Australia’s first wave of utility scale solar farms will reach end-of-life within the next decade, creating significant decommissioning and recycling opportunities. As the need for decommissioning renewable projects increase, so does the regulatory scrutiny on end-of-life management. Additionally, whilst historically managed under voluntary schemes and private investment, these are likely to be insufficient to support recycling infrastructure development on their own. Recently, Sircel, one of Australia’s largest solar panel recycling companies, entered voluntary administration, indicating the need for greater mandated stewardship obligations.
At the Energy and Climate Change Ministerial Council meeting held earlier this year, NSW advocated for a national solar panel reuse and recycling scheme, signalling future regulatory direction. Stakeholders in solar projects, including developers, logistics companies, asset managers, must understand emerging stewardship obligations to position themselves advantageously as regulations evolve.
Evolving regulatory landscape
Proper handling and disposal of solar panels is becoming mandatory across states, with regulatory requirements trending towards comprehensive stewardship obligations:
NSW: The Product Lifecycle Responsibility Act 2025 (NSW) (Act) was assented to on 9 April 2025 but is not yet in force.[1] The Act establishes a framework under which certain products will be subject to mandatory product stewardship schemes to support efficient, responsible and sustainable resource management. It places obligations on brand owners of regulated products to take responsibility across the product lifecycle, including the design, supply, use, reuse, collection, recovery/recycling and disposal of their products.
QLD: In August 2024, Queensland launched a Solar Panel Stewardship pilot program (recycling, reuse, recovery) in partnership with the Smart Energy Council.[2] The pilot program has A$5.5 million in funding drawn and is anticipated to save about 26 tonnes of waste from landfill.
WA: On 1 July 2024, Western Australia implemented the Waste Avoidance and Resource Recovery (e-waste) Regulations 2024, prohibiting the disposal of solar panels and other electrical waste (e-waste) to landfill.[3] The regulations facilitate the recovery of valuable materials and align with the Waste Avoidance and Resource Recovery Strategy 2030 to promote a more circular economy.
VIC: In March 2025, Solar Victoria updated its Notice to Market to include mandatory requirements for installers and retailers in the Solar Homes Programme to responsibly manage end-of-life solar PV systems.[4] Solar panels are now banned from landfill.[5] Installers and retailers must ensure panels are taken to lawful e-waste collection points or recyclers authorised by the Environment Protection Agency (EPA) Victoria. Specialist solar PV recyclers in Victoria can recover up to 90% of a solar panel for reuse. The handling, storage, and reprocessing of e-waste are regulated under the Environment Protection Regulations 2021. Non-compliance with these regulations is an indictable offence with substantial penalties.
What this means for stakeholders
Compliance risk: Understanding your role in decommissioning and any applicable regulations is critical. Improper product handling, storage or disposal could result in liability and penalties under state e-waste regulations, as well as affect entitlement to insurance coverage and premiums.
Reputational risk: Non-compliance or environmentally harmful practices can damage your reputation and affect business relationships. This could result in exclusion from future tenders or loss of existing partnerships with developers and investors increasingly focused on strong ESG credentials.
Development Approvals: Planning and development approvals are increasingly contingent on providing thorough end-of-life management plans. Projects without credible decommissioning strategies may face approval delays or refusals. If you would like to read more about the changing approval processes please see here.
In consideration of the above, proponents may take the following actions to manage their risks:
- (Portfolio and Contract Review) Regularly review existing solar farms and relevant agreements to identify when panels will reach end-of-life and to determine who bears responsibility for decommissioning and disposal. Clearly setting out and understanding each party’s obligations early on allows for better risk management and financial planning.
- (Strategy for Regulatory Compliance) Monitor regulatory changes that may affect your projects and develop and maintain a stewardship strategy aligned with the trajectory of incoming legislation and regulations. Demonstrating knowledge of evolving regulatory regimes, paired with capability to comply with such regimes, adds value to your service offering and positions you ahead of competitors as regulations continue to tighten.
- (Engagement with Recyclers) Identify and engage with EPA-authorised recyclers in your relevant project states to understand current capacity, costs and logistics requirements. Consider forming partnerships or offtake arrangements for recovered materials. Early investment in partnerships with reputable recyclers can prove invaluable for managing end-of-life risk as a contractor, developer or asset manager.
Proponents who invest early in developing compliant processes and strategic partnerships will differentiate themselves in tenders and stand out in an increasingly competitive market. Demonstrating proactive compliance and risk management, accountability and a commitment to facilitating circular economy principles can appeal to several stakeholders including investors, regulators, other project proponents and the local community.
Conclusion
As Australia moves toward a more circular renewable energy sector, proactive engagement with product stewardship obligations is critical for all project proponents. By embedding end-of-life considerations into project planning through to development, delivery and decommissioning, proponents not only safeguard compliance but also strengthen their commercial resilience and ESG credentials, allowing them to stand out in an increasingly regulated and sustainability-driven market. Those who take a forward-looking approach to stewardship and take steps for early preparation will be best placed to manage risk, capture value, and maintain investor confidence across the life cycle of their assets.
The Hamilton Locke team advises across the energy project life cycle – from project development, grid connection, financing, and construction, including the buying and selling of development and operating projects. For more information, please contact Matt Baumgurtel.
[1] Product Lifecycle Responsibility Act 2025 (NSW) s 3.
[2] Queensland Government, ‘Miles Labor Government delivering Australia’s leading solar panel recycling scheme’ (Media Statement, 29 August 2024) <https://statements.qld.gov.au/statements/101195>.
[3] Waste Avoidance and Resource Recovery (E-waste) Regulations 2024 (WA).
[4] Solar Victoria, Manage End-of-Life Solar PV (Web Page, 11 March 2025) <https://www.solar.vic.gov.au/manage-end-life-solar-pv>.
[5] Sustainability Victoria, National Approach to Manage Solar Panel, Inverter and Battery Lifecycles (Web Page, 5 August 2025) <https://www.sustainability.vic.gov.au/circular-economy/product-stewardship/national-approach-to-manage-solar-panel-inverter-and-battery-lifecycles>.
