Solar Panel Waste in India: The EPR Obligation Coming for Every Rooftop and Utility Project

Updated: October 10, 2026 · 16 min read

India’s solar panel installations crossed 90 GW of cumulative capacity by mid-2026 — a milestone celebrated by the Ministry of New and Renewable Energy and every ESG report from Rajasthan to Tamil Nadu. What those reports do not carry, with equal prominence, is the arithmetic on the other end: a 25-year panel lifespan means the modules commissioned in the early 2000s and the mid-2010s are already entering their end-of-life phase, and the next decade will see that trickle become a flood. For producers, importers, and large-scale developers, solar panel waste EPR India obligations are no longer a future agenda item — CPCB’s enforcement machinery is already warm, and the compliance window for FY 2026-27 is open.

1.8 Lakh Tonnes by 2030: India’s PV Waste Problem Is No Longer Future Tense

NITI Aayog and the International Renewable Energy Agency (IRENA) have separately projected that India could generate between 1.8 lakh and 4.4 lakh tonnes of photovoltaic panel waste annually by 2030, depending on the pace of capacity additions and the rate of early replacements driven by efficiency upgrades. Even the conservative estimate dwarfs current formal recycling capacity. India’s 500 GW target for 2030 — anchored in the National Solar Mission — all but guarantees that both the installed base and the corresponding end-of-life wave will be larger than any projection made five years ago.

The composition of a decommissioned solar panel is itself the compliance problem. A standard crystalline silicon module contains aluminium frames (roughly 11–15% by weight), glass (roughly 65–75%), silver-paste contacts, copper wiring, lead-based solders in older units, and trace quantities of cadmium and selenium in thin-film variants. Under Indian law, lead and cadmium classify a spent PV module as a hazardous waste under Schedule II of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 — a fact that catches many renewable energy developers by surprise when they discover that informal disposal or landfilling of even a single broken panel can constitute a cognisable offence.

The volume projections are not uniform across states. Rajasthan, Gujarat, and Andhra Pradesh — which host the largest utility-scale solar parks — will disproportionately generate decommissioned modules. Maharashtra, Karnataka, and Tamil Nadu will see significant rooftop volumes. State Pollution Control Boards (SPCBs) in these states are increasingly cross-checking generation capacity records with EPR registration data, a scrutiny model borrowed directly from the e-waste enforcement playbook.

How Solar Panels Enter India’s E-Waste Framework: Schedule I and the 2022 Rules

The regulatory home for end-of-life solar panels is the E-Waste (Management) Rules, 2022, notified by the Ministry of Environment, Forest and Climate Change (MoEFCC) on 1 November 2022 and published in the Official Gazette (G.S.R. 801(E)). Schedule I of the Rules lists the categories of electrical and electronic equipment subject to EPR obligations. Solar photovoltaic panels — including monocrystalline, polycrystalline, and thin-film modules — appear explicitly in this Schedule, bringing them squarely within the definition of “electrical and electronic equipment” for regulatory purposes.

This was a deliberate and significant expansion from the earlier E-Waste (Management) Rules, 2016, which referenced solar panels only obliquely. The 2022 Rules resolved the ambiguity. Rule 4 of the 2022 Rules mandates that every producer of equipment listed in Schedule I register on the CPCB’s centralised EPR portal and submit an EPR plan specifying annual collection and recycling targets. Importers are treated as producers for the purposes of this obligation — a provision with immediate implications for EPC contractors who import panels from Chinese or Vietnamese manufacturers on a project-by-project basis.

What “Producer” Means in the Solar Context

The 2022 Rules define a producer as any person who manufactures and sells, imports, or re-brands electrical and electronic equipment in India. For the solar sector, this captures: (a) domestic module manufacturers such as those in Surat’s solar manufacturing cluster; (b) importers of foreign-origin panels, including project developers who self-import; and (c) brand owners who affix their name to equipment manufactured by a third party. An EPC contractor who procures and installs modules on behalf of a client sits in a grey zone — but the regulatory default position, reinforced by recent CPCB guidance, is that liability flows to the entity whose name appears on the commercial invoice and customs bill of entry.

Who Is Obligated? Producers, Importers, Brand Owners, and the EPC Contractor Question

Establishing who holds the EPR obligation is not an academic exercise — it determines who registers on the CPCB portal, who files the annual return, and who faces the show-cause notice if collection targets are missed. The 2022 Rules draw the line clearly in principle, but the solar sector’s project-delivery model creates genuine ambiguity that enforcement is beginning to test.

Consider a utility-scale developer in Rajasthan who awards an EPC contract to a tier-1 contractor, who in turn imports 500 MW of modules under a master supply agreement. The customs importer of record is the EPC contractor, but the modules are branded with the developer’s project name, and the developer holds the Power Purchase Agreement and the land lease. Under Rule 3(1)(p) of the E-Waste (Management) Rules, 2022, the “producer” definition encompasses the entity that places the equipment on the market — which could, on a generous reading, include the developer. Both parties would be prudent to contractually allocate EPR responsibility and ensure the obligated entity is registered before modules are commissioned.

For rooftop solar — residential and commercial alike — the obligation typically rests with the solar company supplying and installing the system. However, where a corporate offtaker or a commercial establishment installs a captive rooftop system by importing panels directly (common in the 1–10 MW range), that establishment becomes the importer-producer. Compliance heads in manufacturing and warehousing companies that have invested in captive solar in Gujarat or Pune need to audit their import documentation against the EPR registration requirement.

EPR Targets, Storage Obligations, and the Hazardous Waste Overlap

The E-Waste (Management) Rules, 2022 establish a phased EPR target structure for all Schedule I categories. For solar panels, the target trajectory requires producers to collect and channel for recycling an increasing percentage of the weight of equipment they placed on the market in a reference year. The specific solar panel targets, read alongside MoEFCC’s clarificatory office memoranda, set a baseline of 10% collection in FY 2023-24, stepping up through annual increments towards a long-term target of 70% as the installed base matures. Producers who fail to meet targets must either purchase EPR certificates from compliant recyclers on the CPCB portal or face the penalty consequences described below.

The hazardous waste angle adds another layer of obligation. Where a decommissioned solar panel contains cadmium (relevant for CdTe thin-film modules) or lead-based solder (present in a significant proportion of pre-2020 crystalline silicon modules), its storage and transport must comply with the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. Rule 7 of those Rules requires generators of hazardous waste to maintain a record of waste generated, stored, and dispatched — and to store hazardous waste for no more than 90 days without SPCB authorisation. A large solar park decommissioning even 5 MW of old panels in one season can easily cross the threshold that triggers hazardous waste storage authorisation requirements, particularly in Maharashtra (governed by MPCB) and Gujarat.

Transport and Manifest Requirements

Spent solar panels transported off-site must be accompanied by a manifest under Form 6 of the Hazardous Wastes Rules, 2016 if they are classified as hazardous. The transporter must hold a valid SPCB authorisation for hazardous waste transport. Routing waste through an informal scrap dealer — however common the practice — exposes both the generator and the transporter to prosecution under Section 15 of the Environmental Protection Act, 1986, which carries imprisonment of up to five years and fines up to ₹1 lakh per day of continuing violation. The 2022 E-Waste Rules additionally impose an EPR-specific penalty structure (discussed in the next section) that operates independently.

The Recycler Capacity Gap: Why EPR Compliance Is Harder Than It Looks

Registering on the CPCB EPR portal is step one. Finding an authorised recycler with actual PV module processing capability is step two — and it is considerably harder. As of the first half of 2026, only a small number of India’s CPCB-authorised e-waste recyclers have invested in the specialised equipment needed to separate solar panel components: the high-temperature thermal processing or chemical dissolution lines required to recover silicon wafers, silver, and copper from encapsulant layers. The majority of registered e-waste recyclers in India handle IT and consumer electronics, not PV modules.

The result is a structural capacity gap. Industry body estimates, supported by data shared at the CII Sustainability Summit in early 2026, suggest that India’s formal PV recycling capacity stands at under 5,000 tonnes per annum — against a projected annual waste volume that could reach 30,000–50,000 tonnes by FY 2027-28, rising sharply thereafter. This is not a theoretical gap; it directly limits how many EPR certificates a developer can legitimately procure. CPCB has flagged the risk of certificate inflation — certificates issued against recycling claims that are not backed by actual processing — and has tightened audit requirements for recyclers in FY 2026.

For compliance officers, the practical implication is this: do not assume that because EPR certificate procurement is the backstop mechanism, it will always be available at a reasonable price or in the required volume. Early contracting with recyclers who have verifiable PV module processing lines is both a compliance necessity and a commercial hedge. Our EPR compliance services page outlines what a valid recycling agreement and certificate chain looks like in practice.

Year-Wise EPR Targets and Penalty Slabs: The Numbers Your CFO Needs

The table below sets out the indicative EPR collection targets for solar PV modules under the E-Waste (Management) Rules, 2022, alongside the penalty exposure for shortfalls. Producers should treat these targets as floor obligations, not aspirational benchmarks.

Financial Year	EPR Collection Target (% of POM weight)	Penalty for Shortfall (per tonne)	Governing Authority
FY 2023-24 (baseline)	10%	Up to ₹1 lakh per tonne of shortfall	CPCB / MoEFCC
FY 2024-25	20%	Up to ₹1 lakh per tonne of shortfall	CPCB / MoEFCC
FY 2025-26	30%	Up to ₹1 lakh per tonne of shortfall	CPCB / MoEFCC
FY 2026-27 (current)	40%	Up to ₹1 lakh per tonne of shortfall	CPCB / MoEFCC
FY 2027-28 onwards	Stepping to 70% by FY 2029-30	Up to ₹1 lakh per tonne of shortfall	CPCB / MoEFCC

The penalty of up to ₹1 lakh per tonne of EPR shortfall operates under the framework of the Environmental Protection Act, 1986, which empowers CPCB to issue directions and impose financial consequences. In FY 2026, CPCB has issued show-cause notices to several e-waste producers — including entities in the solar category — for failing to meet FY 2024-25 targets and for lapses in EPR annual return filing. These actions signal that the regulator is moving from a registration-compliance posture to an enforcement posture. Solar-sector producers who registered in 2023 and then treated the obligation as a one-time administrative exercise are the most exposed.

Separately, producers who wish to understand how EPR certificate pricing works — including the floor price mechanism that CPCB introduced to prevent certificate dumping — should read our detailed post on the CPCB floor price framework for EPR certificates, which covers the pricing logic applicable to all Schedule I categories, including solar panels.

The 7-Step Solar EPR Compliance Checklist for FY 2026-27

Compliance with solar panel waste EPR obligations in India requires action across legal, procurement, and operational functions. The following checklist reflects the specific obligations under the E-Waste (Management) Rules, 2022 and the Hazardous and Other Wastes Rules, 2016, as they apply to solar producers, importers, and large-scale developers in FY 2026-27.

1. Confirm your “producer” status: Review import records, customs bills of entry, and commercial invoices for all solar modules placed on the Indian market. If your entity name appears as importer of record, you are a producer under Rule 3(1)(p) of the E-Waste (Management) Rules, 2022.
2. Register on the CPCB EPR portal: If not already registered, complete EPR registration at cpcb.nic.in/e-waste. Submit your EPR plan, including projected placed-on-market (POM) quantities for FY 2026-27 and a collection/recycling roadmap to meet the 40% target.
3. Audit module inventory for hazardous classification: Determine whether your decommissioned or damaged modules contain cadmium (thin-film) or lead solder (pre-2020 crystalline silicon). If yes, hazardous waste storage and transport obligations under the Hazardous and Other Wastes Rules, 2016 apply — including the 90-day on-site storage limit under Rule 7.
4. Contract with a CPCB-authorised PV recycler: Do not rely on generic e-waste recyclers without verified PV module processing capability. Request the recycler’s CPCB authorisation certificate and confirm it covers “solar photovoltaic modules” as a processing category. Obtain a template certificate of recycling before signing.
5. Embed EPR clauses in EPC and O&M contracts: For projects in construction or under long-term O&M agreements, insert explicit contractual provisions allocating EPR responsibility, specifying which party registers with CPCB, and requiring the recycling contractor to provide Form 6 manifests for hazardous module transport.
6. File the EPR Annual Return by 30 June 2027: The annual return for FY 2026-27, covering POM quantities and recycling achieved, must be filed on the CPCB portal. Cross-reference recycling certificates from your authorised recycler to substantiate claims. Our guide on EPR annual return filing deadlines and audit trails provides the documentation checklist.
7. Prepare BRSR disclosure data: Listed companies and large unlisted entities subject to SEBI’s Business Responsibility and Sustainability Reporting (BRSR) framework must disclose hazardous waste generated and e-waste managed under Principle 2 of the BRSR. Solar panel waste data — including weight recycled, recycler name, and certificate numbers — must be documented now to support the FY 2026-27 BRSR report.

Related Articles

• E-Waste Floor Price for EPR Certificates: What CPCB’s Pricing Framework Means for Your Budget
• E-Waste EPR Targets Under the 2022 Rules: Year-Wise Percentages Every Producer Must Hit
• EPR Annual Return Filing: Deadlines, Data You Need and the Audit Trail That Survives Scrutiny

Frequently Asked Questions

Are solar panels legally classified as e-waste in India?

Yes. Solar photovoltaic modules are explicitly listed under Schedule I of the E-Waste (Management) Rules, 2022, notified by MoEFCC on 1 November 2022. This brings them within the full EPR framework — including registration obligations, annual collection targets, and the requirement to channel end-of-life panels only to CPCB-authorised recyclers. The classification was a deliberate expansion from the 2016 Rules, which covered solar panels only ambiguously.

What is the EPR collection target for solar panels in FY 2026-27?

Under the E-Waste (Management) Rules, 2022, the EPR collection and recycling target for solar PV modules in FY 2026-27 is 40% of the weight of modules placed on the Indian market in the corresponding reference year. This steps up annually towards a long-term target of 70%. Shortfalls attract penalties of up to ₹1 lakh per tonne of uncollected/unrecycled weight under the Environmental Protection Act, 1986.

Do EPC contractors need to register for EPR, or does the liability rest with the developer?

It depends on who is the importer of record. Under Rule 3(1)(p) of the E-Waste (Management) Rules, 2022, the producer/importer — the entity whose name appears on the customs bill of entry — holds the primary EPR obligation. Where the EPC contractor imports modules on behalf of the developer, the contractor is the obligated producer unless the contract explicitly transfers that liability and the developer separately registers with CPCB. Both parties should take legal advice and document the allocation contractually.

Does solar panel waste qualify as hazardous waste under Indian law?

It can. Decommissioned solar panels containing cadmium (CdTe thin-film) or lead-based solder (present in many pre-2020 crystalline silicon modules) are classified as hazardous waste under Schedule II of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. Generators must comply with Rule 7 — including the 90-day on-site storage limit — and use Form 6 manifests for transport to authorised recyclers. Informal disposal is a prosecutable offence under the Environmental Protection Act, 1986.

How do I find a CPCB-authorised recycler specifically for solar panels?

The CPCB’s e-waste portal maintains a list of registered recyclers. However, most authorised recyclers process IT equipment — not PV modules. You must verify that the recycler’s CPCB authorisation specifically covers solar photovoltaic modules as a processing category and that they have physical processing infrastructure, not just registration. The National Recycling Corporation can assist in identifying and contracting vetted PV recycling partners — visit our e-waste management service page or contact us directly.

Work With The National Recycling Corporation

The National Recycling Corporation is a Mumbai-headquartered B2B recycling and scrap trading company with pan-India operations, and has been working with renewable energy developers, EPC contractors, and manufacturing companies on compliant end-of-life material management. As India’s solar EPR enforcement landscape tightens in FY 2026-27, we offer a structured service pathway for solar panel waste — from initial compliance consultation through to certified recycling and BRSR-grade documentation.

Our network includes CPCB-authorised disposal and recycling partners with verifiable PV module processing capability across Maharashtra, Gujarat, Rajasthan, Karnataka, and Tamil Nadu. Every engagement includes GST-compliant invoicing, certificates of recycling that identify waste by category and weight, Form 6 hazardous waste manifests where applicable, and a documentation package designed to satisfy both the CPCB annual return process and SEBI BRSR Principle 2 disclosures. Metal recoveries — aluminium frames, copper wiring, silver — are priced at fair market rates benchmarked against London Metal Exchange (LME) benchmarks, partially offsetting the cost of compliant recycling.

If you are a solar developer, an EPC contractor, or a corporate with a captive rooftop system approaching end of life, the time to build your vendor chain is before enforcement catches up — not after. Please contact us to discuss your EPR compliance requirements, or visit our dedicated EPR services page for a full picture of how we support producers under the E-Waste (Management) Rules, 2022.

• Pan-India collection logistics for end-of-life PV modules, including hazardous waste transport with Form 6 manifests
• CPCB-authorised recycling partners with verified solar panel processing capability
• Certificates of recycling suitable for CPCB EPR annual return filing
• GST-compliant invoicing and full audit-ready documentation trail
• BRSR Principle 2 disclosure support: waste generated, recycled, and channelled by weight and category
• Fair-market pricing for recoverable metals (aluminium, copper, silver) indexed to LME benchmarks

Sources and References

• CPCB E-Waste Portal — EPR Registration and Authorised Recycler Lists
• Ministry of Environment, Forest and Climate Change — E-Waste (Management) Rules, 2022 Gazette Notification (G.S.R. 801(E), 1 November 2022)
• CPCB — Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016
• NITI Aayog — Circular Economy and Solar Waste Policy Resources
• Central Pollution Control Board — EPR Enforcement Notifications and Show-Cause Guidance (FY 2026)
• London Metal Exchange — Aluminium and Copper Benchmark Prices
• International Renewable Energy Agency (IRENA) — “End-of-Life Solar PV Panels” report (referenced for global and India-specific volume projections)
• Press reports (Business Standard, Economic Times Energy) — coverage of CPCB enforcement actions in FY 2026 and MNRE solar capacity milestones