How do you dispose of old solar panels? The 2026 federal and state rules, and a homeowner procedure

Who takes the panels down decides which rules apply

Federal hazardous waste law reaches a discarded panel only when two things are true: the panel is hazardous waste, and someone who is not a household generated it. The first is a test result; the second is a fact about your removal job. The Code of Federal Regulations, current through October 28, 2026, lists household waste among the solid wastes that "are not hazardous wastes" and defines it as material derived from households, including single and multiple residences (40 CFR 261.4(b)(1)). A separate section, 40 CFR 273.8, lets anyone managing exempt household waste choose to handle it under the universal waste rules if it is the same type as a listed universal waste.

The test result is a genuine unknown. EPA's frequent questions page on solar panel waste, updated September 18, 2026, says testing at end of life shows some panels exhibit the toxicity characteristic and some do not, and its regulations page adds that this can vary even within the same model and manufacturer. The usual trigger is lead or cadmium leaching in the toxicity characteristic leaching procedure; for lead, the regulatory limit is 5.0 milligrams per litre, which carries waste code D008. EPA's examples of generators are utilities, schools, commercial buildings and government buildings, and it tells homeowners to contact their installer or state and local environmental agencies. Washington's Ecology adds that cadmium telluride thin-film panels are more likely to designate as dangerous waste than ordinary silicon panels.

So the household exclusion does most of the work for a homeowner, and the state documents read for this guide show the specific ways it can stop applying. The table sets those cases side by side. Each line is one agency's reading of its own rules, not a national rule, which is why the state table further down matters as much as the federal text.

Two of those lines involve no decision by the homeowner at all. The contractor's routing and the panels' legal owner are both set by paperwork you sign, which is why the removal contract should state where the panels go and whether they go there directly.

The crew that "takes care of it"

Letting the removal crew "take care of" the old panels without saying where they go. Under Wisconsin's reading, panels that detour through a contractor's yard stop being exempt household waste, and in California a crew that drops them in a dumpster bound for a landfill is breaking the universal waste rules with your panels. A line in the contract naming the receiver, and a receipt afterwards, costs nothing and settles both.

The federal position on October 30, 2026: not yet a universal waste

The federal universal waste program is a lighter set of handling rules for common hazardous wastes, designed to make collection and recycling easier. As of the eCFR text current through October 28, 2026, 40 CFR 273.9 names five categories: batteries, pesticides, mercury-containing equipment, lamps and aerosol cans. Solar panels are not among them. EPA's frequent questions page states it directly: "Currently, solar panels are not a federal universal waste," although some states have added them as a state-only universal waste.

The rulemaking to change that has been running for years. A coalition of industry associations affiliated with the electric power industry petitioned EPA on November 19, 2021, and EPA announced the rulemaking on October 23, 2023. EPA's rulemaking page, updated July 31, 2026, says the agency is working on a proposal to add hazardous waste solar panels to 40 CFR Part 273 and, in the same package, a separate universal waste category tailored to lithium batteries. The dates have slipped between agenda editions, so the table prints each one with its source.

For a homeowner, a final federal rule would change less than the headlines suggest. The universal waste rules govern handlers: how they store, label, track and ship waste. The agenda abstract says the change would ease burdens on generators of solar panel waste, promote collection and recycling, and encourage municipal and commercial collection programmes, which is where a household would feel it, through more drop-off points. Part 273 already lets households opt in to universal waste management under 273.8. And a federal change does not land everywhere at once: Washington's Ecology tells businesses to keep following current regulations until new rules are codified and adopted in Washington. Until EPA publishes proposed text, the details of handling, labelling and frame removal for panels remain unwritten, so plan around the state rules in force on the day your panels come down.

State rules on one page, each with its date

Most states have no rule written for solar panels at all, so their general solid and hazardous waste rules apply. EPA's own list of state policies names California, Hawaii, New Jersey, North Carolina and Washington and says the list is not comprehensive. The table adds New York, which is weighing a rule, and three states whose agencies publish fact sheets or guidance pages for residents: Vermont, Iowa and Wisconsin. Every row cites the agency's own page or document; a few are Internet Archive copies of the agency's page, labelled with their save dates.

If your state is not in the table, start with its environmental agency, which EPA links from its list of state hazardous waste programmes, then your county or municipal solid waste office. Ask two things in the same call: whether panels from a house are treated as household waste, and which local facility accepts them.

California and Hawaii: where panels are already universal waste

California's rule began with SB 489, enacted on October 1, 2015, which added section 25259 to the Health and Safety Code and authorised the Department of Toxic Substances Control to designate end-of-life photovoltaic modules that are hazardous waste as universal waste. The regulation took effect on January 1, 2021. DTSC's universal waste page lists PV modules as one of eight categories, alongside batteries, electronic waste, cathode ray tubes and their glass, lamps, mercury wastes and non-empty aerosol cans, and it is blunt about the consequence: universal wastes "must be taken to a designated handler or recycler" and "cannot be discarded in household trash nor disposed of in landfills."

The paperwork in California falls on the businesses in the chain, not on you. Businesses that intend to manage waste PV modules as universal waste must notify DTSC for each facility, and handlers that accept more than 100 kilograms (200 pounds) of modules from offsite sources, or that treat them, file an annual report by February 1. DTSC also reminds handlers that its PV module standards apply only in California, so a load shipped to another state needs a hazardous waste determination first. What that means at home is simple: the place that receives your panels should appear on DTSC's published list of universal waste handlers that accept or recycle PV modules, and you should get a record of the drop-off.

Hawaii took a narrower route. Its Department of Health added solar panels as a universal waste category in rules effective June 7, 2021, and the chapter 11-273.1 guidebook for the edition effective July 7, 2025 shows the scope: the rules cover waste solar panels that exhibit a toxicity characteristic, and a handler who claims a panel is not hazardous bears the burden of showing it. A used panel becomes a waste on the date it is discarded. Handlers must store panels so they do not break, though intact panels need not be containerised, and any panel showing damage that could cause leakage must be placed in a closed, sound container. Since January 29, 2024, handlers may remove aluminium frames under conditions, which the department says cuts shipping costs because frameless panels stack more tightly. The guidebook incorporates 273.8, so household panels may be managed under these rules at the household's option; the department's pages read for this guide give no separate household instruction, so a Hawaii homeowner should ask the county or the department's Solid and Hazardous Waste Branch where to take them.

Washington's takeback law, now delayed to 2031

Washington is the one state in the table with a manufacturer takeback law for solar panels. Senate Bill 5939, passed in 2017, created chapter 70A.510 RCW, which requires manufacturers to give the public a convenient and environmentally sound way to recycle modules purchased after July 1, 2017, and to finance the takeback and recycling at no cost to the panel's owner. It covers modules on or integral with buildings, grid-connected modules, and off-grid uses such as solar fencing and signs.

The law has never fully taken effect. Ecology says the legislature amended it in the 2025 session to move the date by which manufacturers must have an Ecology-approved stewardship plan to sell panels in or into Washington from July 1, 2025 to January 31, 2031. Ecology itself requested the delay so the industry could keep operating legally while fixes to the law are developed, and it notes that some manufacturers had chosen not to sell panels in Washington rather than comply. Manufacturers may still develop plans voluntarily, so the practical step for a Washington homeowner is to ask the panel's maker whether it runs a takeback programme today.

Meanwhile Ecology's dangerous waste guidance does the day-to-day work. A panel on a residential home "likely meets the household hazardous waste exclusion" in WAC 173-303-071(3)(c), so it can go to a recycling centre that accepts solar panels or to a standard Subtitle D solid waste landfill with the landfill's approval. Panels a utility leases to a home are business waste and do not qualify. Businesses recycling panels under Ecology's interim electronic waste policy may accumulate them for no more than 180 days before shipping them for recycling.

New Jersey, North Carolina and New York: studies and drafts

New Jersey studied the problem by statute. P.L. 2019, c. 215, signed on November 7, 2019, created the New Jersey Solar Panel Recycling Commission, and its report dated November 29, 2023 found that there were no state mandates, policies or guidelines that specifically address end-of-life panels. It recorded that the state's largest utility, PSE&G, ships damaged or non-functional modules to out-of-state hazardous waste landfills at substantial cost, and that anecdotal evidence suggests some panels go into New Jersey solid waste landfills. Its recommendations were to amend N.J.A.C. 7:26A-7 so panels become universal waste handled by Class D recycling centres, to pass legislation banning landfill disposal, and to consider an advanced recovery fee per panel at purchase and an extended producer responsibility scheme. One recommended design had three regional depots offering pickup to residential clients. None of that is a rule a homeowner can rely on until it is adopted, and the NJDEP commission page, in the copy saved January 19, 2026, lists the statute, the 2023 report and meeting records but no adopted rule.

North Carolina's study came from S.L. 2019-132 (House Bill 329), which directed the Department of Environmental Quality and the Environmental Management Commission to inform rules on end-of-life panels, energy storage batteries and the decommissioning of utility-scale solar and wind. The final report, approved in January 2021, recommended rulemaking to add PV modules to the state's universal waste rules. It weighed a landfill ban and set out the case against one for now: recycling markets in the region were not developed, a ban could cause stockpiling, and after hurricanes or fires damaged panels mixed with debris may not be recyclable at all. Its practical line for non-hazardous panels is the useful one for a homeowner: they may go to a municipal solid waste landfill, but should not go to a construction and demolition landfill, because decommissioning solar equipment is not demolition and most such landfills are unlined. Ask DEQ's Division of Waste Management whether that recommended universal waste rule has since been adopted.

New York's Department of Environmental Conservation has a page stating it is considering adding solar panels to its universal waste rule, with draft definitions for photovoltaic cell, module and system in 6 NYCRR 370.2. In the copy saved November 11, 2025 it was an early-stage outreach page, not an adopted rule, and it noted that most panel waste is expected to come from the utility sector.

Vermont, Iowa and Wisconsin: what the state fact sheets tell residents

Vermont's Department of Environmental Conservation keeps it short. Its Solar Panels page tells residents to ask the company that installed the panels whether it will take them back for recycling, and if not, to contact the local Solid Waste Management Entity. Businesses are told to follow EPA's hazardous waste regulations. The page lists four reuse and recycling vendors serving Vermont with the note that inclusion is not an endorsement, and gives two handling rules worth copying anywhere: store all panels under cover, and keep them from breaking in storage or transport.

Iowa's Department of Natural Resources fact sheet, dated September 2021, says Iowa has no laws or rules specific to solar panel disposal or recycling. It answers the homeowner question directly: the federal hazardous waste law exempts homeowners, while businesses must make a waste determination. It then adds the catch: homeowners should work with their landfill or solid waste agency because some landfills may not accept used panels, even from homeowners. Panels are neither electronic devices nor universal wastes in Iowa, and a business's panels that prove hazardous cannot go to Iowa landfills; the fact sheet notes EPA Region 7 administers hazardous waste in the state. Its list of what makes panels hazardous is unusually specific: lead solder in older silicon panels, hexavalent chromium coatings on some older ones, cadmium in cadmium telluride panels, arsenic in gallium arsenide panels and selenium in CIGS thin film.

Wisconsin's 2024 guidance, PUB-WA-2038, is the most detailed of the three. A panel removed from a home that is not going to be reused, and that the household manages or disposes of, is household waste exempt under s. NR 661.0004 (2) (a). The department encourages recycling but says the panels could go to a solid waste landfill if the landfill is willing. It is the source of the consolidation rule in the first table: a contractor that takes household panels straight to a disposal or recycling facility keeps the exemption, while one that takes them back to its own warehouse operates under household hazardous waste collection rules. For businesses, it notes that panels that are hazardous waste cannot go to a solid waste landfill or incinerator, that Wisconsin has no active hazardous waste landfills, and that ASTM E3325-21 sets a standard practice for sampling panels for toxicity testing.

What recycling and disposal cost, from the public record

The Department of Energy's Solar Energy Technologies Office states the economics in one line: in the United States, the total cost of recycling panels is still generally greater than the cost of sending them to a landfill. No federal agency publishes a current per-panel recycling price, and no recycler's price list is used here. The figures below are the ones official state reports have printed, each with its year and its original source, because most of them are several years old and were gathered with utility-scale decommissioning in mind.

For California, Hawaii, New York, Vermont, Iowa and Wisconsin, no published per-panel cost figure was found. Treat every number in the table as a dated reference point to test a quote against, not as a price you should expect to pay. The North Carolina report also notes that landfills may reject bulky waste streams or adjust their fees, and a landfill that wants proof panels are not hazardous may ask for a test the owner pays for.

Twenty panels, four price points

Suppose an 8 kW array made of twenty 400-watt panels comes off a roof in a state with no panel-specific rule. The panel count and wattage are invented for the arithmetic; the per-panel weight of 40 to 50 pounds is the New Jersey commission's estimate, so the load is 800 to 1,000 pounds, or 0.4 to 0.5 tons.

At the $15 to $45 per panel range the New Jersey report attributes to NREL, recycling the twenty panels would cost $300 to $900. At North Carolina's $25 to $30 per module for high-value recycling it would be $500 to $600, before transport to the recycler. Landfilling the same load, where a landfill accepts household panels, would be about $40 to $50 at New Jersey's ballpark of $2 to $2.50 per panel, or about $17 to $21 at North Carolina's fiscal 2018-19 average tipping fee of $42.60 per ton. All four results are illustrations built from report figures of different years, not quotes.

Set against the $23,600 comparison line for an 8 kW system at the Department of Energy's Q1 2025 benchmark of $2.95 per watt DC (2024 dollars), even the top recycling figure is under 4 percent of that line: $900 divided by $23,600 is 3.8 percent. Removal labour is a separate and usually larger line, priced in the removal and reinstall guide. The gap between recycling and landfilling, a few hundred dollars here, is the gap the Department of Energy describes, and it is why the receiver's written price belongs in the removal contract.

From roof to receipt: the homeowner procedure

The order matters because each call can remove the need for the next one. The steps below assume panels you own outright on a house; a lease or a closed installer changes steps one and three, covered further down.

1. Decide whether the panels are waste at all. EPA does not treat a used panel sent for legitimate reuse or repair as solid waste. If the panels still produce power and you are removing them for a reroof, an upgrade or a move, resale or donation comes before recycling.
2. Read the labels before anything comes down. Photograph the make, model and serial number on each panel's label. Iowa's DNR advises consulting the manufacturer about a product's makeup, and the panel type (silicon or thin film) is the first thing a recycler will ask.
3. Confirm who owns the panels. If a leasing company or utility owns them, removal and disposal are its decision under the contract, and Washington treats utility-leased panels as business waste.
4. Ask the installer and the manufacturer about takeback. This is Vermont's first instruction to residents, and in Washington it is the route the stewardship law is meant to create.
5. Look up your state's rule in the table above and, if your state is not listed, call its environmental agency and the county solid waste office. In California, choose a receiver on DTSC's list of universal waste handlers that accept PV modules.
6. Find the receiver before the removal date. EPA points to the Department of Energy's photovoltaic manufacturing map (which includes recyclers), Earth911 and the Solar Energy Industries Association for recycler searches, and says it endorses none of them. Ask what the receiver charges per panel or per pound, whether it collects, and whether it issues a receipt or certificate of recycling.
7. Write the destination into the removal contract. Name the receiver, who transports the panels, and whether they go there directly or via the contractor's yard, which, under Wisconsin's reading, decides whether the household exemption still applies.
8. Store and move the panels carefully. Keep them under cover and protect them from breaking, as Vermont advises; Hawaii's handler rules give stretch-film-wrapped panels on a pallet as an example of storage that prevents breakage.
9. Keep the paperwork. File the receipt with the system's warranty and permit records. If you sell the house later, a buyer's inspector or the next installer may ask what happened to the original array.

Seven facts to have on paper before removal day

• Make, model, serial number and type (silicon or thin film) of every panel, photographed from the label.
• Who owns the panels, from the contract or lease.
• The installer's and the manufacturer's answer on takeback, in writing.
• Your state's rule and the agency or county office that confirmed it.
• The receiver's name, price per panel or per pound, and whether it collects.
• Whether the panels travel directly to the receiver or through a contractor's yard.
• A receipt or certificate of recycling, filed with the system's records.

Cracked glass, storm debris, and the parts that are not panels

An intact panel is a sealed object. EPA's frequent questions page says working panels do not leach their metals because a strong encapsulant prevents it; silicon modules are sealed under a front glass sheet with a polymer encapsulant and backsheet, and cadmium telluride cells sit between two sheets of glass. Breakage is what changes the handling. Hawaii's universal waste rules require a handler to clean up and containerise any panel showing damage that could cause leakage, and both Vermont and Wisconsin stress keeping panels from breaking during storage and transport. If a storm has shattered a panel, keep the pieces together, contained and out of the rain, and ask the receiver before delivery whether it accepts broken panels. A panel in daylight still produces voltage at its connectors even off the roof, so leave unplugging and wiring to the crew.

After a hailstorm or fire, disposal often becomes part of an insurance claim. Ask the adjuster in writing whether the estimate covers hauling and recycling the damaged array, and send the receiver's written price; the guide to solar and homeowners insurance reads the policy wording on dwelling coverage. North Carolina's report notes that when storm or fire debris is mixed through the panels, recycling may not be possible at all.

The rest of the system follows different channels. EPA's recycling page says inverters may be recycled with electronic waste, racking with similar scrap metals, and battery storage through existing battery recycling programmes. Wisconsin's table agrees and adds detail: aluminium framing and copper wiring are not hazardous and recycle as scrap metal, while an inverter can be hazardous because of lead solder. If an inverter is being replaced rather than the whole array, the inverter replacement guide covers the purchase; a home battery's removal belongs with its maker's instructions and a battery recycler, never the household bin.

Resale, a leased array, or an installer that has closed

Reuse sits above recycling in the state guidance read for this guide, but it has limits. EPA's frequent questions page says panels sent to resellers for legitimate reuse or repair are not solid waste, and Washington's guidance notes that most panels are guaranteed to produce 80 percent of their rated output after 25 years. EPA's recycling page is candid that the secondary market has not gained traction in the United States, and that grid interconnection rules and fire, building and electrical codes complicate reconnecting used panels; it suggests off-grid uses such as charging stations. If you are swapping working panels for higher-wattage ones, the guide to expanding an existing system covers how the utility treats the change, and selling the old panels to a buyer who will reuse them keeps them out of the waste rules entirely.

A leased array is the lessor's property, so its removal and disposal follow the lease, not your preferences. Read the end-of-term and removal clauses; if you are selling the house, the guide to selling a house with leased solar sets out the transfer and buyout routes. Remember Washington's line that utility-leased panels are business waste: the household shortcut is not yours to use on equipment you do not own.

If the installer has gone out of business, the takeback promise in its contract may have gone with it, but the panel maker's warranty and any manufacturer programme usually survive. The guide to an installer that has closed explains how to reach the maker and find a new servicer, and the same serial-number photographs you took in step two of the procedure are what the maker will ask for.

Dates to watch through 2028

Four pending items could change this page, and each has a public marker to check. EPA's proposal was due in August 2026 under the 2026 Unified Agenda and had not appeared by October 30, 2026; when it does, it will open a comment period and show the proposed handling rules for panels. Washington's Ecology says that, subject to funding, it expects an advisory committee to begin work in November 2027, a consultant report by June 1, 2028, and Ecology's own recommendations to the legislature by December 1, 2028, ahead of the January 31, 2031 plan deadline. New Jersey's commission recommendations and New York's draft definitions need adoption before they bind anyone.

Until then, the working rule for a homeowner is the one the agencies already agree on: reuse first, recycle through a receiver you have confirmed, keep the household exemption by having panels go straight from your roof to that receiver, and keep the receipt. The panels themselves are rarely the urgent part of a solar system's later years; the maintenance routine that keeps them producing is where most owners spend their attention, and disposal arrives once, at the end.