Within the European project RETRIEVE – Reintegration of PV panel waste back into manufacturing as high-value products, the Solar Energy Association of Ukraine has prepared a review of the Ukrainian regulatory framework applicable to end-of-life photovoltaic modules and the reuse of materials recovered through recycling.
The purpose of the study was to assess how the current Ukrainian legal framework supports the development of a circular model for the solar energy sector – from the classification and collection of PV waste to recycling and the reintegration of glass, metals, silicon and other recovered materials into manufacturing.
The review covers, in particular:
- the general waste-management framework and classification of end-of-life PV modules;
- permitting and licensing requirements for waste-management operations;
- digital waste accounting and traceability;
- transboundary waste shipments;
- end-of-waste rules and the re-entry of secondary materials into production;
- prospects for introducing extended producer responsibility for electrical and electronic equipment.
Particular attention was paid to the development of dedicated legislation on waste electrical and electronic equipment. Draft Law No. 2350 was registered in the Verkhovna Rada in 2019 and was subsequently included in the parliamentary agenda; however, as of January 2026, it had not been adopted.
The analysis shows that Ukraine has already developed a substantial part of the general legal infrastructure required for modern waste management. At the same time, a dedicated regulatory regime for waste electrical and electronic equipment – including a comprehensive framework for extended producer responsibility, collection, recycling and specific requirements relevant to PV modules – remains incomplete.
A further challenge is the creation of a complete legal pathway that would support not only the recycling of solar panels, but also the reintegration of recovered materials into manufacturing. This is particularly important for the high-value materials targeted by the RETRIEVE project.
The results of the review will be used as SEAU’s contribution to the RETRIEVE project in the areas of circular PV market development, analysis of regulatory barriers and preparation of recommendations for future policy on solar panel recycling.
Official RETRIEVE project website: https://www.retrieveproject.eu/