New Jersey Proposes Solar Panel Recycling Rules

State regulators want retired solar panels classified as universal waste and Class D recyclable material, while only one authorized site currently recycles them.

Updated on Nov. 4, 2026 in Energy

Isometric editorial illustration of a stacked pile of dark solar panels on a flat concrete yard beside a steel sorting cage and a low shed.
New Jersey regulators are proposing to classify retired solar panels as universal waste, while only one permitted facility in the state currently recycles them. AI Illustration. Upload story photo >

Live Poll

Do you support New Jersey requiring solar panel owners to fund recycling of retired panels?

New Jersey regulators are proposing to designate solar panels as universal waste and Class D recyclable material. Six sites in the state can accept retired panels, but only one, in Phillipsburg, actually recycles them.

Why it matters

The proposal follows the S3399 law signed January 12, which makes owners, producers, distributors, or manufacturers responsible for taking back and recycling or refurbishing solar equipment at end of life. Without permitted recyclers, collection sites operate under temporary authorizations while rules are pending.

Six New Jersey sites accept retired solar panels, but only one, Commercial Solar Panel Recycling in Phillipsburg, recycles them, with four other sites sending panels there. The six sites together processed 107 tons of retired panels in 2025, and the state has not yet issued a permit to any solar panel recycler.

The players

Phil Murphy

Former Governor of New Jersey who signed the S3399 law requiring solar equipment producers and owners to take back and recycle panels at end of life.

Commercial Solar Panel Recycling

Phillipsburg, New Jersey company that is the only authorized site in the state actually recycling solar panels.

The details

Four sites send collected panels to the Phillipsburg facility, while a sixth uses an out-of-state facility it owns. Class D facilities with good compliance records can accept non-hazardous panels through the agency's research, development, and demonstration framework, subject to toxicity testing.

Timeline

  1. 2024: Initial research, development, and demonstration authorizations were issued to collection sites.

  2. January 12: Then-Gov. Phil Murphy signed the S3399 law.

  3. 2025: Six sites processed 107 tons of retired solar panels.

Big Picture

The proposal turns the S3399 take-back mandate into a working regulatory framework, since the law requires end-of-life recycling but the state has not yet permitted any solar panel recycler. Until final rules take effect, New Jersey relies on temporary one-year Class D authorizations.

Solar panel owners in New Jersey may face new responsibilities to return retired panels for recycling once the S3399 requirements take effect. Until then, collection sites operate under temporary authorizations that may not reflect final recycling standards.

The takeaway

Solar panel owners should confirm where they can legally return retired panels in New Jersey, since only temporary authorizations currently cover collection sites.

Further reading

Explore more on Energy coverage for New Jersey's solar recycling rules.

Source note: This article includes information reported by The Cool Down.

Live Poll

Do you support New Jersey requiring solar panel owners to fund recycling of retired panels?