Determine the correct end-of-life disposal and recycling path for decommissioned PV panels given current federal and state waste rules

Steps

1. Check panel manufacturer/composition data first — whether a given panel is classified as hazardous waste depends on its material content (e.g., cadmium telluride vs. standard crystalline silicon) and can vary by panel model
2. Confirm there is currently NO final federal universal-waste classification for PV panels: EPA's proposed rule to add solar panels to the RCRA Universal Waste program (40 CFR Part 273) is expected as a proposal around February 2026, with a final rule not expected until roughly August 2027
3. Check state-level rules directly, since only California and Hawaii have formally reclassified solar panels as universal waste at the state level as of this research — other states default to standard (often non-hazardous, landfill-eligible) waste rules absent their own reclassification
4. For California or Hawaii projects, follow the state-specific universal waste handling, storage, and manifesting requirements rather than assuming a national standard applies
5. Where a formal state or federal universal-waste path doesn't yet apply, use a manufacturer or third-party PV recycling program voluntarily rather than defaulting to landfill disposal, and document the disposition for customer/ESG reporting purposes