The solar industry is the backbone of the energy transition. However, from a regulatory standpoint, manufacturers and importers of photovoltaic modules operate in one of the most complex areas of environmental law. Legally speaking, PV modules are not simply components, but electrical appliances classified under category 6.
Here are the key aspects of the current legal landscape, as well as the critical changes you need to keep in mind for 2026.
1. Dual-use classification
In Germany, PV modules are almost without exception classified as B2C devices.
- Why? Since panels can potentially be used in both solar farms and on private residential roofs, they are considered “waste electrical and electronic equipment from private households” regardless of their actual location of use.
- The consequence: You are required to deposit an insolvency-proof guarantee with the ear Foundation. Without this financial security, registration and thus legal sale is impossible.
2. The 72-hour pickup period
As soon as the minimum quantity of 2.5 m³ of end-of-life modules (collection group 6) is reached at a municipal recycling center, the ear Foundation triggers an automated pickup order.
- The time pressure: Manufacturers must ensure that the pickup and delivery of a new empty container are coordinated within 72 hours (on business days).
- Risk of liability: As the volume of PV scrap is rising sharply due to the repowering of old systems, the frequency of these orders will increase significantly in 2026. Delays not only result in fines but also directly jeopardize your registration.
3. The new symbol for the return of old devices
The ElektroG4 amendment will make the return of end-of-life equipment more visible to consumers. This affects PV manufacturers and retailers, particularly in their interactions with customers:
- Appearance & Requirements: The previous black-and-white symbol will be replaced by a new, colored logo.
- Stationary retail: Retail locations (e.g., specialty stores for solar technology) must display this symbol prominently in the entrance area (at least A4 size) starting July 1, 2026.
- Online retail: The change is significant for web shops: In the future, the new symbol must be integrated directly on the product pages for PV modules or, at the latest, “easily found” during the ordering process. A mere note in the footer, in the legal notice, or buried deep in the terms and conditions is no longer legally sufficient.
New symbol for the return of old devices
4. The ZEREZ Requirement
One of the most significant changes for the marketing of PV components is the integration of environmental law and energy law:
- Market access barrier: Starting in 2025, PV modules must be registered in the ZEREZ (Central Register).
- Consequences for customers: Without a valid ZEREZ ID from the manufacturer, grid operators are increasingly refusing to commission and connect new systems to the grid.
5. The counter model
As of January 1, 2026, the counter service model applies at collection points:
- PV modules may only be accepted at recycling centers by trained staff.
- Objective: To prevent non-compliant items (such as large household appliances or loose batteries) from ending up in collection group 6.
ECOPV-EU: Your Specialized PV Compliance Partner
As the market becomes more complex, we simplify the processes for you:
- ✅ Express pickup coordination: We guarantee compliance with the statutory 72-hour deadline through our specialized logistics network.
- ✅ Guarantee management: We provide the required insolvency-proof guarantees for your PV registration.
- ✅ Reporting & BDO: We handle precise volume reporting and ensure correct declarations—even for complex cross-border transactions (e.g., BDO reports in Poland).
- ✅ WEEE expert advice: We are already implementing the latest EU requirements for you today.
Contact us for comprehensive advice on your compliance issues relating to electrical and electronic equipment, packaging, batteries, and PV panels.
www.ecopv-eu.com/en/contact/ | 
E-Mail: info@ecopv-eu.com
Supported over 20,000 customers with EPR compliance
Rated 5.0 on Google
Contact
We look forward to your message!
