On 17 August 2023 the National Development and Reform Commission, together with the National Energy Administration, the Ministry of Industry and Information Technology, the Ministry of Ecology and Environment, the Ministry of Commerce and the State-owned Assets Supervision and Administration Commission, published the Guidance on Promoting the Recycling of Retired Wind and Solar Equipment (Fa Gai Huan Zi [2023] No. 1030). It is the first national guidance document in this field.
Its significance lies less in a recycling target than in treating equipment retirement as a matter requiring responsibility, qualifications and contracts to be arranged in advance, rather than as an end-of-life issue for power station operators.
Retirement and responsibility
The guidance sets a 2025 target: responsibility mechanisms for retired equipment at centralised wind farms and solar stations should be basically established, standards improved and key technologies advanced. By 2030 the recycling system should be more complete.
The core of the mechanism is to establish who is responsible and to what extent. Station owners, equipment manufacturers, recyclers and local governments carry different obligations in dismantling, transport, storage, recovery and disposal. A company cannot discharge its responsibility by saying that it handed the equipment to a recycler.
Green design and collection
The guidance covers green design, regulated collection, high-value recovery and harmless disposal, and encourages manufacturers to design for disassembly and recovery.
For manufacturers, product responsibility extends forward. The material composition, dismantling instructions and recycling markings for blades, towers, nacelles, modules and inverters all affect downstream disposal costs. For station owners, a retirement plan should be prepared during operation, not when equipment reaches the end of its life.
High-value recovery and harmless disposal
Wind blades and solar modules contain recoverable glass, silicon, silver, copper and aluminium, and may also contain materials requiring assessment under solid waste or hazardous waste rules. The guidance encourages high-value recovery, but on the premise that sorting, testing and destinations are lawful.
The intermediate steps are where problems most often arise: environmental assessment and discharge permits for dismantling sites, dust and spillage during transport, seepage and fire protection at storage sites, and the qualifications and records of recyclers. A missing link can turn recycling into unlawful disposal.
Three compliance points easily missed
First, the classification of solid and hazardous waste. Equipment names are not enough; composition testing and the relevant catalogue should be considered.
Second, cross-provincial transfer and destination. Solid waste and hazardous waste transfers follow separate procedures, and the receiving party’s qualifications must be verified.
Third, safety and occupational health. Dismantling tall equipment, cutting blades and handling modules all involve operational risk. A contractor cannot use an indemnity clause to replace on-site management.
Contracts and records
Retirement and disposal should be written into contracts: equipment list, handover point, transport responsibility, disposal method, final destination, environmental and safety responsibility, breach and compensation. Records should capture source, quantity, weight, destination and the recycler’s qualification documents.
The signal is clear: retired equipment is not a grey area of waste handling but a formal part of the new energy supply chain. The earlier responsibility, qualifications and contracts are settled, the lower the cost at retirement.
For qualifications and operating permits of recyclers, see business licensing; for allocation of responsibility in disposal contracts, see commercial contracts; for ongoing compliance management, see annual legal counsel.
This note is based on the Guidance on Promoting the Recycling of Retired Wind and Solar Equipment published by six departments on 17 August 2023. It is for reference only and does not constitute legal advice.