Solar Panel Recycling EPR: India’s Next Compliance Bombshell for Power Companies

Updated: July 11, 2026 · 16 min read

India crossed 90 GW of installed solar capacity in early 2025. Almost nobody in the power sector is talking about what happens when those panels come down. MoEFCC circulated a draft Extended Producer Responsibility framework for solar photovoltaic modules in 2024 — and when it is formally notified, the compliance window for solar developers, EPC contractors, independent power producers and corporate rooftop buyers will be shorter than most boards currently appreciate. The question is not whether solar panel recycling EPR India rules are coming. It is whether your organisation will be ready before the first enforcement cycle begins.

1.8 Million Tonnes by 2030: The PV Waste Crisis India Cannot Defer

The International Energy Agency’s 2023 Special Report on Solar PV Global Supply Chains, read alongside projections published by the Central Pollution Control Board (CPCB), places India’s cumulative end-of-life solar PV waste at approximately 1.8 million tonnes by 2030 under a moderate-growth scenario — and closer to 3.2 million tonnes under an accelerated-deployment scenario aligned with India’s 500 GW renewable target. These are not speculative figures. They are calculated from actual installation records, manufacturer-declared module lifespans of 25–30 years, and early-retirement rates driven by efficiency degradation, storm damage, and policy-led plant repowering.

The more immediate concern is the first wave: modules installed between 2010 and 2015 under the Jawaharlal Nehru National Solar Mission’s Phase I are now entering the 12–15-year band, where degradation rates accelerate and bankability assessments often recommend replacement. In Rajasthan and Gujarat — India’s two largest utility-scale solar states — this first decommissioning cohort is estimated to produce roughly 200,000 tonnes of PV module waste between 2025 and 2028, according to NITI Aayog working papers on circular economy transition.

Solar panels are not inert. A standard crystalline silicon module contains lead-based solder, cadmium telluride (in CdTe thin-film variants), antimony, and hexavalent chromium traces — all of which qualify as hazardous constituents under Schedule II of the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016. Dumping decommissioned panels in municipal landfills — which is currently the informal practice at smaller rooftop installations — is already a legal violation under those rules, irrespective of whether a specific solar EPR notification has been issued.

What MoEFCC’s Draft Solar EPR Framework Actually Proposes

The Ministry of Environment, Forest and Climate Change (MoEFCC) circulated a draft notification in 2024 proposing an EPR regime for solar PV modules. The structural architecture is unmistakably borrowed from the E-Waste (Management) Rules, 2022 — the same rules that have since driven aggressive CPCB enforcement action against electronics producers and importers who failed to register on the central EPR portal. The parallels are deliberate: MoEFCC wants a proven scaffolding, and the e-waste EPR framework, now with over 40,000 registered producers, is the closest Indian precedent for a product-category-specific extended producer responsibility regime.

Under the draft proposals, “producers” are defined broadly to include manufacturers of PV modules sold in India, importers of modules, and — critically — project developers who commissioned plants using modules procured from entities that no longer exist or are not registered in India. This last category is the most significant. A sizeable portion of India’s early solar capacity was built using Chinese module brands that have since restructured, been acquired, or exited the Indian market. In such cases, the draft proposes that the developer or EPC contractor who commissioned the plant bears the EPR obligation.

Registration and EPR Credit Mechanics

The draft framework envisions a two-track compliance mechanism. Producers above a prescribed threshold (likely 1 MW of modules sold or commissioned in a financial year) would be required to register on the CPCB’s centralised Extended Producer Responsibility portal — the same platform currently used for plastic and e-waste EPR. They would then be required to either (a) channel end-of-life modules to CPCB-authorised recyclers and obtain EPR credits, or (b) purchase EPR credits from the exchange mechanism proposed under the rules. Annual EPR targets under the draft are structured as a percentage of the producer’s historical sales volume, with the target escalating from an estimated 30% recovery in the first year of enforcement to 70% by Year 4 — a ramp-up rate identical to the trajectory set for battery EPR under the Battery Waste Management Rules, 2022.

Producers who miss EPR targets would face an Environmental Compensation levy, the quantum of which the draft pegs at ₹5 per watt-peak (Wp) of unrecovered module capacity — a figure that translates to approximately ₹18–22 lakh per MW of unrecovered waste. For a 100 MW plant operator with no recycling arrangement in place, the exposure is material.

Retrospective Risk: Why Plants Already Commissioned Are Not Safe

The single most contentious provision in the draft is retrospective applicability. The framework, as currently worded, would require producers to account for the total stock of modules they have placed in the Indian market since commercial sales began — not merely modules sold after the rules’ notification date. This is analogous to the retrospective EPR targets that blindsided several electronics importers when the E-Waste (Management) Rules, 2022 were enforced through CPCB notices in 2023 and 2024, requiring companies to demonstrate recycling volumes against multi-year historical sales data.

For solar developers, this creates a concrete balance-sheet risk. A developer who commissioned a 250 MW plant in Andhra Pradesh in 2016 using imported Chinese modules would, under the draft, be responsible for the EPR obligations on those modules once the plant is decommissioned — even if the plant is still operational today. The draft does not grandfather existing installations. Compliance officers at IPPs and EPC firms need to treat this as a contingent liability that belongs in financial statements now, not when the plant reaches end-of-life.

Informally, recent CPCB enforcement actions under the existing Hazardous Waste Rules against waste handlers who improperly stored decommissioned panels have already flagged the regulatory posture. While no solar-specific enforcement order has been publicly issued, the direction of travel is clear: regulators are watching the waste stream, and the formal EPR notification will provide the legal instrument for structured enforcement.

The BRSR Core Disclosure Trap for Listed Power Companies

For companies listed on Indian exchanges, the compliance dimension extends well beyond MoEFCC’s forthcoming rules. Under BRSR Core as mandated by SEBI’s circular dated 12 July 2023, the top 150 listed companies by market capitalisation are required to provide third-party-verified disclosures on environmental metrics including waste generation, waste disposal methods, and circular economy initiatives. Power companies with significant solar assets — think Adani Green, Torrent Power, JSW Energy, NTPC Renewable Energy — are squarely within scope.

The BRSR Core reporting template includes a specific line item for “hazardous waste disposed of through authorised channels as a percentage of total hazardous waste generated.” Decommissioned solar modules, classified as hazardous under Schedule II of the Hazardous and Other Wastes Rules, 2016, fall within this disclosure. A company that cannot demonstrate authorised recycling of its decommissioned panels is exposed to a qualified verification opinion from its BRSR assurance provider — a reputational and investor-relations problem that ESG-sensitive institutional investors are increasingly treating as a governance red flag.

SEBI has signalled that BRSR Core coverage will expand to the top 250 companies by FY 2026-27, which means mid-sized renewable IPPs that currently sit outside the mandate should be building documentation systems now rather than scrambling in Year 1 of expanded coverage. Our dedicated page on EPR compliance services outlines how structured recycling partnerships can generate the documentation BRSR auditors require.

Decommissioning Cost Provisions: The ₹18–₹22/Wp Question Every CFO Must Answer

Indian solar project finance documents rarely contain a decommissioning reserve clause for panel recycling. This is a structural gap that lenders are beginning to notice. In comparable markets — Germany, Japan, the United States — project finance agreements for utility-scale solar plants routinely require developers to maintain a decommissioning fund equivalent to 3–5% of total project cost, ring-fenced in an escrow or bank guarantee. On a ₹450 crore, 100 MW plant, that translates to a ₹13.5–₹22.5 crore provision.

Indian project finance lenders — IREDA, SBI Capital, REC Limited — have not yet mandated this uniformly, but the Andhra Pradesh Electricity Regulatory Commission issued an advisory in 2023 noting that decommissioning obligations should be factored into project approval conditions. As MoEFCC’s EPR rules approach notification, expect lenders to begin inserting decommissioning bond requirements as a covenant in new project finance term sheets.

The recycling cost itself is a variable that the market has not yet priced with precision. Current indicative rates from the handful of operational solar PV recyclers in India — concentrated in Tamil Nadu, Telangana, and Maharashtra — suggest a gate fee of ₹18–₹22 per watt-peak (Wp) for crystalline silicon modules, inclusive of transportation and processing. CdTe thin-film modules command a higher rate due to cadmium handling requirements under the Hazardous Waste Rules. Against this, recovered materials — primarily aluminium frame scrap, copper wiring, and glass cullet — yield back roughly ₹6–₹9/Wp, making the net disposal cost approximately ₹10–₹15/Wp for a competently managed recycling chain. For reference, aluminium frame scrap from decommissioned panels grades as 6063-series alloy, currently trading at ₹145–₹155/kg across Mumbai and Pune scrap yards.

Solar PV EPR Targets and Timelines: What the Draft Rules Signal

The following table consolidates the indicative EPR targets, penalty structures, and compliance milestones as proposed in MoEFCC’s 2024 draft notification and cross-referenced with parallel frameworks under the E-Waste Rules, 2022 and the Battery Waste Management Rules, 2022. Treat these as indicative until the final gazette notification — but plan against them now.

Year of Enforcement	EPR Recovery Target (% of historical stock)	Environmental Compensation (₹/Wp unrecovered)	Key Compliance Action
Year 1 (FY 2025-26, upon notification)	30%	₹5/Wp	Register on CPCB EPR portal; appoint authorised recycler
Year 2 (FY 2026-27)	45%	₹5/Wp	Submit annual EPR return; purchase EPR credits if target missed
Year 3 (FY 2027-28)	60%	₹7/Wp	Third-party audit of recycling volumes; BRSR disclosure alignment
Year 4 onward (FY 2028-29+)	70%	₹10/Wp	Full EPR credit reconciliation; lender decommissioning bond compliance

The escalating Environmental Compensation rate — from ₹5/Wp in Year 1 to ₹10/Wp by Year 4 — is the draft’s enforcement lever. For a 500 MW IPP that misses its 70% recovery target in Year 4, the unrecovered 30% of historical module stock could represent a liability of ₹15–₹20 crore in a single financial year. That is a number large enough to be material in most power company P&L statements, and certainly large enough to attract audit committee attention.

The 7-Step Solar EPR Compliance Checklist for FY 2025-26

Given the near-certain notification of the rules within the current financial year, the following actions represent the minimum credible compliance posture for any solar developer, EPC contractor, or corporate rooftop buyer with more than 1 MW of commissioned capacity:

1. Conduct a module inventory audit: Compile a complete list of all PV modules commissioned to date — manufacturer, model, watt-peak rating, installation year, and current operational status. This is your EPR baseline; without it, you cannot calculate your recovery obligation.
2. Classify modules under the Hazardous Waste Rules, 2016: Identify CdTe thin-film or modules with lead-based solder above Schedule II thresholds, as these require distinct handling, transport manifests (Form 10), and disposal records under the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016.
3. Register on the CPCB EPR portal: Even before the solar-specific rules are notified, producers handling end-of-life panels with hazardous constituents should establish a presence on the CPCB EPR portal and maintain correspondence records, as regulators treat early registration as evidence of good-faith compliance.
4. Appoint a CPCB-authorised recycler and execute a formal agreement: Verbal arrangements will not satisfy EPR audit requirements. You need a written recycling agreement specifying volumes, timelines, and the recycler’s CPCB authorisation number — valid and current. Review our EPR compliance services for partnership structures that meet this requirement.
5. Build a decommissioning cost provision into your financial statements: Work with your CFO and auditors to establish a provision for EPR compliance costs at ₹10–₹15/Wp net of material recovery value. For BRSR Core reporters, this provision should be disclosed in the environmental liabilities section.
6. Align BRSR Core disclosures with PV waste data: If your company falls within SEBI’s top 150 or top 250 scope, ensure your BRSR assurance provider is furnished with recycling certificates, waste manifests, and authorised recycler agreements for the relevant reporting period. A gap here will produce a qualified verification opinion.
7. Engage your lenders and project finance teams on decommissioning covenants: If your plant has existing project finance facilities with IREDA, REC Limited, or domestic PSU banks, proactively flag the forthcoming EPR obligations. Lenders who discover this liability during covenant review — rather than from you — will treat it as a governance concern.

Related Articles

• Lithium-Ion Battery Recycling India: New Safety Norms, Fire Risks and Insurance Implications
• BRSR Core: Why SEBI’s New ESG Mandate Will Force a Rethink of Your Scrap Disposal
• CPCB Authorisation Renewal: The 30-Day Compliance Window Most Recyclers Miss

Frequently Asked Questions

Who is considered a “producer” under India’s draft solar EPR rules?

Under MoEFCC’s 2024 draft framework, “producers” include manufacturers of solar PV modules sold in India, importers of modules, and project developers who commissioned plants using modules from entities no longer registered in India. This mirrors the producer definition in the E-Waste (Management) Rules, 2022, where importers bear full EPR responsibility when the original foreign manufacturer has no registered Indian entity. EPC contractors who procured and installed modules on a developer’s behalf may also be jointly classified as producers depending on the contractual structure of the project.

What penalties apply for missing solar EPR targets once the rules are notified?

The draft rules propose an Environmental Compensation levy of ₹5 per watt-peak of unrecovered module capacity in Year 1, escalating to ₹10/Wp by Year 4. Additionally, non-registration on the CPCB EPR portal could attract action under the Environment (Protection) Act, 1986, with penalties of up to ₹1 lakh per day of continuing violation. Systematic non-compliance with EPR obligations under comparable rules — such as the Battery Waste Management Rules, 2022 — has resulted in CPCB show-cause notices and suspension of import licences coordinated with DGFT.

Are decommissioned solar panels classified as hazardous waste under existing Indian rules?

Yes. Certain solar PV modules — particularly CdTe thin-film panels and crystalline silicon modules containing lead-based solder above Schedule II thresholds — are classifiable as hazardous waste under the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016. Disposing of such modules in municipal landfills or through unregistered handlers is a current legal violation, irrespective of whether the specific solar EPR rules have been notified. Generators must use Form 10 transport manifests and channel waste only to facilities with valid CPCB or SPCB authorisation.

What documentation does a solar developer need to satisfy BRSR Core on PV waste?

Under BRSR Core (SEBI circular dated 12 July 2023), third-party-verified disclosures must cover hazardous waste disposed of through authorised channels as a percentage of total hazardous waste generated. For solar developers, the required documentation includes: (a) a recycling agreement with a CPCB-authorised PV recycler, (b) certificates of recycling specifying module model, weight, and watt-peak ratings, (c) Hazardous Waste transport manifests (Form 10) for each consignment, and (d) the recycler’s current CPCB authorisation number. Without these, a BRSR assurance provider cannot issue an unqualified verification opinion on the relevant disclosure line.

Can a corporate rooftop solar buyer be liable under the draft EPR rules?

Yes, if the module manufacturer or importer is not identifiable or not registered in India. The draft rules’ “last responsible entity” clause — borrowed from the E-Waste (Management) Rules, 2022 — allows CPCB to assign EPR obligations to the entity that placed the module in use if the original producer cannot be traced. Corporate buyers who procured rooftop systems through EPC turnkey contracts should review their EPC agreements to confirm which party bears the EPR obligation for end-of-life modules, and should seek contractual warranties or indemnities accordingly.

Work With The National Recycling Corporation

The National Recycling Corporation is a Mumbai-headquartered industrial recycling and scrap trading company with pan-India operations spanning Maharashtra, Gujarat, Karnataka, Telangana, Tamil Nadu, and Delhi-NCR. As the solar EPR regulatory landscape crystallises, we are positioned to be the compliance backbone for solar developers, EPC firms, and corporate rooftop buyers who need a documented, auditable recycling chain — not just a pickup service.

We work exclusively with CPCB-authorised processing and disposal partners. Every decommissioned solar module we collect is processed through an authorised facility, with full chain-of-custody documentation: hazardous waste transport manifests, weight-based certificates of recycling specifying recovered material fractions (aluminium, copper, glass, silicon), and GST-compliant tax invoices for all scrap materials recovered and credited back to you. All material pricing for recovered aluminium and copper is indexed to prevailing LME and domestic market rates, ensuring you receive fair-market value on every tonne. Our metal scrap recycling services and CPCB-authorised e-waste recycling service provide the same documentation standard — now being extended to solar PV waste streams as the regulatory framework matures.

For companies with BRSR Core reporting obligations, we provide BRSR-grade recycling certificates that your assurance provider can verify directly. For project finance compliance, we can provide lender-format disposal documentation confirming authorised end-of-life management. To discuss a decommissioning plan, schedule a module collection, or receive a compliance quote tailored to your plant’s installed capacity, please contact us directly.

• Pan-India pickup for decommissioned and damaged PV modules, including utility-scale and rooftop installations
• CPCB-authorised disposal partners with valid authorisation numbers — verifiable on the CPCB Hazardous Waste portal
• GST-compliant invoicing and credit notes for all recovered scrap materials (aluminium frames, copper wiring, glass cullet)
• Certificates of recycling and hazardous waste manifests formatted for BRSR Core assurance and EPR compliance filings
• Fair-market pricing on recovered metals, indexed to LME for copper and domestic market benchmarks for aluminium alloy 6063
• Dedicated account management for IPPs and EPC contractors handling multi-site decommissioning programmes

Sources and References

• Ministry of Environment, Forest and Climate Change (MoEFCC) — Draft Solar PV EPR Notification, 2024
• Central Pollution Control Board (CPCB) — Hazardous Waste Management and EPR Portal
• CPCB Extended Producer Responsibility Portal — Producer Registration and EPR Credit System
• CPCB — Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016
• NITI Aayog — Circular Economy and Waste Management Working Papers
• International Energy Agency (IEA) — Solar PV Global Supply Chains: Special Report, 2023
• SEBI — Business Responsibility and Sustainability Reporting (BRSR Core) Circular, 12 July 2023
• CPCB — E-Waste (Management) Rules, 2022: Producer Registration and EPR Compliance