Structural Mismatch: the EU WEEE Directive and Photovoltaic End-of-Life Management

Sammanfattning

Photovoltaic (PV) technology stands at the core of the EU’s energy transition, yet its rapid expansion points to an inevitable surge in future waste streams. Currently, decommissioned modules are managed under the Waste Electrical and Electronic Equipment (WEEE) Directive. This framework was originally tailored for short-lived consumer electronics, creating a profound structural mismatch with PV modules, which function as durable and high-value power generation equipment. Through a mixed-methods approach, this thesis integrates quantitative market data from France, Germany and Sweden with qualitative expert interviews to assess this mismatch. Three main misalignments are identified. Financially, the pay-as-you-go mechanism is not suitable for products with a 30-year lifespan, which risks funding deficits and the accumulation of orphan waste. Logistically, municipal collection networks are inadequate for heavy and fragile panels, leading to high costs and physical damage. Regarding value recovery, weight-based compliance targets incentivize downcycling and undermine reuse potential and the retrieval of valuable and strategic materials such as silver and high-purity silicon. Patching the existing framework is no longer sufficient to meet the challenges ahead. This thesis recommends separating PV modules from the WEEE framework and setting a dedicated legislation for this product group. By adopting measures including Digital Product Passports (DPPs), independent trust funds and material-specific recovery targets, the EU can drive PV End-of-Life (EoL) toward a closed-loop system of value retention.