U.S. Solar Panel Recycling Faces Growing Scrutiny Over Landfilling, Offshoring and Disposal Practices
Sustainable Source Studios (S3), an independent sustainability research and strategy practice, has published a new white paper examining how retired solar panels are handled in the United States and raising questions about whether much of the industry’s reported “recycling” activity actually results in meaningful material recovery.
Titled “SOLAR RECYCLING REALITY — Millions of Old Panels Are Being Replaced. Where Does This Hazardous Waste Actually Go?”, the report provides a market survey of U.S. solar panel end-of-life practices. Its central argument is that the majority of material described as solar recycling does not represent true closed-loop recovery. Instead, the paper identifies three dominant pathways: landfilling, overseas processing and what it describes as “camouflaging,” in which disposal is presented or marketed as recycling.
The report was authored by Isaac Nichelson, a sustainability-industry veteran and founder of Sustainable Source Studios. According to S3, the analysis was developed using regulatory records, independent market assessments, peer-reviewed scientific research and public disclosures from recycling and processing companies.
The findings come as the U.S. solar industry continues to expand and an increasing number of photovoltaic modules approach the end of their useful lives. Solar panels can contain valuable materials such as aluminum, copper, silver and silicon, but they can also contain potentially hazardous substances, including lead and cadmium. How those materials are removed, processed and ultimately disposed of has therefore become an increasingly important environmental and supply-chain issue.
One of the paper’s major conclusions is that the United States lacks sufficient domestic infrastructure to complete the recycling process for certain materials recovered from solar panels. S3 points to the closure of the country’s last domestic primary lead smelter in 2013 and argues that no U.S. facility currently refines primary heavy metals recovered from solar panel residues at industrial scale.
The report also highlights the international nature of the current recycling chain. According to corporate disclosures cited by S3, Korea Zinc, through PedalPoint Holdings, operates four U.S. shredding facilities under evTerra Recycling. Metal-bearing concentrates generated from shredded American solar panels are then transported approximately 5,500 nautical miles to South Korea for smelting.
S3 argues that the economics and processing targets behind this model make U.S. solar waste an important source of feedstock. The paper notes that Korea Zinc has established a target of processing 120,000 tons of solar material annually by 2030 at its Onsan smelter. At the same time, the report cites projections indicating that South Korea is expected to generate only about 1,222 tons of solar waste in 2025. S3 concludes that the substantial difference between those figures creates a strong incentive to import solar waste from the United States and other markets.
The environmental implications of the overseas processing route are another major focus of the white paper. S3 cites peer-reviewed research concerning contamination around industrial facilities in South Korea. According to the studies referenced in the report, stream sediments near the Onsan industrial complex have recorded heavy-metal concentrations ranging from three to 1,302 times higher than levels measured in urban areas. Other research cited by the paper reports unusually high concentrations in road-deposited sediments and elevated blood-lead and urinary-cadmium levels among residents near the Seokpo smelter.
The white paper further argues that mechanical processing can create environmental risks of its own. Shredding and crushing solar modules can expose substances that were previously contained within the panel structure. Research cited by S3 found that crushed solar-panel material released lead at concentrations of 9.3 milligrams per liter in testing, compared with a 5 mg/L regulatory threshold. The report also cites research involving cadmium-telluride panels, which found that approximately 73% of their cadmium could be released within 30 days under simulated landfill conditions.
Regulatory oversight is also emerging as a significant issue. The paper points to an April 30, 2026 Notice of Violation issued by the Texas Commission on Environmental Quality concerning a major solar recycler’s Odessa facility. The notice, identified as TCEQ Complaint No. 455069, involved alleged failure to monitor stormwater discharges. S3 presents the case as evidence that environmental compliance risks can exist even within facilities operating under the broader label of solar recycling.
The report also identifies certification and downstream traceability as potential mechanisms for distinguishing legitimate recycling from disposal-oriented practices. According to S3’s review of the SERI R2 registry, only two North American facilities currently hold R2v3 Appendix G certification for solar panel recycling, with only one operating at industrial scale. Appendix G is designed to address the responsible management and recycling of photovoltaic modules.
Beginning in January 2027, the paper notes, Appendix G will become mandatory for every R2-certified solar recycler. S3 argues that this change could significantly increase transparency by requiring recyclers and their customers to pay greater attention to downstream material handling and chain-of-custody practices.
The issue extends beyond environmental protection, according to the report. S3 also identifies a potential economic-security concern surrounding valuable materials contained in solar modules. Silver, copper, aluminum and silicon are identified in the paper as U.S. federal critical minerals as of November 2025. Under export-oriented recycling models, the report argues, these materials can permanently leave U.S. jurisdiction. The paper specifically states that silicon is not recovered through the model it examines.
Nichelson emphasized that the report is not intended as an argument against solar power. Instead, he said the industry’s rapid growth makes responsible end-of-life management increasingly important.
“This is not an anti-solar argument — it is the opposite,” Nichelson said. He described solar energy as an efficient and increasingly important form of energy production, while arguing that the industry needs a more transparent and accountable end-of-life system.
He also pointed to the emergence of certified domestic recycling capacity as a positive development. According to Nichelson, traceable domestic recycling is now operating at industrial scale, while the upcoming R2 requirements could provide additional safeguards for downstream material management.
The report concludes with recommendations aimed at solar asset owners, procurement teams, investors, regulators and ESG-focused capital providers. Among its recommendations are requiring Appendix G certification in recycling contracts, obtaining shipment-level chain-of-custody documentation and closely examining recycling proposals whose prices appear unusually low.
S3 argues that a recycling bid priced at or below the cost of conventional landfill disposal should be treated as a potential warning sign requiring additional verification. The report encourages stakeholders to evaluate not simply whether a contractor accepts retired panels, but what happens to the materials after collection, where processing occurs and whether recovered commodities ultimately return to productive use.
As the U.S. solar fleet continues to mature, the volume of retired photovoltaic modules is expected to grow. The findings presented by Sustainable Source Studios therefore place greater emphasis on transparency, domestic processing capacity, environmental compliance and verifiable downstream recovery. For solar developers, asset owners and investors, the report suggests that the definition of “recycling” may need to extend beyond collection and shredding to encompass the complete journey of materials from retired panels through their final processing and reuse.
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