Japan’s Ministry of the Environment and Ministry of Economy, Trade and Industry (METI) have proposed that owners of commercial solar installations planning to dispose of 50 metric tons (MT) or more of panels be required to file an advance disposal plan. The ministries presented the proposal to a study group drafting the implementing rules for a new recycling law.
The Act on Promoting the Recycling of Solar Cell Waste was enacted on May 29 and promulgated on June 5. It must take effect within 18 months, and the government’s working schedule targets around early December 2027.
The law itself leaves key thresholds to cabinet orders and ministerial ordinances. The study group took up panel types, weights and the large-volume threshold at its first meeting on Oct. 30. It will turn to certification and processing standards in mid-November and judgment criteria in early December.
A joint council will then review the proposals from December to March before public consultation. The ministries plan to publish the rules around spring 2027, when recyclers can also begin pre-applying for certification, ahead of the law taking effect.
Under existing law, panels must be handled as waste, but recycling is not mandatory, and the government says landfill has often been chosen. The new law sets three tiers of obligations. Everyone who disposes of panels has a general duty to promote recycling. Commercial disposers, including rooftop owners who sell their power, would receive guidance and advice under government criteria. Commercial disposers above the threshold would have to file disposal plans in advance and could face government recommendations and orders. As a result, the threshold would determine which operators face the law’s most stringent requirements.
The ministries compared thresholds of 40 MT, 50 MT and 60 MT. All three would capture a similar share of panel waste expected from 2027 to 2050: 38.7% at 40 MT, 38.3% at 50 MT and 37.9% at 60 MT. The difference is in which plants are covered. At 40 MT, 8,368 facilities would be covered, including 1,263 of 600 kW or less. At 50 MT, the figure falls to 7,398, with none of that size. At 60 MT, it is 6,784.
The ministries said 40 MT or 50 MT would capture the majority of plants of 1 MW or more. Of 6,267 module models installed in Japan, 99.3% correspond to 40 MT or more per megawatt of capacity, 94.9% to 50 MT or more and 72.2% to 60 MT or more. The ministries said 50 MT would avoid excessive regulation of smaller plants while focusing requirements on operators they consider able to recycle cost-effectively.
Industry news outlet IRU-MIRU reported that most study group members backed 50 MT, while some argued for 40 MT to widen coverage.
To prevent operators from staying under the threshold by breaking one project into several smaller disposals, the ministries proposed counting panels removed from the same plant during a single decommissioning or repowering within a set period, about one year as a guide, as one disposal. Replacements after disasters or equipment failures, and routine maintenance swaps, would not count as split disposal if documented.
The law would apply only to panels weighing at least 3.7 kg each. The cutoff is meant to exclude small products such as calculator cells while covering almost all conventional modules. The lightest module model installed since 2011 weighs 4.7 kg, and, with one small exception, the lightest earlier model weighs 3.7 kg.
Silicon modules, which the ministries said account for about 95% of global production, would be covered, along with copper indium gallium selenide (CIGS) and cadmium telluride (CdTe) thin-film panels. Single-glass, double-glass and building-integrated photovoltaic (BIPV) panels would all be included, as the ministries said processing routes exist for these designs.
Double-glass modules made up 39.3% of Japanese shipments in 2025, based on data from 17 members of the Japan Photovoltaic Energy Association (JPEA). In a survey of 81 waste processors, 46 (56.8%) said they could accept double-glass panels and 21 (25.9%) said they could accept BIPV panels. A recent study found that targeted recycling of glass-glass modules lowers energy use and climate impact but reduces the value of recovered materials.
Organic cells, including both glass and film perovskite, would be excluded, along with gallium arsenide and other specialty compound cells and glass-fiber flexible panels. The ministries said recycling technologies and processing routes for these do not yet exist, and that the scope would be reviewed as technology and markets develop.
Since July 2022, solar projects of 10 kW or more under Japan’s feed-in tariff and feed-in premium schemes have had to set aside funds for decommissioning costs. The new law adds recycling and disposal-plan requirements on top of that.
The government projects end-of-life panel waste will peak at up to about 500,000 MT a year in the 2040s, well above an earlier estimate of 170,000 MT to 280,000 MT a year around 2035 to 2037.
The perovskite exclusion comes as Japan pushes the technology. The government aims to deploy 20 GW of perovskite solar by 2040, and in September it said it would exclude silicon modules from new subsidies to prioritize perovskite. In October, Panasonic began selling glass-based perovskite panels, a product type that falls outside the proposed scope.
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