Q: If PV modules are now considered an R2 Controlled Stream, how does that affect which downstream business partners I can do business with?

 R2 Controlled Streams require special management – both on site by the facility and throughout the downstream chain – because of the risk they can pose to people and the environment. To ensure safe and environmentally sound management by downstream business partners, facilities must verify that those business partners meet the downstream vendor qualifications specified in Appendix A of the R2 Standard. 

 Appendix A requires R2 Facilities to verify that their downstream vendors (DSVs) are qualified to receive R2 Controlled Streams, which includes PV modules before shipping occurs. The qualification steps differ for R2 DSVs versus non-R2 DSVs. 

 For R2 Certified DSVs, Appendix A(7) requires the following: 

• Verify the DSV has an active R2 Certification. 

• Verify the DSV has the Scope and Process Requirements necessary to process PV modules.  

No further DSV qualification is required because the R2 DSV has already been audited and is under the ongoing scrutiny of the audit and certification process. An important note is as follows: Under the R2 Code of Practices, R2 Facilities controlling PV modules aren’t required to add Appendix G to their scope until Jan. 31, 2027. Until then, if an R2 DSV hasn’t yet completed its scope extension to include Appendix G, that R2 DSV can still be qualified to receive PV modules under the non-R2 DSV qualification process (described below). 

 For non-R2 Certified DSVs, Appendix A(8) requires a more involved qualification process, including the following:  

• Verify the DSV has the capabilities to process the materials stream(s). 

• Verify the DSV conforms to the R2 Facility’s FM Management Plan (Core 8a). 

• Verify the DSV adheres to a documented system to manage specified environmental, health, safety and legal requirements in the R2 Standard. 

• Additional DSV qualifications are required depending on whether the DSV is testing, repairing, and/or refurbishing PV modules for reuse; processing PV modules for materials recovery; or brokering PV modules.  

• The R2 Facility also must audit all of the non-R2 DSVs at least annually to confirm they still qualify to receive the R2 Controlled Streams.  

 As an example, let’s consider DSV qualification requirements for an R2 Certified Facility that collects PV modules and sends them to a non-R2 DSV for materials recovery at that facility. In this scenario, in order for the R2 Facility to send PV modules to the DSV, the R2 Facility would first need to confirm that its would-be DSV is regularly conducting a hazards identification and assessment. That hazards identification and assessment will likely point to different types of hazards and incorporate varying levels of controls depending on the intensity and types of materials recovery processes occurring at the DSV. For example, if the non-R2 DSV is simply removing aluminum frames from PV modules and sending the rest of the panel elsewhere for the recovery of solar cell metals, then the DSV’s hazards identification and assessment likely wouldn’t need the  same robust industrial hygiene and medical monitoring programs that a non-R2 DSV shredding solar panels might need. In the latter case, the hazards identification and assessment might also include several other controls – such as specifically designated decontamination areas, guards and lockout/tagout procedures for shedders, and annual mechanical separation process risk assessments – that might be deemed unnecessary at a manual dismantling facility.  

 It’s also important to note that these requirements may extend beyond the first shipment. R2 Facilities are held to these non-R2 DSV verification requirements for any subsequent transfers of R2 Controlled Streams to non-R2 facilities. What that means is if an R2 Facility sends PV modules to a non-R2 facility, which sends the PV modules to another non-R2 facility, which sends them to a third non-R2 facility, then the R2 Facility must verify that all three DSV facilities are meeting the applicable R2 requirements. 

 Keep in mind, however, that all of these DSV qualification requirements only apply when transferring R2 Controlled Streams. DSV qualification is not necessary when transferring PV modules that have been processed by the R2 Facility or a DSV and no longer meet the definition of an R2 Controlled Stream. Examples of PV modules, components and materials that are no longer considered an R2 Controlled Stream are the following:  

• R2 Facility (or its DSV) has tested and performed any necessary repairs to restore functionality of the PV module. If a solar panel is tested and confirmed functional in accordance with one of the REC categories for PV modules, then it’s no longer an R2 Controlled Stream, it is a Functional Product. That means it can be sold and shipped to whomever the R2 Facility chooses without conducting DSV verification in accordance with Appendix A.  

• R2 Facility (or its DSV) has sorted and separated materials to such a degree that they’re no longer considered an R2 Controlled Stream. This applies specifically to the PV module Focus Materials, which are defined as the solar cells and interconnections, as well as a mix of glass, solar cells and interconnections. As soon as the Focus Materials reach one of the depollution conditions or recycling outlets described in the Definitions section of the R2 Standard, they are no longer considered an R2 Controlled Stream, and therefore, no longer subject to downstream tracking or verification. It’s important to emphasize, however, that most facilities might lack the recycling processes and technologies necessary to achieve that final disposition of the Focus Materials. As a result, it’s likely that most R2 Facilities will still have to perform DSV qualification on at least some PV module-related streams leaving their facilities. 

In summary, because Appendix G requires PV modules to be managed as an R2 Controlled Stream, a number of tracking and DSV qualification requirements apply to PV modules. R2 Facilities must qualify all DSVs to verify that they meet the requirements of Appendix A. However, DSV qualification is no longer necessary when PV modules reach a point at which they’re no longer defined as R2 Controlled Streams. That’s the case with tested and confirmed functional PV modules, as well as with solar cells that have been processed for metals recovery, processed for use in their entirety in a new product with a known end use and existing market, decontaminated to be below specified thresholds, or received at a downstream R2 Facility.