What about recycling

Explore our advanced solutions for recycling photovoltaic panels, ensuring compliance and sustainability in waste management

Introduction

Waste treatment is typically a high-volume low-return process. A fixed or lowered base price, either for the incoming waste or for the recycled product, has placed the commercial emphasis on maximising throughput and reducing cost overheads.

The cost of waste treatment is typically established on the basis of investments and running costs.

For PV Panels – similar as for e.g. lighting bulbs – the waste management industry has a huge challenge to define when ramping up for photovoltaic (PV) Panels treatment.

Due to the long lifetime of PV Panels (10 years product guarantee and 20 years performance guarantee; in some countries and regions strengthened by long feed-in-tariff mechanisms) and the unpredictable deployment of photovoltaic energy throughout all countries or regions across the globe, a waste management company shall not invest in building a waste treatment line for PV Panels when there is no guaranteed supply of tonnage each day.

A normal industrial-scaled waste treatment line processes daily 500 tonnes of waste or annually 100.000 tonnes of waste. A normal situation means that a waste treatment line or facility is operated without the support of financial incentives or local, regional or national public funding. The latter might avoid that the gate fee of the waste treatment plant does not reflect the real treatment costs of the treated waste.

At the start of PV CYCLE in 2007, there was barely treatment and recycling solutions existing for any commercially available PV technology. The ‘on-the-shelf’ treatment solution was then the limited amount of flat glass recyclers. From a material perspective, a PV Panel is mainly a laminated flat glass product, similar to a windshield or car window or a building glass product.

A PV Panel contains at minimum 75% to even for some technologies 95% flat glass.

We describe in the following paragraphs the several options which exist to manage the end-of-life phase of PV Panels.

Important for us, there is no best-in-class waste treatment solution or technology for PV Panels.

There is no legal reference to social media jargon such as high value recycling, downcycling or closed loop recycling.

The only legal and the only daily practice of any permitted waste treatment and recycling facility is to focus on the materials inside a PV Panel, on the characteristics of these materials, on the amount of these materials. Any waste treatment or recycling facility shall do its utmost best to recover as much as possible the valuable materials and to minimize as much as possible the costs related to those materials which do not generate value and shall generate a cost in the final treatment operations.

Most important criterion is the quality of the recovered mono-materials. This means that the contamination has to be as less or as-zero as possible. Only in the ‘zero’-case, the recycler shall benefit from the best prices for recovered materials at the final destination of e.g. glass cullets, ferro or non-ferrous metals.

All these parameters, define the costs of treatment and the profitability of recovered materials of a product – PV Panel or any other kind of product – once it becomes ‘waste’!

Therefore, PV CYCLE acknowledges that all kind of waste treatment technologies are welcomed and needed to treat the upcoming mass of PV Panels. As long as all these treatment technologies comply with their permit and permit conditions, which find their origin in the Industrial Emissions Directive; the latest version of IED has entered into force on August 4, 2024.

Under the IED, environmental permits are granted to the concerned waste treatment installations by national permitting authorities. Best available techniques (BAT) play hereby a key role. These techniques are the most environmentally effective and economically and technically viable for the prevention and control of emissions.

BATs are generally identified sector-by-sector through the collaborative, transparent and fact-based Sevilla Process, managed by the European Commission’s Joint Research Centre (JRC). This identification process results in BAT Reference Documents (BREFs), which help form BAT Conclusions (BATCs). BATCs are implementing decisions adopted by the Commission that are the basis for drafting permit conditions by Member States’ permitting authorities.One the BREFs is the BREF Waste Treatment. Permits must also contain binding quantitative resource efficiency requirements for materials, water and energy, as appropriate, to better address water scarcity challenges and waste generation.

To ensure compliance, harmonised environmental inspections take place on site at least every one to three years by competent authorities, depending on the risks of the concerned activities.

Waste Hierarchy explained

PV CYCLE supports the Waste Hierarchy:

Prevention of waste
Preparing for reuse and Reuse
Recycling
Other Recovery, e.g. energy recovery
Disposal, e.g. landfilling

PV CYCLE calls upon all photovoltaic industry stakeholders to promote much more that PV Panels are massively contributing to the first rung of the Ladder of the Waste Hierarchy, i.e. preventing waste and preventing costs for the society.

Especially, with a product guarantee of minimum 10 years and a performance guarantee of often 20 years and – in some countries or regions – supported by a subsidy mechanism of 10 to 15 years, PV Panels barely generate waste during the first 15 years, unless there is an economical driver whereby PV Power installations are repowered or revamped; in the latter case, the economical lifetime becomes approximately 12 to 15 years, which is still quite long compared to many consumable products, such as packaging waste and a reasonable amount of e-waste.

With regard to the preparation for reuse and reuse of Photovoltaic panels, PV CYCLE has already ordered in the year 2020 a Reuse Study PV Panels, which analysed the economical, environmental and societal feasibility of preparing PV Panels for reuse.

Mid 2021, PV CYCLE initiated with representatives from IMEC to present our pledge at the International Electrotechnical Commission (IEC) to have a standard or a norm in place with regard to the ‘reuse of PV Panels’. Shortly after, IEC TC 82 agreed to start with a Technical Report about the reuse of PV Panels. The reference is IEC “TR 63525 ED1 – Reuse of PV modules and circular economy”.

The coordinator of these works is fully financed by PV CYCLE since mid 2021.

We expect the Technical Report ‘TR 63525 ED1’ to be published by the first quarter of the year 2025.

Where everyone is looking forward to the recycling and recovery of PV Panels, lacking the importance of prevention of waste and preparation for reuse, we notice today that many (waste) treatment solutions can be applied on PV Panels.

Similar as there are many types of waste, there are many ways in which wastes can be managed.

In most cases, the waste treatment operations start in Waste Transfer Installation or a Frist Treatment Installation.

Operations carried out in this kind of installation include: reception, bulking, sorting, transferring pending, prior to submission to a recovery or disposal operation.

Sorting is a common process step in waste treatment activities, which is performed, among other reasons, for:

ensuring that the waste input is able to be treated in the subsequent waste treatment process;
improving the waste treatment process recovery and recycling rate;
ensuring the quality (purity) of the output for its further use.

Sorting may be performed manually or automatically.

An automated sorting line in relation to PV Panels consists today of several options:

Mechanical treatment or shreddering; or
Hot-knife machinery, peeling off the PV Panel layer per payer; or
Physico-chemical treatment; or
Pyrolysis; or
Other treatment options which might currently be explored in R&D Projects.

In a second phase, the sorted or extracted or recovered materials are further processed by mono-material treatment technology which shall result in material or product recycling or recovery or other recovery operations, which we explain a bit more during the next paragraphs.

The common idea behind Recycling is that a waste material is processed in order to alter its physico-chemical properties allowing it to be used again for the same or other applications.

Specific waste management activities that are classed as recycling under the Waste Framework Directive (WFD) 2008/98/EC include (but are not limited to) recycling of materials, e.g. plastic granulated and pelletised for extruding or moulding; crushed waste glass graded for blasting.

Recycling includes any physical, chemical or biological treatment leading to a material which is no longer a waste. The definition of Recycling does not require any particular characterisation of the processing or reprocessing activity, as long as it serves the objective of generating a material which is used for the original or for other purposes, and thus of closing the economic material circle.

Did you know ?

The consequence of the definition of recycling in the WFD is that only the reprocessing of waste into products, materials or substances can be accepted as recycling.

Processing of waste which still results in a waste which subsequently undergoes other waste recovery steps would not be considered recycling, but pre-treatment prior to further recovery. Such an operation would be categorised as ‘preparation prior to recovery or disposal’ or ‘pre-processing’ prior to recovery. This would include operations like dismantling, sorting, crushing, compacting, pelletising, drying, shredding, conditioning, repackaging, separating, blending or mixing if the material or substance resulting from such operations is still waste.

These activities do not sit on any particular rung of the waste hierarchy of the WFD and instead can be regarded as ‘precursors’ to specific types of recovery.

Food for thought !

It should be noted that the recycling definition in the WFD is slightly different from the recycling definition used in Directives related to specific waste streams (e.g. Extended Producer Responsibility laws). In cases where the definitions in these Directives depart from those in the WFD, the definitions of the specific directives apply.

For example the definition of ‘treatment’ in the End-of-Life Vehicles Directive 2000/53/EC, or the definition of ‘recycling’ in the Packaging Directive 94/62/EC, is different from that of the WFD, and remain in force, in particular for the calculation of targets.

In the Commission Decision 2019/2193/EU laying down the rules for the calculation, verification and reporting of data related to WEEE, one the rules state that the weight of WEEE reported as recovered shall include preparing for re-use, recycling and other recovery, including energy recovery.

The WEEE Directive also clearly states that the definitions of ‘hazardous waste’, ‘collection’, ‘separate collection’, ‘prevention’, ‘re-use’, ‘treatment’, ‘recovery’, ‘preparing for re-use’, ‘recycling’ and ‘disposal’ laid down in the WFD shall apply.

Material recycling means that e.g. recovered aluminium is used again in new aluminium material. This applies also to all materials which are recovered by smelting or refining by using technologies such as pyrometallurgy, hydrometallurgy, a mix of these or integrated pyrometallurgical processes. Hydrometallurgy is used when high purity products are sought.

Product recycling means that e.g. recovered aluminium frame becomes again an aluminium frame.

Recovery is divided into three sub-categories: preparing for re-use, recycling, and other recovery.

The principal result of a recovery operation is ‘waste serving a useful purpose by replacing other materials which would otherwise have been used to fulfil a particular function, or waste being prepared to fulfil that function, in the plant or in the wider economy‘.

The ‘recovery’ provisions apply not only where a material is actually substituting other materials, but also to processes preparing a waste material in such a way that it no longer involves waste-related risks and is ready to be used as a raw material in other processes.

In certain production processes such as co-processing, waste can be used in an operation combining two waste management recovery options at the same time. The energy content of the waste is recovered (R1 operation) as thermal energy, thus substituting fuels, while the mineral fraction of the waste can be integrated (hence recycled) in the matrix of the product or material produced, e.g. cement clinker, steel or aluminium (R4 or R5 operation).

Annex II to the WFD sets out a non-exhaustive list of recovery operations (R1 to R13). An operation may be a recovery operation, even if it is not listed in this Annex II, if it complies with the general definition of recovery.

Other recovery is any operation meeting the definition for ‘recovery’ under the WFD but failing to comply with the specific requirements for preparation for re-use or for recycling.

Examples of other recovery operations are:

Incineration or co-incineration where the principal use of the waste is as a fuel or other means to generate energy. It is a waste management operation with energy recovery (R1 in WFD).
Backfilling operations meeting the recovery definition and in compliance with the general environmental protection principles of precaution and sustainability, technical feasibility and economic viability, protection of resources as well as the overall environmental, human health, economic and social impacts.

‘Backfilling’ is explicitly accepted by Article 11(2) (b) of the WFD as a recovery operation. However, the WFD itself does not provide a definition for backfilling. Article 2(6) of Commission Decision establishing rules and calculation methods for verifying compliance with the targets set in Article 11 (2) of the WFD states that ‘backfilling’ means a recovery operation where suitable waste is used for reclamation purposes in excavated areas or for engineering purposes in landscaping and where the waste is a substitute for non-waste materials’.

Often forgotten and unknown by the general society not familiar with treating waste, is the legal concept of ‘By-product’ (BYP).

The European Court of Justice, through a number of rulings, has given guidance on when a material can be regarded as something which an undertaking wishes to exploit rather than a substance or object which is being discarded.

The WFD does not change these legal considerations in substance but has codified them in Article 5 WFD to improve legal certainty and has also introduced a mandate for the Commission to determine technical criteria for certain materials based on these legal considerations.

A BYP is a material that is not deliberately produced in a production process but may or may not be a waste.

A BYP is a BYP if the following conditions are met:

further use of the substance or object is certain;
the substance or object can be used directly without any further processing other than normal industrial practice;
the substance or object is produced as an integral part of a production process; and
further use is lawful, i.e. the substance or object fulfils all relevant product, environmental and health protection requirements for the specific use an will not lead tooverall adverse environmental or human health impacts.

A decision on whether or not a particular substance or object is a by-product must in the first instance be made by the producer of the substance or object, together with the competent national authorities, based on the applicable national legislation transposing the WFD.

These tests are cumulative, meaning that all four conditions must be met.

‘Further use is certain’ means that it is not a mere possibility but a certainty; in other words, it is guaranteed that the material will be used. If further use were not certain, there would be a risk of the material being disposed of as waste.

However, ‘certainty of further use’ may be indicated through, for example: existence of contracts between the material producer and subsequent user or a financial gain for the material producer or a solid market (sound supply and demand) existing for this further use.

‘Used directly without any further processing other than normal industrial practice’, the crucial point is to determine what ‘normal industrial practice’ is.

Normal industrial practice can include all steps which a producer would take for a product, such as the material being filtered, washed, or dried; or adding materials necessary for further use; or carrying out quality control.

In this context, an example of a BYP is blast furnace slag which is produced in parallel with hot iron in a blast furnace. The production process of the iron is adapted to ensure that the slag has the requisite technical qualities. A technical choice is made at the start of the production process that determines the type of slag that is produced. Moreover, use of the slag is certain in a number of clearly defined end uses, and evidence of a demand can be provided. Blast furnace slag can be used directly at the end of the production process, without further processing that is not an integral part of this production process. This material can therefore be considered a by-product and fall outside the definition of waste.

In contrast, de-sulphurisation slag is produced due to the need to remove sulphur prior to the processing of iron into steel. The resulting slag is rich in sulphur, cannot be used or recycled in the metallurgical circuit and is, hence, waste.

‘Produced as an integral part of a production process’ requires that the substance or object ‘is produced’ as an integral part of a production process. It can be taken from this that the process where the by-product is generated has to be an integral part of a production process.

However, also further treatment operations which are normal industrial practice do not exclude the classification of a production residue as a by-product, irrespective of where such industrial treatment is carried out — on the site of the generator of the material, on the site of the industrial facility using the material, or on an intermediate site.

When ‘Further use is lawful‘, can be relatively easily assessed. It may for example be indicated through:

A material meeting the technical specifications relevant to its further use, or an object meeting product specifications relevant to its further use;
If there are no relevant technical specifications for the material, it can still be lawful to use it simply if its use is not specifically forbidden.

Finally, whether a material is a ‘by-product’ or a ‘waste’ has to be decided on a case-by-case basis.

The European Commission has a mandate under the WFD to define ‘by-product’ criteria for specific substances or objects through comitology procedure. Additionally, Member States may set out by-product criteria at national level. These criteria need to be based on the four conditions of a BYP, and described above

We have explained – in summary – the By-Product legal framework because this legal notion enters quite often into the games when treating all kind of wastes, including photovoltaic panels.

In a number of cases, By-products are the result of initial waste treatment operations. For example, some recovered mono-material in a first treatment plant can be used by smelters as By-products. After the smelting operations, mono-materials generated by the smelter can be used as material recycling or by-product in for example clinker or concrete blocks.

European Union versus harmonisation

Besides the fact that the Waste Framework Directive is the overarching waste legislation in Europe, each specific Directive e.g. about Extended Producer Responsibility has Lex specialis status.

The recycling definition in the WFD might slightly be different from the recycling definition used in Directives related to specific waste streams (e.g. Extended Producer Responsibility laws).

Moreover, the differences in recycling yield are in the European Union different per country because one EU-27 country might have a different interpretation of the definition of ‘recycling’ depending on which treatment technology or application is used.

This might be caused by personal opinions at the public administration or might be triggered by economical considerations to protect the local recycling industry.

Last point, there is no global definition of ‘recycling’ or ‘recovery’.

Hence, the waste treatment and as consequence the recycling and the recovery yield of photovoltaic panels, is today not harmonized, nor within the European Union, nor within other countries and regions around the globe. When you are reading recycling or recovery results, it is important to realize that the wording ‘recycling’ has around the globe several and different definitions and interpretations.