For Europe’s PV industry, non-compliance with WEEE has serious consequences

WRITTEN BY PIA ALINA LANGE. “I am not a producer because I do not manufacture.” “I am not a producer because my foreign supplier is member of a take-back scheme.” “I am not a producer because this brand is already listed with a take-back scheme.”

Does any of this sound familiar?

Since early 2014, the WEEE Directive that regulates waste from electrical and electronic equipment — including photovoltaic panels — has changed the framework in which PV module waste is managed. Waste management is no longer brand-related, cross-national nor voluntary. With WEEE, waste management has become a mandatory, legally binding prerequisite for selling PV modules in every single country of the European Union.

While the PV sector may act internationally, the waste authorities and WEEE inspection certainly don’t Previously, a big producer’s single membership with a take-back scheme covered the collection and recycling of the PV module waste that occurred across Europe – independent from the country or value chain actors involved. This voluntary, pan-European approach set the benchmark for environmental responsibility in the PV industry. Several thousand waste tonnes made it to our take-back and recycling network. Not less than 90% of the European PV volume was managed by PV CYCLE.

Today the situation is different. The waste claims of a foreign supplier, a take-back logo on a module or the membership of a daughter company in another EU country are not decisive for WEEE-compliance with national law. Every single party is solely responsible for the PV modules it brings on the market, and everybody in the PV value chain can be affected by WEEE-compliance. Take-back and compliance schemes, such as PV CYCLE, facilitate the operative, administrative and financial processes, and can relieve producers from significant extra burdens.

Not the brand but the module needs to be compliant
Brands no longer play a role in a WEEE-regulated environment, nor does the activity field of a PV company. Anybody who is established in an EU-country and manufactures, sells or imports PV modules is considered to be a “producer” in this market; WEEE-compliance has consequently become a mandatory obligation.

For a company to be compliant, the following obligations need to be fulfilled: 
 

• Registration with the national WEEE register in each country a company is based with own entities
• Country-related, periodic declaration(s) of the PV modules sold in a year
• Organization and financing of take-back and treatment of their PV module waste
• Marking of their PV modules with a crossed-out wheelie bin 

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