End-of-life photovoltaic modules are classified as industrial solid waste. As entities that “generate industrial solid waste,” PV power plant owners are subject to Article 490 of the Ecological and Environmental Code, which clearly stipulates that entities generating industrial solid waste must verify the principal qualifications and technical capabilities of entrusted parties. Failure to fulfill this verification obligation constitutes a violation of the law.

According to Item (4) of Article 1171 of the Code, where “an entity generating industrial solid waste entrusts another party to transport, utilize, or dispose of industrial solid waste in violation of this Law,” the competent ecological and environmental authority shall order rectification, confiscate illegal gains, and impose a fine of not less than 100,000 yuan but not more than 1 million yuan. In serious cases, it may also order the suspension of operations or closure.

With respect to civil liability, Article 1068 of the Code clearly stipulates that an entrusting party that fails to fulfill obligations such as verification and supervision shall bear joint and several liability with the entrusted party that causes environmental pollution. Once a small workshop causes environmental pollution during dismantling, the waste-generating party must also bear liability.

How to determine whether a disposal provider is compliant

Qualifications: A complete set of four certificates—business license, environmental impact assessment approval, pollutant discharge permit, and relevant filing/qualifications for solid waste disposal—is the minimum requirement. This can prevent joint environmental liability and also meet financial accounting requirements.

Process: Whether environmentally friendly processes such as physical crushing and pyrolysis are used, and whether the overall recovery rate reaches more than 90%.

At present, leading domestic companies can process up to 20,000 tonnes annually using pyrolysis, with an overall recovery rate of 96%. Although the physical method currently dominant in the industry has a simple process and relatively low cost, it has limitations in material purification. Therefore, integrated recycling technology combining physical crushing, pyrolysis, and chemical purification is becoming the industry consensus and development direction.