Golden Gate University Environmental Law Journal


Genevieve Coyle


This Comment provides a background on solar power and PV technology, identifies the toxic components of PV products, and explains how disposal of PV waste poses a threat to the environment. Part II also illustrates how poor management of electronic waste (e-waste) in the U.S. has resulted in environmental pollution - a preventable consequence that can be avoided for the PV industry.

Part III advocates a recycling and life-cycle-management approach to regulation because it provides a more sustainable future for the solar industry. Part IV discusses federal and state hazardous waste regulations and demonstrates how these laws are ineffective to regulate PV waste, primarily because they exclude most PV products from regulation and promote disposal over recycling. Part V discusses proposed regulations in California that would modify its hazardous waste program to allow alternative management options. It explains why California should proceed with its proposed regulations that foster reclamation and recycling of solar panels and aim to reduce the volume of hazardous waste entering landfills. Part VI describes how states should take the next step to prevent a future PV waste problem by enacting extended producer responsibility (EPR) laws that focus on the life cycle of PV products and encourages states to subsidize these regimes. That Part also describes the European approach to PV waste management, which is based on a voluntary EPR system and explains why mandatory EPR laws may be required for the U.S.