How to Assess Solar Module Recycling and Circularity in China: the 2023 Responsibility Rule (Centralised Wind and PV Generators Bear Retired-Equipment Disposal; No Unauthorised, Unlawful Disposal by Landfill or Dumping), the 2026 Six-Department Opinion (250,000 t Cumulative Utilisation by 2027, Scrapping-Evaluation Standard, Low-Temperature Pyrolysis Below 200 °C, Weak-Acid Silver Leaching), GB/T 45922-2025 and GB/T 39753-2021, MEE's Pollution-Control Specification in Drafting, and the IRENA/IEA-PVPS Volume and Recovery Evidence

Short answer. China's PV end-of-life framework is young but no longer empty. Responsibility was fixed in 2023: centralised wind and PV generators must bear disposal of retired equipment including parts by law, may not unlawfully landfill or dump it on their own initiative, and may not put industrial solid waste into household waste collection facilities; module makers are supported in building distributed-PV take-back through self-, joint or delegated recovery and encouraged to offer recovery services; the targets were a basic responsibility mechanism by 2025 and a mature full-process recycling system by 2030. The State Council General Office repeated the responsibility mechanism in its 2024 waste-recycling opinion and asked for the e-waste catalogue to be reviewed. In February 2026 MIIT and five other departments issued a PV-module-specific opinion: by 2027, breakthroughs in surface dismantling, laminate separation and component extraction, a batch of standards and backbone enterprises, and 250,000 tonnes cumulatively utilised; by 2030 a capability able to cope with the retirement wave. It writes design-for-recycling into manufacturing (easily dismantled adhesives, non-cross-linked films, fluorine-free backsheets, lead-free ribbons and pastes), calls for a scrapping-evaluation standard supported by drone EL and thermal imaging, and makes owners verify any contractor they delegate disposal to. Two national standards exist — GB/T 45922-2025 on scrapping (effective 1 January 2026) and GB/T 39753-2021 on recycling — and MEE is drafting a pollution-control specification for the whole chain from dismantling to disposal. The scale is set by the international projections: 1.7–8 million tonnes of global panel waste by 2030 and 60–78 million by 2050, with China's share put at 13.5–19.9 million tonnes by 2050. This guide reads the policy texts, the standard records and two international reports; it quotes no Chinese retirement statistic, recycler capacity or recovered-material price.

1. Responsibility: the 2023 and 2024 texts

CNWattHub reading: for a plant buyer, the 2023 rule means decommissioning is the owner's liability and should sit in the financial model as a cost line, not as a salvage credit, until a recycler's quote says otherwise; for a module buyer, the texts support and encourage maker take-back for distributed PV rather than mandate it, so a supplier's take-back offer is worth asking for and writing into the contract, because the policy does not yet guarantee it.

2. The 2026 opinion: what changes

• Targets. By 2027: key technologies for surface-structure dismantling, laminate separation and component extraction; a batch of green-design and utilisation standards; backbone enterprises; 250,000 tonnes of modules comprehensively utilised cumulatively. By 2030: a chain able to cope with large-scale retirement.
• Design for recycling. Makers are encouraged to use easily dismantled and separated adhesives, explore non-cross-linked encapsulant films, and choose fluorine-free backsheets, lead-free ribbons and lead-free pastes to cut future dismantling and disposal cost.
• Scrapping decisions. A scrapping-evaluation standard is to be drawn up; drone EL imaging, thermal imaging and AI monitoring are encouraged to identify structural integrity, safety and power degradation as reference for maintenance and scrapping decisions.
• Contractor verification. Makers, plants and EPC contractors that delegate transport, utilisation or disposal must verify the contractor's qualification and technical capability and agree pollution-control requirements.
• Process routes (annex). Physical glass removal by low-cost winding, hot-knife, stripping, cutting and pulse crushing; solvent chemistry with microwave- and ultrasound-assisted de-bonding and solvent recycling; pyrolysis with encouragement for low-temperature processes below 200 °C and flue-dust treatment; combined routes; and new separation processes for double-glass, thin-film and perovskite modules. Silver recovery with non-acid or weak-acid leaching and acid recycling is encouraged.
• Industry norms. Norm conditions for the comprehensive-utilisation industry are to be drafted, with regulated management and a published list of compliant enterprises when the time is right.
• Logistics. Mobile, modular quick-dismantling equipment and an 'arrive-and-dismantle' model for varied terrain; utilisation capacity laid out around the plant clusters of the Northwest, East China and North China, with near-site utilisation to cut transport cost.

MIIT's published expert reading calls the opinion a closed-loop system covering green design, orderly retirement, efficient dismantling and whole-chain coordination, and names the present bottlenecks as low dismantling efficiency, immature separation technology and insufficient chain coordination.

CNWattHub reading: the 250,000-tonne figure is a cumulative national utilisation target through 2027, not a forecast of retirements or a measure of the market, and should not be used as either. The annex is a research agenda rather than a list of approved processes — a plant that claims a "compliant" process today should be asked which standard it complies with, because the opinion calls for further standards — a batch of green-design and utilisation standards and a scrapping-evaluation standard — still to be drawn up, alongside the two existing GB/T standards listed below.

3. Standards and pollution control

CNWattHub reading: the two GB/T standards are the documents a recycler or an EPC contract should cite today; their texts were not read for this guide, so what they require of a scrapping decision or a recycling process is not described here. The pollution-control specification, once issued, will set whole-chain pollution-control requirements for waste PV equipment; in the meantime the sources point to routine environmental supervision, the 2024 enforcement precedent and the 2026 contractor-verification duty as the protections in place.

4. Scale and economics: the international evidence

• Volumes. IRENA and IEA-PVPS projected in 2016 cumulative global panel waste of 1.7–8 million tonnes by 2030 and 60–78 million tonnes by 2050 under regular-loss and early-loss scenarios; for China, 200,000 t to 1.5 million t by 2030 rising to 13.5–19.9 million t by 2050; China was then described as a leading market without PV-specific waste regulations.
• The EU model. The same report explains that the EU WEEE Directive requires all producers supplying PV panels to the EU market, wherever based, to finance collection and recycling of end-of-life panels, and that Germany and the UK built different frameworks when implementing it.
• Industry status, 2021 data. IEA PVPS Task 12 found China's recycling policies still under development; noting that no reliable world data exist, it said it seems a few thousand tonnes a year are processed in Germany, France, Italy and Japan; from a questionnaire with few responses it reported recyclers mostly using mechanical approaches with estimated recovery above 80% by weight, most plants below 1,000 t/year capacity and most treating under 100 t/year, and that crystalline-silicon cell materials and polymers seem not to be recycled while recovered glass goes to lower-value products.

CNWattHub reading: the 2016 China range (200,000 t to 1.5 million t by 2030) is a decade-old scenario made before the installation surge and should be read as a dated projection, not as a forecast or a bound; the 2021 survey's observation that most responding plants treat under 100 t/year while capacity sits below 1,000 t/year is the clearest statement in the sources of why unit costs are high — plants wait for volume. The 2026 opinion's call for mobile, modular 'arrive-and-dismantle' equipment and for capacity laid out near the plant clusters of the Northwest, East China and North China reads as a response to exactly that logistics problem, though the opinion does not cite the survey.

5. An assessment sequence built from the sources

1. Liability. Confirm who bears disposal (plant owner for centralised; for distributed, whether the maker offers the take-back the policy supports) and that the plan excludes unauthorised, unlawful disposal by landfill or dumping.
2. Contractor. Verify the recycler's qualification and technical capability and write pollution-control requirements into the contract.
3. Scrapping test. Ask which scrapping-evaluation method (GB/T 45922-2025; EL, thermal, monitoring) decides retirement versus repair or reuse.
4. Process. Identify the route (physical, solvent, pyrolysis, combined) and whether the plant's claims match the annex's directions, noting that the further standards the 2026 opinion calls for are still to be drawn up (the two existing GB/T standards are in §3).
5. Design. For new procurement, ask about adhesives, films, fluorine-free backsheets and lead-free materials.
6. Scale. Place the project's expected retirements against the 2027 national utilisation target and the international volume ranges.
7. Pollution control. Track MEE's specification and the 2024 enforcement precedent.

Scope limits

This guide reads the 2023 six-department opinion, the 2024 State Council General Office opinion, the 2026 MIIT-led opinion and MIIT's expert reading, the records of GB/T 45922-2025 and GB/T 39753-2021 (texts not read), MEE's July 2025 reply, the 2016 IRENA/IEA-PVPS report and the 2022 IEA PVPS Task 12 executive summary. The EU WEEE Directive text was not retrieved (EUR-Lex returned an empty response) and is described only through the IRENA report. No Chinese retirement-volume statistic, recycler capacity, recovered-material price or project case is quoted. Not legal, environmental-compliance or investment advice.