Used PV Modules: When is a Solar Module Second-Hand Goods – and When is it Waste?

After a repowering or the dismantling of a photovoltaic system, a crucial question often arises:

What happens to the decommissioned solar modules?

If the modules are still technically usable, they may be reused and sold. If, however, they are waste, different requirements apply to transport, recovery, and especially to transboundary shipments. An important principle applies:

A decommissioned solar module is not automatically waste. Its condition, functionality, intended further use, and – especially in the case of shipment – the corresponding documentation are crucial.

Especially for larger dismantling and repowering projects, it is therefore worthwhile to check which modules are still suitable for reuse before a blanket disposal.

Used or Waste: Why This Distinction is So Important

For example, a solar park is repowered. The existing modules are replaced by modern modules with significantly higher performance. Initially, this only means that the previous modules are no longer needed for this particular system. It does not automatically follow that all decommissioned modules are technically unusable.

Some may still be functional and suitable for direct reuse. Other modules may have damage or technical faults. Still others may be so severely damaged that further use is no longer sensible, and recovery or recycling becomes the priority. Especially during repowering, large quantities of used modules can therefore arise that were decommissioned not due to a defect, but for economic or technical reasons.

“Decommissioned” and “defective” are two different things.

SecondSol already discusses the economic and technical possibilities of such inventories in more detail in the articles on Repowering of Solar Parks and Reuse of Used Photovoltaic Modules. However, operators also face the legally relevant question:

When is it actually second-hand goods – and when is it waste?

When Can a Decommissioned PV Module Be Second-Hand Goods?

The German Electrical and Electronic Equipment Act (ElektroG) contains specific requirements for the shipment of used electrical and electronic equipment. § 23 ElektroG stipulates that used electrical and electronic equipment, which may be waste equipment, may only be shipped into, out of, or through the scope of the Act in accordance with Annex 6 ElektroG. Annex 6, in turn, describes what documentation is required to distinguish between used and waste equipment. Two points, in particular, are of central importance:

The equipment must be intended for direct reuse and be fully functional.

Applied to photovoltaic modules, this means:

A module does not become second-hand goods simply because it is decommissioned, placed on a pallet, and then offered for sale. The actual situation must match the intended reuse and be verifiable accordingly.

The Reason for Decommissioning Can Make a Big Difference

Solar modules can be removed from a system for a variety of reasons.

Typical examples include:

• Repowering of a solar park,
• complete dismantling of a PV system,
• modernization of individual system components,
• replacement after an insurance claim or damage event,
• conversion or expansion of a system.

Especially during repowering, modules are often not decommissioned because they have reached their technical lifespan. For example, the operator may decide to replace older modules with significantly more powerful products to install more capacity on the same area. The existing modules may still be technically functional at this point. This is precisely where the potential for reuse instead of recycling arises.

When Does a Solar Module Become Waste?

The question cannot be answered solely based on the age or external appearance of a module.

In European waste law, it is fundamentally important whether the owner of an item disposes of it, intends to dispose of it, or must dispose of it. For the shipment of used electrical and electronic equipment, where waste equipment may be present, the distinction is further specified by § 23 and Annex 6 ElektroG. § 23 Paragraph 4 ElektroG is particularly relevant.

According to this, it is rebuttably presumed to be waste equipment and an illegal shipment if, among other things,

• the required documents to prove the used equipment status are missing,
• the documents are insufficient for a corresponding assessment, or
• there is no adequate protection against damage during transport and during loading and unloading.

For operators, dealers, and project developers, this means:

The mere designation "used solar modules" on an invoice, pallet, or freight document is not sufficient.

The actual condition and intended use, as well as the necessary documentation, are crucial.

What Documentation is Important for Used PV Modules?

Annex 6 ElektroG defines minimum requirements for the shipment of used electrical and electronic equipment where there may be a suspicion that it is waste equipment. The following points are particularly relevant for PV modules.

1. Direct Reuse Must Be Intended

To prove this, a copy of the invoice and the contract for the purchase or transfer of ownership must be kept available, among other things. This must show that the devices are intended for direct reuse and are fully functional. This gives the actual marketing and usage perspective particular importance. It makes a difference whether an inventory of functional modules is specifically sold for further use or whether a large quantity of uninspected and possibly defective modules is merely to be transported under the designation "used."

2. Functionality Must Be Tested

Another important component is proof of functionality. Annex 6 ElektroG describes a testing and documentation procedure for this. For most electrical and electronic equipment, testing of the main functions is required. The testing and assessment must be carried out by a qualified electrician or a certified initial treatment facility.

A clear distinction is important here:

The ElektroG does not generally stipulate that every used PV module must undergo a flash test or an electroluminescence inspection.

However, depending on the origin, condition, type of damage, quantity, and planned further use, such more extensive tests may be technically and economically sensible.

3. The Test Must Be Documented

A test alone is not enough.

The results must be documented. Annex 6 lists, among other things, information such as:

• designation of the device,
• identification or type number, if available,
• year of manufacture, if known,
• name and address of the company responsible for the functional verification,
• result and date of the functional test, and
• type of test performed.

For large repowering projects with several thousand or even tens of thousands of modules, it should therefore be considered before the start of dismantling how testing, sorting, and documentation will be organized.

What Tests Are Useful for Used Solar Modules?

The minimum legal requirements and a technically or economically sensible assessment of a used PV module are not necessarily identical. For example, a structured visual inspection can be the starting point. The following abnormalities, among others, can be detected:

• Glass breakage,
• Damaged or deformed module frames,
• Damaged module backsheets,
• Delamination,
• Corrosion,
• Damaged junction boxes,
• Damaged cables,
• Damaged or scorched connectors,
• Visible cell damage,
• Moisture traces, or
• Other mechanical or electrical abnormalities.

Depending on the project and the specific question, further testing procedures may then be useful.

Power Measurement or Flash Test

A power measurement can determine what electrical power a module still achieves under defined conditions. Especially for older module inventories, this can be an important basis for residual value and reuse assessment.

Electroluminescence Inspection

Using electroluminescence – or EL for short – damage that is difficult or impossible to detect with a normal visual inspection can be made visible. This includes, for example, cell and micro-cracks. Such additional tests can help to classify modules into different quality classes, especially for larger repowering inventories or after damage events. The following still applies:

Not every technically useful test is automatically legally required.

The specific testing strategy should therefore be based on the respective inventory, the intended reuse, and the legal requirements.

Packaging Can Also Be Relevant for the Distinction

One point is easily underestimated in practice: How are the modules packaged and transported?

Anyone claiming that functional used modules are being transported for further use must treat them accordingly. Annex 6 ElektroG requires adequate protection against damage during transport and during loading and unloading, in particular through sufficient packaging and suitable stacking. § 23 ElektroG also explicitly addresses this point. A lack of adequate transport protection can lead to a rebuttable presumption that it is waste equipment and an illegal shipment. This is also practically understandable:

Modules that are actually intended for a second use should be dismantled, packaged, and transported in such a way that they are not damaged on their way to their next deployment.

Therefore, the planned reuse should already influence the dismantling process.

What Applies to the Export of Used Solar Modules?

At the latest, when it comes to transboundary shipments, the distinction between second-hand goods and waste becomes particularly important. § 23 ElektroG concerns such shipments into, out of, and through the scope of the Act. The requirements from Annex 6 serve to distinguish between used electrical and electronic equipment and waste equipment.

In parallel, European waste shipment law must be observed. The Regulation (EU) 2024/1157 on the shipment of waste forms the new European legal framework for this. For a specific international project, it should therefore be checked early on:

• Is it actually second-hand goods or waste?
• Where are the modules to be shipped?
• Is direct reuse intended?
• What documentation is available regarding functionality and intended use?
• What documentation obligations exist?
• How must the modules be packaged?
• What additional regulations apply to the specific shipment and, if applicable, in the destination country?

Especially for larger international repowering projects, this check should not take place only when the first truck is loaded. It belongs in the planning of the dismantling.

Reuse or Recycling? The Decision Should Begin Before Dismantling

With several thousand modules, it is inefficient to first dismantle the entire system and only then decide what should happen to the modules. A planned process is more sensible:

Record inventory → assess reuse potential → professionally dismantle → sort modules → carry out necessary tests → document results → market reusable modules → send non-reusable modules for recycling.

This can result in different groups.

Reuse: Modules are functional and suitable for further use.

Further testing: The condition is not clear or additional technical information is needed for marketing.

Recycling: Meaningful reuse is no longer an option due to the condition or other prerequisites.

SecondSol also addresses this interplay of dismantling, reuse, and recovery in the article Planning PV Repowering Correctly: From Dismantling to Marketing.

Selling Used Solar Modules from Dismantling and Repowering

Anyone dismantling or repowering a photovoltaic system should therefore not prematurely classify existing modules as worthless or generally send them for recycling. Functional modules can still have a residual value. SecondSol purchases used solar modules from dismantling and repowering projects. Both smaller inventories and large project quantities can be offered. Depending on the inventory, the modules can be evaluated and, if necessary, technically tested. This allows to determine, even before or during dismantling, whether and to what extent further marketing is an option.

Selling Solar Modules from Dismantling or Repowering?

SecondSol evaluates used PV modules and purchases suitable inventories from dismantling and repowering projects.

Offer Used Solar Modules to SecondSol

Checklist: Used Module, Further Testing, or Recycling?

Conclusion: Dismantling Does Not Automatically Mean Recycling

A decommissioned solar module is not automatically waste.

If functional modules are merely replaced by more powerful technology, for example as part of a repowering, further use may be technically and economically possible. At the same time, especially during shipment, it is not sufficient to simply declare a decommissioned module inventory as "used goods."

Intention for reuse, functionality, inspection, documentation, and suitable transport must all align.

Therefore, the question "Reuse or Recycling?" should ideally be answered before dismantling.

This way, reusable modules can be specifically identified, tested, and marketed, while modules that are truly no longer usable are sent to an appropriate recycling process.

Further information on recycling can be found in the SecondSol article Recycling and Disposal of Photovoltaic Modules.

Frequently Asked Questions About Used PV Modules

Are Decommissioned Solar Modules Automatically E-Waste?

No. The mere decommissioning of a PV module does not automatically make it waste. Its condition, functionality, and intended further use play a role in its specific classification. For the shipment of used electrical and electronic equipment, which may be waste equipment, § 23 and Annex 6 ElektroG are particularly relevant.

Can Solar Modules from a Repowering Still Be Sold?

Generally, yes. Especially during repowering, functional modules are often decommissioned not due to a defect, but because the existing system is being modernized or equipped with more powerful components. Therefore, reuse and marketing may be an option for suitable modules. SecondSol purchases such module inventories from dismantling and repowering projects.

Do Used PV Modules Have to Be Inspected Before Shipment?

For the shipment of used electrical and electronic equipment, which may be waste equipment, Annex 6 ElektroG requires proof of functionality and corresponding records. The inspection and assessment described therein must be carried out by a qualified electrician or a certified initial treatment facility.

Is a Flash Test Required for Every Used Solar Module?

No. The ElektroG does not generally stipulate a flash test for every used photovoltaic module. However, a power measurement can be useful depending on the project to better assess the actual performance and thus the further usability or residual value of a module.

Is an Electroluminescence Inspection Required for Used Modules?

An EL inspection is also not generally legally required for every used PV module. However, it can be useful for technical condition assessment, for example, to make cell and micro-cracks visible that are not reliably detectable from the outside.

Can Used Solar Modules Be Sold Abroad?

Functional used modules can generally be traded across borders. However, a clear distinction between second-hand goods and waste is crucial. For a specific shipment, the applicable documentation, transport, and, if necessary, waste law requirements must be checked. For used electrical and electronic equipment, where waste equipment may be present, Annex 6 ElektroG in particular contains corresponding provisions.