PV recycling: WEEE does not require an industry-specific take-back system20. June 2012 By: Oliver Friedrichs/Christoph Brellinger, take-e-way
The new WEEE directive is expected to come into effect for photovoltaic modules at the end of 2013. While the recycling implications are commonly-known, many manufacturers are not aware of the bureaucracy and cost expenditures involved. Take-e-way’s Oliver Friedrichs and Christoph Brellinger discuss the impact the directive is likely to have, and outline the processes involved. Overall, they believe a photovoltaic industry specific take-back system is not required.
Effect of the WEEE recast on PV manufacturers and importers
When the amended directive of the European Parliament and council on waste electrical and electronic equipment (WEEE) directive becomes binding for all manufacturers and importers of photovoltaic modules, affected producers will require support in implementing the new requirements.
The WEEE directive regulates, in summary, the professional recycling of waste electrical and electronic devices, and its financing by the manufacturers. In the future, photovoltaic modules will be included in this directive.
After the implementation of the "WEEE2" in the European Union, the requirements and obligations will already apply before the sales of photovoltaic modules, and not only when they are recycled.
Bureaucracy and cost expenditures are underestimated
It is apparent that lots of manufacturers of photovoltaic modules apparently do not yet realize these aspects, since the WEEE directive discussion often focuses on the recycling aspects. However, much more significant are the obligations, and their effects, which occur already in the short-term.
For example, in Germany, manufacturers and importers have to prove an insolvency-proof guarantee for the notified sales quantity, which involves a time-consuming registration process. Furthermore, they must undertake a complex monthly and annual reporting process. It is also necessary to provide a suitable disposal network, in order to be able to handle possible recycling requirements in compliance with the law in a timely and qualitative manner.
The accomplishment of these obligations is the basis for photovoltaic module sales in Germany, which is generally forbidden without the release of the registration and issuance of an individual WEEE number by the responsible authority.
Fines and prohibitions on sale as a result of illegal sales
Manufacturers found guilty of an administrative offence could incur a fine ofup to €100,000 as a result of an omitted registration, according to the ElektroG (Electrical and Electronic Equipment Act). The consequences may be confiscated profit, competition law conflicts and even general prohibition on sales. Therefore, manufacturers should take care to register their photovoltaic modules in accordance with the ElektroG in time.
Recycling can be handled via established systems
In Europe, the recycling and take-back of photovoltaic modules can be handled via the established logistics and recycling systems. Due to the integration in the ElektroG, for instance, in Germany, manufacturers do have an opportunity to handle their obligations in a cost-efficient way. However, if possible, it is necessary to make sure the used modules are not damaged when they are taken back. To do so, it is recommended to check if it would be possible to install a proper collection group for modules at the transfer points. The gathering and transportation can, for example, be performed on stake pallets.
WEEE does not require an industry specific take-back system for PV manufacturers
The consideration shows that it is not sufficient to consider the WEEE directive only from the end-of-life perspective (EOL), since the directive already becomes binding at the beginning of the photovoltaic module lifecycle, plus the recycling can be handled by already-established logistics and disposal structures.
Furthermore, among others, the self-organization of the manufacturers for the take-back of EOL photovoltaic modules did not previously protect against the integration of the industry in the WEEE directive, since the majority of EOL photovoltaic modules will only accrue in a few years and, therefore, it was not possible to generate sufficient collection rates.
The pure focus on the EOL recycling leads photovoltaic manufacturers into a cul-de-sac against the background of the upcoming WEEE directive. Due to this, the integration of the WEEE directive makes sense: The processes and structures have been successfully established for over seven years. Additionally, the WEEE rules dictate that EOL recycling be accepted, free of charge in more than 1,500 public recycling centres in Germany alone.
Overall, the industry-comprehensive system solutions for the complete handling of the WEEE directive have long been available on the market. The established providers have already implemented the learning curve effects in handling the WEEE directive after many years of experience, which can still be seen in their cost structures, their quality and their process reliability and, thus, to the benefit of photovoltaic manufacturers. Against this background, it will be difficult for industry specific take-back systems to enter the market.
Finally, it is relevant in the implementation of the WEEE directive to reduce the administrative burdens and to realize a quick registration. The manufacturers need to participate in a guarantee and recycling system, according to performance as a basis of the legal and cost optimized sales. To do so, no industry specific take-back system of the manufacturers is required, from our point of view.
About the authors
Oliver Friedrichs, qualified geographer, is the manager of the take-e-way GmbH in Hamburg, Germany, which that takes care of the requirements and obligations resulting from ElektroG for small and medium sized companies. Friedrichs is board member of the VERE Association for the Return and Recycling of electric and electronic Devices (VERE e.V.) the organization which has the largest number of members for the implementation of the ElektroG (Electrical and Electronic Equipment Act) in Germany.
Christoph Brellinger, graduated businessman, is the head of marketing and corporate communications of the take-e-way GmbH and is also responsible for the organisational communication and the public relations of the VERE Association.
Disclaimer: The views and opinions expressed in this article are the authors own, and do not necessarily reflect those held by pv magazine.
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