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Market update · Europe · Used panels & recycling

PV CYCLE calls for stronger enforcement against illegal exports of end-of-life solar panels

PV CYCLE is calling for stricter enforcement against illegal cross-border shipments of discarded solar panels. Legitimate reuse remains possible, but exporters need clear contracts, documented safety and functionality testing, and written confirmation that the modules are not waste.

SolTraCo market update · · 4 min read

Collection volumes are rising, but more slowly than expected

PV CYCLE collected 1,785 tonnes of end-of-life solar panels in Belgium in 2025, an increase of 20% compared with 2024. Director Jan Clyncke says the volume remains a small share of the installed base because many systems continue operating beyond the point at which earlier forecasts expected them to be replaced.

The organisation has 435 participating companies and says these represent approximately 99.9% of the Belgian market. Belgium's visible environmental contribution on PV invoices finances collection and processing through a dedicated fund, helping to cover future costs for a product with a long service life.

Recycling capacity is developing

PV CYCLE reports a recycling rate of 86% and a valorisation rate above 96%, driven mainly by the recovery of glass and aluminium. Belgium currently works with three recycling companies, although one processing line is temporarily on hold while it is upgraded.

New recycling methods, including mechanical, thermal and chemical processes, are also being developed. However, the economics remain challenging: processors still charge for treatment, while newer module designs may contain less aluminium and silver, reducing the value of the recovered material.

Illegal exports undermine legitimate reuse

PV CYCLE identifies illegal exports as a persistent problem. End-of-life panels are leaving the European Union for destinations including the Sahel, Afghanistan and Pakistan. Cross-border reuse is not inherently unlawful, but shipments become problematic when waste is presented as functional second-hand equipment or when the required documentation is absent.

Under the Basel Convention and the European Union's Waste Shipment Regulation, a reuse shipment requires a contract or invoice between sender and recipient, evidence that the modules have been tested for functionality and safety, and written confirmation on company letterhead that the shipment is not waste. PV CYCLE says these requirements are often not followed in practice.

The organisation is working on a standard expected to be published in 2026 as a step towards an IEC standard. The aim is to give environmental inspectors a clearer framework for distinguishing legitimate reuse from illegal waste shipments.

Commercial relevance for used-panel transactions

For cross-border used-panel trading, module condition and documentation are as important as price. Sellers and buyers need traceable ownership, an identifiable destination, test evidence, safe packing and contractual records before panels move across borders.

Modules that pass a credible functionality and safety assessment may qualify for reuse. Loads containing damaged, unsafe or untested panels risk being classified as waste and should enter a compliant recycling route instead. For project owners, early sorting and documentation reduce regulatory risk and help preserve the value of genuinely reusable modules.

Sources

This update is an original SolTraCo synthesis of the linked industry sources. Reported facts and commercial interpretation are kept separate. It does not contain confidential deal information and is not investment, legal or technical advice.