling standards that a compliance team can rely on.
Comstock Metals is the first solar panel recycling company in North America certified to R2v3/RIOS under Appendix G, the section specifically written about PV modules.[3] That certification covers Comstock Metals' primary recycling facility, owned and operated in the United States. For a compliance team, this means that the chain of custody is documented and verifiable at every step: receiving, storage, processing, and downstream reuse of the recovered material.
The underlying process is what makes the certification possible in the first place. Comstock Metals' proprietary system fully delaminates every panel type, including thin-film, separating glass, aluminum, silicon, copper, and silver into clean, commodity-ready feedstock as part of its zero-waste solar panel recycling process. Nothing goes to landfill, and nothing is improperly resold. That is a materially different outcome from a shred-and-sort process, and it's why the recovered material can re-enter domestic manufacturing rather than sit as a liability on a compliance team's minds.
Comstock Metals also accepts panels regardless of how they are classified under RCRA, whether manifested as universal waste, solid waste, or hazardous waste, regardless of their condition. That flexibility matters precisely because the federal waste classification for panels is still being finalized. A compliance team working with Comstock Metals does not have to resolve the TCLP question before moving panels off a site; Comstock Metals runs a certified, audited process that already accounts for it.
R2v3 solar panel recycling under Appendix G is what separates a certified, auditable recycling process from a vendor's word. Comstock Metals holds the R2v3 Appendix G solar panel recycling certification, runs a zero-waste process, and welcomes short-notice site visits so a compliance team can verify compliance directly. If an organization needs a certified, zero-waste partner for end-of-life solar panels, contact Comstock Metals to discuss solar panel recycling needs.
Appendix G verifies that a recycler's photovoltaic module processing has been independently audited, including how it handles the glass, silicon, and heavy metals unique to solar panels. It does not just rely on general electronics evaluations that never specifically address solar.
RIOS (Recycling Industry Operating Standard) is typically certified alongside R2v3 and covers quality, environmental, and safety management systems at a recycling facility. Comstock Metals holds both R2v3 and RIOS certifications under Appendix G, covering how panels are processed and how the facility is managed.
Comstock Metals fully delaminates every panel type, including thin-film, into glass, aluminum, silicon, copper, and silver, with nothing sent to landfill and nothing improperly resold. Every downstream vendor handling that recovered material is audited as part of the same R2v3/RIOS certification.
Partner with a certified, zero-waste solar panel recycler. Comstock Metals holds R2v3 and RIOS certification under Appendix G and welcomes short-notice site visits.
[1] SERI, "Adding Solar Panels to R2v3 Demonstrates the Adaptability of the Standard's Design," accessed August 27, 2026, https://sustainableelectronics.org/photovoltaic-modules-case-study/.
[2] SERI, "Qualifying Downstream Vendors - General Questions," R2 Knowledge Base, accessed August 27, 2026, https://sustainableelectronics.org/knowledge-base/5061/.
[3] Comstock Metals, "Comstock Metals Awarded the First R2v3/RIOS Certifications for Zero-Waste Solar Panel Recycling in North America," accessed August 27, 2026, https://comstockmetals.com/newsroom/comstock-metals-awarded-the-first-r2v3/rios-certifications-for-zero-waste-solar-panel-recycling-in-north-america.
[4] U.S. Environmental Protection Agency, "End-of-Life Solar Panels: Regulations and Management," accessed August 27, 2026, https://www.epa.gov/hw/end-life-solar-panels-regulations-and-management.
[5] U.S. Environmental Protection Agency, "Resource Conservation and Recovery Act (RCRA) Overview," accessed August 27, 2026, https://www.epa.gov/rcra/resource-conservation-and-recovery-act-rcra-overview.