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Implementing a bidding and tendering verification system for “five social insurances and one housing fund” helps improve the standardization of the photovoltaic recycling industry
Jun 27, 2026

I. Policy Traceability: The “Five Social Insurance Programs and Housing Provident Fund” Verification Model in the Water Resources Sector Can Be Replicated in PV Recycling Bidding

On June 4, 2026, the Department of Water Resources of Xinjiang Uyghur Autonomous Region issued the Announcement on Requiring Proof of Payment of “Five Social Insurance Programs and the Housing Provident Fund” for Key Project Management Personnel in Bidding for Water Conservancy Construction Projects, which clearly lists proof of payment of pension insurance, medical insurance, work-related injury insurance, unemployment insurance, maternity insurance, and the housing provident fund for core personnel such as project managers, technical directors, and safety officers as mandatory bidding documents. Based on the Labor Law, the Social Insurance Law, and the Regulations on the Administration of Housing Provident Funds, the announcement clarifies that employers must pay the five social insurance programs and the housing provident fund in full for on-duty employees, and that tenderers have the right to verify the genuine employment relationships of personnel, thereby fundamentally addressing irregularities such as qualification affiliation and shell-company bidding.

This verification logic is not exclusive to the water resources sector and is fully applicable to the PV module recycling bidding market. As retired PV modules are currently entering a large-scale scrapping cycle, compliance governance in the industry has become urgent. Incorporating proof of payment of the five social insurance programs and the housing provident fund for core management personnel into bid qualification review can establish a screening threshold at the employment level, filtering out in batches trading intermediaries, shell companies, and illegal dismantling workshops that lack substantial production capacity and stable teams, and reshaping a fair competitive order in PV recycling bidding.

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II. Existing Pain Points in the PV Recycling Industry: Shell Traders and Small Workshops Disrupt the Bidding Market

(I) A Large Number of Asset-Light Trading Companies Borrow Qualifications for Collusive Bidding and Lack Contract Performance Capability

At present, nearly 5000 PV recycling-related enterprises are registered in China, but fewer than 20 are legitimate large-scale enterprises with complete hazardous waste disposal qualifications, standardized dismantling production lines, and stable professional teams. Most of the rest are pure trading intermediaries or shell companies. Such enterprises generally have three major shortcomings:
  1. No fixed full-time management team: They only hold registered business licenses and have no long-term on-duty project leaders, environmental protection specialists, or safety managers. During bidding, they temporarily borrow personnel certificates from external entities for qualification affiliation, make short-term proxy social security payments, and make zero housing provident fund contributions, participating in bidding merely by piecing together qualifications;
  2. No self-owned disposal sites or equipment: They have no compliant hazardous waste storage workshops or harmless dismantling equipment. After winning a bid, they subcontract the work to underground small workshops to earn the price spread and cannot implement environmental disposal requirements;
  3. Frequent collusive and bid-rigging practices: Multiple affiliated shell enterprises bid simultaneously, manipulating quotations to squeeze out legitimate enterprises and creating a situation in which “bad money drives out good.”

(II) Illegal Dismantling Workshops Engage in Low-Cost Malicious Competition, Causing a Complete Breakdown of Compliance Bottom Lines

Hundreds of illegal PV dismantling workshops are scattered across the country. Without environmental impact assessments or hazardous waste operation permits, they avoid investments in waste gas and wastewater treatment and labor protection, reducing dismantling costs to around half those of legitimate enterprises, and rely on high prices to compete for retired modules. If such entities enter bidding through qualification affiliation, they will create multiple risks:
  1. Environmental pollution risks: Crude dismantling releases toxic and harmful substances such as lead, cadmium, and fluorides. Without anti-seepage measures or waste gas collection facilities, it contaminates soil and groundwater and violates the requirements of the Solid Waste Law and the Ecological and Environmental Code;


  1. Severe waste of resources: They simply strip off aluminum frames for resale, while high-value metals such as silicon, silver, and copper are discarded at will, which runs counter to the policy direction of PV circular utilization.

(III) Traditional Social Security-Only Verification Has Loopholes, While Housing Provident Fund Verification Creates Dual Evidence Locking

In the past, bidding only checked social security contribution records, leaving room for falsification through short-term proxy payments, one-time back payments, and affiliated proxy payments. By contrast, housing provident fund accounts are managed on a one-person, one-account basis and are networked nationwide, with strict restrictions on back payments and very few proxy payment channels, making falsification extremely costly. To reduce costs, many shell traders and small workshops will not open housing provident fund accounts for temporarily affiliated personnel and can only forge social security transaction records. Housing provident fund contribution records can directly expose false employment relationships.

III. Screening Logic for Applying “Five Social Insurance Programs and Housing Provident Fund” Verification to PV Recycling Bidding

With reference to the legal basis in the announcement of the Xinjiang Department of Water Resources, tender documents for PV recycling projects may add clauses requiring bidders to provide official proof of payment of the five social insurance programs and the housing provident fund for the project leader, environmental protection supervisor, and full-time safety officer for 6 consecutive months. The payment entity must be exactly the same as the name of the bidding enterprise. Missing records, payment interruptions, or inconsistencies in the payment entity shall directly result in failure of qualification review, enabling three layers of precise screening:

Layer 1: Screen Out Pure Trading Shell Companies

Pure intermediaries have no substantial production operations or long-term, stable full-time teams, and will not continuously pay housing provident fund contributions for project management personnel. Shell enterprises only borrow certificates temporarily for bidding and cannot provide continuous housing provident fund contribution details matching both the personnel and the entity. They will directly lose bidding eligibility, eliminating subcontracting arbitrage behavior of “only taking orders without disposal” at the source.

Layer 2: Eliminate Underground Small Workshops Without Fixed Employment

Illegal small workshops employ temporary casual workers and day laborers, do not sign formal labor contracts, and are even less likely to open housing provident fund accounts or pay the five social insurance programs and the housing provident fund in full. Legitimate recycling enterprises need to maintain long-term environmental protection, safety, and dismantling professionals and continuously pay housing provident fund contributions in accordance with regulations. This creates a clear distinction in employment compliance between the two, quickly separating out unqualified and unprotected dismantling workshops.

Layer 3: Prevent Certificate Affiliation and False Employment

Core positions in PV recycling projects require certified personnel to be on duty. Social security for affiliated personnel can be paid by proxy in the short term, but housing provident fund records for continuous contributions cannot be forged across different entities. Through two-way verification of social security + housing provident fund records, a closed-loop evidence chain for employment relationships is formed, thoroughly addressing illegal bidding practices such as borrowed qualifications and false on-duty appointments, and ensuring that winning bidders have genuine teams capable of contract performance.

About RESOLAR

Shanghai RESOLAR Energy Technology Co., Ltd. is committed to becoming a recycled material photovoltaic group with deep decarbonization. RESOLAR focuses on technological innovation and builds a world-leading solution for component recycling, impurity removal of damaged cells, recycled silicon materials and cells, and cascaded utilization of components. With professional technology and services, we help customers realize the recycling and reuse of waste photovoltaic resources, and make positive contributions to the development of environmental protection and new energy industries. For more detailed information, you can browse the official website: www.resolartech.com .

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