// PRODUCT CATEGORY
Solar Panels Under ESPR
Solar panels (photovoltaic modules) are a priority product category under the Ecodesign for Sustainable Products Regulation (EU 2024/1781). The EU's solar energy ambitions — targeting 600 GW of installed solar capacity by 2030 — make the sustainability credentials of solar panels a critical policy priority. ESPR will require Digital Product Passports for solar panels, setting requirements for carbon footprint disclosure, recycled content, durability, and end-of-life management.
Truth Anchor: ESPR Recital 18 identifies solar panels as a priority product category. The Commission's preparatory study for solar panels (Lot 38 under the ErP framework) has been completed and provides the technical basis for the delegated act. Source: EUR-Lex CELEX:32024R1781
Why Solar Panels Are a Priority Under ESPR
Solar panels present a specific sustainability challenge: they are manufactured to generate clean energy, but their production has a significant environmental footprint. The production of crystalline silicon solar cells requires large amounts of energy, and the manufacturing process uses hazardous chemicals including hydrofluoric acid and nitrogen trifluoride. At end of life, solar panels contain valuable materials — silver, silicon, aluminium, glass — that are currently not efficiently recovered. ESPR addresses both the production footprint and the end-of-life management of solar panels.
The EU's dependence on Chinese solar panel manufacturing is also a policy concern. Approximately 95% of solar panels installed in the EU are manufactured in China. ESPR's carbon footprint and recycled content requirements are designed in part to create a level playing field for EU solar panel manufacturers, who face higher energy and labour costs but produce panels with lower carbon footprints due to the EU's cleaner electricity grid.
Expected ESPR Requirements for Solar Panels
Carbon footprint declaration: Solar panels will be required to declare their carbon footprint per watt-peak (Wp) of rated power output. The carbon footprint must be calculated using a standardised methodology (expected to be based on ISO 14067 and the Product Environmental Footprint methodology). The Commission may set maximum carbon footprint thresholds that panels must meet to be placed on the EU market. This requirement would effectively exclude the highest-carbon panels from the EU market.
Durability and performance: Solar panels will be required to meet minimum performance retention standards — for example, retaining at least 90% of their rated power output after 25 years of operation. Manufacturers must provide performance warranties that meet minimum standards. The DPP must include the manufacturer's performance warranty terms.
Recycled content: The delegated act is expected to set minimum recycled content requirements for aluminium frames and glass. Recycled aluminium and recycled glass are already commercially available and used in some solar panel manufacturing. The DPP must disclose recycled content percentages.
End-of-life management: Solar panels are currently covered by the WEEE Directive, which requires manufacturers to take back and recycle end-of-life panels. ESPR will strengthen end-of-life requirements by requiring DPP data that enables efficient material recovery — specifically, data on silver content, silicon purity, and encapsulant type that recyclers need to optimise recovery processes.
Hazardous substances: The DPP must disclose hazardous substances used in solar panel manufacturing, including substances used in thin-film panels (cadmium telluride, copper indium gallium selenide). This data is required for safe end-of-life management.
Digital Product Passport for Solar Panels
| Data Category | Required Data Fields | Relevance |
|---|---|---|
| Product identification | Model, rated power (Wp), cell technology (mono-Si, poly-Si, thin-film), dimensions, weight | Installation and recycling |
| Carbon footprint | CO2e per Wp (production), CO2e per kWh (lifecycle), manufacturing country | Procurement decisions, EU market access |
| Performance | Power tolerance (%), temperature coefficient, degradation rate (%/year), performance warranty terms | Energy yield calculations |
| Recycled content | Recycled aluminium % (frame), recycled glass % (cover), total weight breakdown | Circular economy compliance |
| Materials | Silver content (g/panel), silicon purity, encapsulant type, backsheet material | End-of-life material recovery |
| Hazardous substances | Cadmium content (thin-film only), lead content, other substances of concern | WEEE compliance, safe disposal |
| End-of-life | Take-back scheme details, recycling instructions, material recovery rates | WEEE compliance |
Impact on Non-EU Solar Panel Manufacturers
Chinese solar panel manufacturers — who supply approximately 95% of the EU market — will face significant compliance requirements under ESPR. Carbon footprint declaration requirements will require Chinese manufacturers to calculate and disclose the carbon footprint of their panels, which is typically higher than EU-manufactured panels due to China's coal-heavy electricity grid. If the Commission sets maximum carbon footprint thresholds, some Chinese manufacturers may be unable to meet them without significant changes to their manufacturing processes or energy sourcing.
Chinese manufacturers placing solar panels on the EU market must appoint an EU-based Authorised Representative who is legally responsible for ESPR compliance. The Authorised Representative must maintain technical documentation and ensure that the DPP is accurate and accessible throughout the product's market lifetime.
What Solar Panel Manufacturers Must Do Now
Solar panel manufacturers should begin carbon footprint calculation immediately. The carbon footprint of a solar panel depends primarily on the electricity used in manufacturing — manufacturers using renewable energy will have significantly lower carbon footprints. Manufacturers should also begin collecting recycled content data from their aluminium frame and glass suppliers, and review their end-of-life take-back scheme documentation for inclusion in the DPP.
Solar Panel Manufacturing and the EU Net-Zero Industry Act
The EU Net-Zero Industry Act (NZIA, EU 2024/1735) identifies solar photovoltaic technology as a strategic net-zero technology and sets a target for the EU to manufacture at least 40% of its annual deployment needs domestically by 2030. This industrial policy objective directly intersects with the ESPR delegated act for solar panels — the ESPR requirements will apply to all solar panels placed on the EU market regardless of origin, while the NZIA provides incentives for EU-manufactured panels. The ESPR solar panel DPP will serve as the technical vehicle for demonstrating compliance with both ESPR ecodesign requirements and any NZIA sustainability criteria that may be introduced for public procurement.
Solar Panel Degradation and Lifetime Performance Data
Solar panels degrade over time — the power output of a crystalline silicon panel typically declines at 0.5–0.7% per year under normal operating conditions. The ESPR delegated act for solar panels is expected to require manufacturers to declare the annual degradation rate in the DPP, the minimum power output guarantee at year 10 and year 25, and the testing methodology used to determine degradation rate (IEC 61215 for crystalline silicon, IEC 61646 for thin-film). This data is critical for investors and project developers calculating the financial returns of solar installations — a panel with a lower degradation rate generates more energy over its lifetime and has a higher net present value. Manufacturers that can demonstrate lower-than-average degradation rates will have a competitive advantage in the EU market.
End-of-Life Solar Panel Recycling and ESPR
Solar panels contain hazardous materials — including lead in solder joints, cadmium in CdTe thin-film panels, and selenium in CIGS panels — that require controlled end-of-life management. The EU Waste Electrical and Electronic Equipment Directive (WEEE Directive, EU 2012/19/EU) already classifies solar panels as WEEE category 4 (large equipment) and requires producers to finance the collection and recycling of end-of-life panels. The ESPR delegated act for solar panels will extend these requirements by introducing minimum recycled content targets for new panels (using recycled silicon, glass, and aluminium from end-of-life panels), minimum recyclability rates, and DPP data requirements for end-of-life processing. The EU is investing in solar panel recycling infrastructure through the NZIA and Horizon Europe programmes to build the capacity needed to process the large volumes of end-of-life panels expected from 2030 onwards.
| Solar Panel Technology | Typical Efficiency (%) | Annual Degradation Rate | ESPR DPP Expected |
|---|---|---|---|
| Monocrystalline silicon (PERC) | 20–23% | 0.5–0.6%/year | 2026–2027 |
| Monocrystalline silicon (TOPCon) | 22–24% | 0.4–0.5%/year | 2026–2027 |
| Polycrystalline silicon | 17–20% | 0.6–0.7%/year | 2026–2027 |
| CdTe thin-film | 18–22% | 0.4–0.5%/year | 2026–2027 |
| Bifacial modules | 21–24% (front) + 10–20% rear gain | 0.4–0.5%/year | 2026–2027 |
Frequently Asked Questions
The ESPR delegated act for solar panels is expected in 2025–2026, with mandatory compliance likely from 2027–2028 following a transition period.
The Commission is considering maximum carbon footprint thresholds per watt-peak. If adopted, this would effectively exclude the highest-carbon panels from the EU market. The decision will be made in the delegated act.
Yes. Any solar panel placed on the EU market must comply with ESPR regardless of where it is manufactured. Chinese manufacturers must appoint an EU-based Authorised Representative.
The DPP must disclose the silver content per panel in grams. This data is required for end-of-life material recovery — silver is the most valuable recoverable material in crystalline silicon panels.
Yes. Solar panels are covered by the WEEE Directive (2012/19/EU), which requires manufacturer take-back and recycling. ESPR will strengthen end-of-life requirements by requiring DPP data that enables efficient material recovery.
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ESPR Requirements for Solar Panel Manufacturers
Solar photovoltaic (PV) panels are one of the priority product categories under the ESPR Working Plan, reflecting the EU's commitment to scaling up solar energy deployment while ensuring that solar panels are manufactured sustainably and can be recycled at end-of-life. The ESPR delegated act for solar panels is expected to address: the carbon footprint of solar panel manufacturing (which is dominated by the energy-intensive production of silicon); the use of hazardous substances (particularly lead in solder and cadmium in thin-film panels); the recyclability of solar panels at end-of-life; and the DPP data requirements for solar panels.
Solar panels have a typical lifespan of 25–30 years, which means that the first large wave of solar panels installed in Europe in the early 2000s is now approaching end-of-life. The EU is developing a framework for solar panel recycling under the WEEE Directive and ESPR to ensure that the materials in end-of-life solar panels (silicon, silver, copper, aluminium, glass) are recovered and recycled rather than landfilled. The DPP for solar panels will play a key role in this framework by providing recyclers with the information they need to process panels efficiently.
DPP Data Requirements for Solar Panels
The DPP for solar panels is expected to include: the panel's power output (Wp), efficiency (%), and temperature coefficient; the panel's carbon footprint per Wp of rated capacity; the percentage of recycled content in key materials (silicon, silver, aluminium, glass); information on substances of concern (lead, cadmium, selenium); the panel's expected lifespan and degradation rate; the manufacturer's warranty terms; and instructions for safe handling and recycling at end-of-life. For bifacial panels, the DPP should also include the bifaciality factor and the expected energy yield under different installation conditions.
The carbon footprint of solar panel manufacturing varies significantly depending on the manufacturing location and the energy mix used in production. Panels manufactured in China using coal-powered electricity have a significantly higher carbon footprint than panels manufactured in Europe or the United States using renewable energy. The ESPR DPP will make this carbon footprint data publicly available, enabling buyers (utilities, developers, installers) to compare the carbon footprint of panels from different manufacturers and make procurement decisions based on this data. This is expected to create a competitive advantage for manufacturers who can demonstrate a low carbon footprint.
Frequently Asked Questions
The ESPR delegated act for solar panels is expected to be adopted in 2025–2026, with a compliance date approximately 18–24 months after adoption. Given the strategic importance of solar energy to the EU's Green Deal, the Commission may prioritise this delegated act. Manufacturers should plan for compliance by 2027–2028.
No. ESPR applies to products placed on the EU market after the compliance date. Solar panels already installed before the compliance date do not need a DPP. However, panels manufactured before the compliance date but placed on the EU market (sold) after the compliance date must comply with the requirements.
The EU Solar Energy Strategy (published in May 2022) aims to deploy 600 GW of solar capacity by 2030. ESPR complements this strategy by ensuring that the solar panels deployed are manufactured sustainably. The Commission is also developing a European Solar PV Industry Alliance to support domestic manufacturing of solar panels that meet ESPR requirements.
The specific recycled content requirements for solar panels have not yet been confirmed. The preparatory study will assess the feasibility of recycled content requirements for silicon, silver, aluminium, and glass. Given the early stage of the solar panel recycling industry, the initial requirements are likely to be modest, with more stringent requirements phased in over time.
Yes. The DPP data carrier must be affixed to the solar panel in a durable location that remains accessible throughout the panel's 25–30 year lifespan. The QR code must be resistant to UV radiation, temperature extremes, and moisture. Laser engraving or a UV-resistant label are the most appropriate methods for solar panels.