ExECUTIVE SUMMARY:This study aims to analyse the current state of play of the PV waste management landscape in India and to provide recommendations on how to enhance the policy framework around it. A comparison of the EU and Indian regulatory settings and main policy drivers is carried out, as well as an analysis of the PV module waste market in India, including the amount of waste generated and current waste treatment practices. Based on these assessments, a number of short-, mid- and long-term policy recommendations are included.

Based on the results and recommendations of this report, the development of a draft piece of legislation for PV end-of-life management should be carried out. The new legislative framework could include in the scope modules, 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.

Compared to a BAU scenario or to an improved BAU (BAU+) scenario whereby a landfill ban is introduced, this study recommends the Extended Producer Responsibility 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. They are product take-back, deposit/refund, advance disposal fees, product/material taxes, combined upstream tax and subsidy and minimum recycled content requirements. Policymakers should review these different instruments to identify which might best meet their particular needs. The point of intervention for the instrument selected depends on the point where the market fails to internalize the impacts from the disposal of products at their post-consumer stage. The instrument or mix of instruments that would best meet policy goals should be selected.

Looking at the medium- and long-term time horizon (5-10 years), the following actions should be explored:

1. Develop sustainable product policies for PV modules, inverters and systems, such as Ecodesign and Ecolabel, based on globally recognised standards and a methodology that take into account the full product lifecycle;
2. Consider including sustainability criteria in national renewable energy auctions, based on a point-based system, to reward products with the lowest environmental impact;
3. Periodically re-assess rules on PV waste recycling to keep pace with the evolution of the sector;
4. Set up joint EU-India Horizon 2020 calls for R&D projects on PV recycling technology or innovative equipment.The Waste Electrical and Electronic Equipment (WEEE) Directive

The Waste Electrical and Electronic Equipment (WEEE) Directive

The WEEE Directive 2012/19/EU entered into force in each Member State on 14 February 2014. This recast Directive is the successor of the original WEEE Directive 2002/96/EC, which entered into force on 13 August 2005 in each Member State. The WEEE Directive imposes the responsibility for the disposal of Waste Electrical and Electronic Equipment (WEEE) on the manufacturers or distributors of such equipment or more precisely on the companies, which are putting for the first time such equipment on the territory of a Member State of the European Union (referred to as “producers” in the WEEE Directive’s terminology).The WEEE Directive is an example of the Extended Producer Responsibility (EPR) principle, which is “an environmental policy approach in which a producer’s responsibility for a product is extended to the post-consumer stage of a product’s life cycle”.2 In practice, EPR implies that the first put-on-the-market companies (producers, importers) take over the responsibility for collecting or taking back used goods and for sorting and treating their post-consumer waste. This requires that those companies establish an infrastructure for collecting WEEE, in such a way that “Users of electrical and electronic equipment from private households should have the possibility of returning WEEE at least free of charge”. The directive saw the formation of national “producer compliance schemes”, into which manufacturers and distributors paid an annual fee for the collection and recycling of associated waste electronics from household waste recycling centres.

The Regulation on Registration, Evaluation, Authorisation and Restric- tion of Chemicals (REACH)

The Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals (EC 1907/2006) is the EU Regulation overseeing the use of chemicals, addressing the production and use of chemical substances and their impacts on human health and the environment.This legislation mandates that all companies manufacturing or importing relevant quantities4 of chemical substances in the EU, register such substances with the European Chemical Agency. In the registration, they must identify the risks connected to the substances they produce and import, and illustrate how these risks are managed.The Regulation also addresses the use of a number of substances of very high concern (SVHC). These substances, identified in a Candidate List, cannot be used unless the company is given an authorisation.

Sustainable product policies

The European Commission is currently considering the implementation of a number of sustainable product policies for PV modules, inverters and systems. These measures include both mandatory instruments (Ecodesign, Energy Label) and voluntary instruments (EU Ecolabel, Green Public Procurement), which are undergoing a process assessing their impact on market and product sustainability. Some of the criteria provisionally laid out in the draft measures include performance requirements and information disclosure on material content, dismantlability, repairability, recyclability and presence of hazardous substances. The expected timeframe for entry into force of the first set of these provisions is 2023-2024.

Landfill Directive

The Landfill Directive 1999/31/EC has the objective to prevent and reduce as much as possible the negative effects on the environment, in particular on surface water, groundwater, soil, air, and on human health from the landfilling of waste by introducing stringent technical requirements for waste and landfills.The Landfill Directive defines the different categories of waste (municipal waste, hazardous waste, non-hazardous waste and inert waste) and applies to all landfills, defined as waste disposal sites for the deposit of waste onto or into land. Landfills are divided into three classes: landfills for hazardous waste; landfills for non-hazardous waste; landfills for inert waste.Most of the EU Member States have introduced a landfill ban for untreated waste (including PV modules), separately collected waste such as the products covered by EPR-regulations (such as PV modules).

In March 2018, the E-Waste Rules were amended by the Ministry of Environment, Forest and Climate Change to facilitate and streamline the implementation of an environmentally sound management of e-waste in India. The objective of these amendments is to formalize the e-waste recycling sector by channelizing e-waste generated in the country towards authorized dismantlers and recyclers. To undertake the activities prescribed for PROs under these new Rules, the PROs were to apply for Central Pollution Control Board (CPCB) registration. This amendment is considered as a progressive one in India’s journey of handling e-waste as the requirement of PROs to register with CPCB would ensure continuous monitoring by CPCB thereby ensuring accountability from PROs.As per these revised targets, 10% of the quantity of waste generated shall be collected during 2017-2018 and there shall be a 10% increase every year until the year 2023. After 2023, the E-Waste collection target is fixed at 70% of the quantity of waste generation.The responsibilities of the various entities, producers; consumers (including bulk consumers); collection centres; dismantlers and recyclers, are defined, together with the procedures for obtaining registration and authorisation from the pollution control entities including sample forms. For producers, collection centres, dismantlers and recyclers, an application for a Grant of Authorisation must be made within three months of the start of the Rules, (i.e.) by 31st July 2012, with the authorisation having a five year validity being made up to 90 days later.

Even though the components of a solar PV system – PV modules and inverters – are currently not included in the E-Waste Rules, this piece of legislation could be considered as a reference legislation by both the Indian authorities as well as the Indian solar industry. For example, MNRE’s Guidelines for setting up grid-connected solar power plants state that “the developers will ensure that all solar PV modules collected from their plant after their end-of-life are disposed-off in accordance with the “E-waste (Management and Handling) Rules”. However, today, there are neither any regulations nor any standards for PV waste management in India.The E-Waste Rules also cover the restriction of hazardous substances (RoHS) in electronic and electrical components and equipment. It is applied on producers and distributors involved in the manufacture, sale, and processing of electronic and electrical equipment or components. Under the RoHS provisions, cost for sampling and testing shall be borne by the government for conducting the RoHS test. If the product does not comply with RoHS provisions, then the cost of the test will be borne by the Producer.

Commercial installations shared the majority of the PV rooftop systems (the detailed breakdown in not available in the literature). 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. A B2B network for end-of-life management of PV waste would be the preferred choice to address this.

Compared to current levels, the annual PV market is expected to grow significantly across all scenarios. The Low and Medium scenarios forecast a somewhat stable level of annual installations in the next 5 years, between 9 and 18 GW installed annually. In the mid and long term, annual installations increase significantly, reaching 22-46 GW by 2030. Conversely, the High scenario assumes that national government objectives are reached – this causes a surge of installed capacity in 2021 and 2022. After peaking in 2024, annual installations decline and are at 17 GW in 2030. This results in annual installations in the High scenario to become eventually lower than in the other two scenarios, although the cumulative capacity remains significantly higher.

Response to stakeholder survey – question 4: Would setting up a standard, i.e., a target of a minimum amount of recycled content to be included while manufacturing of new modules, improve PV waste management in India? (Blue: yes; red: no) Do you think the idea of setting up a standard , i.e., a target of a minimum amount of recycled content to be included while manufacturing of new panels, would help in achieving the goal?

Overall, from the survey it can be concluded that stakeholders in India are concerned about the PV waste and it’s management in the country in coming years and are willing to consider a fee to create a fund which is managed by an industry body to facilitate this process and manage India’s PV waste. This report encompasses the measures and strategies that have been proposed or suggested by majority of stakeholders in terms of Landfill ban, EPR enforcement and centralized fund.

Click to download:The Indian Solar Saga