Key takeaways
- Photovoltaic modules in Greece now subject to waste electrical and electronic equipment obligations, placing responsibility on equipment producers, importers, or project owners
- Sharp divide exists between pre-2020 and newer modules regarding recycling costs
- Current recycling fee is highly contested, and many argue real costs are much lower; emerging local recycling capacity could enable fee reductions, but regulatory clarity is needed
Introduction
Greece is rapidly expanding its photovoltaic (PV) capacity with rooftop installations, agricultural installations, and large-scale solar PV parks. As the number of PV systems grows, so does the need to manage their end-of-life responsibly. Under the European waste electrical and electronic equipment (WEEE) Directive1 and Greece’s implementing national legislation,2 PV modules are now fully regulated as WEEE. This means that specific actors – primarily PV modules producers, importers, and, in certain cases PV project owners – bear clear obligations for financing and organising the recycling of this WEEE.
This briefing offers a comprehensive view of how the WEEE system applies to PV modules in Greece; what the compliance process looks like in practice; why the distinction between new and legacy modules matters so much; and how the debate around recycling fees is shaping the market.
The legal and institutional landscape
In Greece, PV modules are categorised as “large equipment” under the WEEE regime. Any entity that – for the first time – places PV modules on the Greek market must be registered with the Producer National Register overseen by the Hellenic Recycling Agency (ΕΟΑΝ). The entities concerned fulfil their obligations by joining an approved collective treatment scheme, with Fotokiklosi3 being until recently the only one active in the collection, transport, sorting, preparing for reuse, treatment, recovery, and recycling of PV modules, as well as in the reporting obligations relating to the treatment of PV modules. However, as of 23 May 2025, RE-LAT,4 PV REVIVE,5 and Anafos6 have also received approval to operate collective treatment systems for PV waste.
Producers must ensure that the PV modules they place on the market are properly labelled and that information relating to the different electrical and electronic equipment (EEE) components and materials, as well as the location of dangerous substances and mixtures in EEE, is available to the treatment and recycling facilities.
Although the framework is well defined, yet quite fragmented, understanding who is the “producer” is essential.
Defining producer and obligations concerning registration, reporting, and monitoring
Under the WEEE national rules, the term “producer” includes any company or individual that places EEE on the Greek market for the first time. This definition includes:
(a) Manufacturers or brand-owners who make or have EEE made and sell it under their own brand
(b) Re-sellers who sell EEE under their own brand (unless the original producer’s brand already appears on it)
(c) Importers/distributors established in Greece who, by profession, place EEE on the Greek market from the EU or third countries
(d) Distance sellers established in another Member State or in a third country who sell EEE directly to consumers or businesses
Whatever the business model, the producer is the party legally responsible for financing the end-of-life management of the PV modules it places on the Greek market.
Before any PV module can be sold, the producer or the authorised representative must register with the Producer National Register. Registration requires, among others, basic corporate information, identification of the EEE categories, brand names, the compliance and selling method, and the EEE quantities placed on the market. Once approved, the producer receives a unique registration number, which must appear on the producer’s tax-related information, such as the company’s stamp, invoices, and delivery notes. Operating or participating in public procurement processes without this registration is prohibited.
After registration comes reporting. Producers must periodically7 declare the quantities of PV modules they have placed on the market. These declarations are used by the collective treatment schemes to calculate the producer’s financial contributions, which are meant to cover future recycling costs. The accuracy of reporting directly affects the long-term stability of the system, as contributions collected today will be needed years later when the PV modules reach their end of life.
ΕΟΑΝ monitors compliance through inspections, data verification, and coordinated checks with other authorities. Approval of environmental terms, cross-border shipment records, producers’ submissions, and operational documentation may be audited, and non-compliance can lead to administrative fines and other sanctions under multiple laws or to suspension of registration certificates in the Producer National Register. This monitoring is essential to ensuring that all market participants contribute fairly and that “free riders” do not undermine the system.
How PV modules recycling works in practice
The actual recycling of PV modules involves several stages and can be logistically demanding. Removing PV modules from rooftops may require specialised equipment, while utility-scale parks are often located in remote areas that complicate transport arrangements. Once removed, PV modules must be packaged and delivered to approved treatment and recycling facilities.
At the treatment and recycling facilities, PV modules are dismantled into their constituent materials: aluminium frames, glass sheets, cables, junction boxes; and the encapsulated semiconductor layer. Recovery of aluminium and glass is well established, but the extraction of silicon and trace metals such as silver remains technologically complex and relatively costly.
Recent developments have significantly improved Greece’s recycling capacity. Three dedicated PV recycling facilities are now operational – in Irakleio (Crete), Ritsona (central Greece), and Kozani (Macedonia) – reducing the need to export PV modules to other countries and lowering transport and treatment costs. Collective treatment schemes report expanding collection networks and rising volumes of handled material, reflecting the gradual maturation of the system.
Legacy PV modules and new PV modules: an essential distinction
One of the key features of the Greek PV-WEEE landscape is the difference between older “legacy” PV modules and those placed on the Greek market from 2020 onwards. Legacy PV modules were sold before the current financing mechanism existed, meaning no recycling contributions were collected at the time of sale. For these PV modules, the cost of recycling now falls on the end user, project owner, or power producer – in the sense of the PV project owner or operator of the installation – not on the EEE producers indistinctively.8
For PV modules installed in newer projects, the rules are clearer. Producers must pay the recycling fee upfront, thereby complying with the “polluter pays” principle. If a producer fails to participate in a collective treatment scheme or ceases operations without having fulfilled its financial obligations, liability may still fall back on the PV module owner. This division between legacy and new products is central to ongoing debates about fairness, cost allocation, and the sustainability of the system – particularly for repowering projects, where large numbers of older PV modules are replaced at once.
The debate over the recycling fee
The minimum mandatory recycling fee set by ΕΟΑΝ, currently €300 per tonne, has been one of the most contentious issues in the sector. Many industry stakeholders argue that this amount is far higher than actual treatment costs, especially now that domestic recycling plants have reduced transport and processing expenses. Some recycling operators estimate the real cost to be closer to between €80 and €100 per tonne. According to this view, the current fee discourages activity and delays the decommissioning of older systems.
Fotokiklosi had previously proposed reducing the fee from €150 per tonne (applicable from 1 January 2023 until 31 December 2024) to €90 per tonne, citing updated cost data and operational experience with local recycling infrastructure. However, following the entry of additional collective treatment schemes, the minimum mandatory recycling fee unexpectedly increased rather than decreased. Many believe that only the Ministry of Environment can provide the legal clarity needed to resolve this dispute and stabilise the system, while EOAN has assigned the preparation of the cost analysis and calculation of the mandatory recycling fee of obligated producers to PricewaterhouseCoopers Business Solutions.
Current challenges and emerging realities
Despite significant progress, several challenges continue to shape the Greek PV recycling landscape. Removing and transporting PV modules can be costly and complex, especially for remote or dense installations. Recycling capacity, although expanding, may face strain as Greece begins large-scale repowering of early PV installations. The recovery of high-value materials remains technologically difficult, which affects the economics of recycling. Timing also matters: producers contribute financially today, but the PV modules they sell may not reach end of life for decades, requiring careful long-term financial planning. Finally, recyclers often face gaps in information about PV module chemistry or construction, limiting material recovery; better traceability, potentially through digital product passports, would significantly improve performance.
A practical way forward
Improving the system will require cooperation across the entire value chain. Producers should plan ahead for future waste volumes and align with compliance schemes early, ideally through long-term contracts. Providers of engineering, procurement, and construction services and of operations and maintenance would benefit from integrating decommissioning planning from the outset of a project rather than treating it as an afterthought. Recyclers need to continue scaling their operations and adopting flexible technologies capable of adjusting to fluctuating waste flows. At the policy level, clearer decisions from ΕΟΑΝ and the Ministry of Environment and Energy – particularly on fee structures and legacy or historical liabilities – will be essential to maintain confidence in the system.
Conclusion
Greece’s WEEE framework for PV modules has evolved into a functioning, but still imperfect, system. The debates around fee levels and the allocation of responsibility for legacy PV modules reveal how sensitive the balance between regulation, cost, and environmental stewardship can be. With clearer rules, better coordination, and continued expansion of recycling capacity, Greece could transform end-of-life PV modules management into a genuine example of circular-economy practice. The decisions taken today will determine how effectively the country handles millions of PV modules in the decades ahead.
- Directive 2012/19/EU of the European Parliament and of the Council of 4 July 2012 on waste electrical and electronic equipment (WEEE), as amended by virtue of (a) Directive (EU) 2018/849 of the European Parliament and of the Council of 30 May 2018 and (b) Directive (EU) 2024/884 of the European Parliament and of the Council of 13 March 2024. The latter has not been yet transposed into national law.
- Ministerial Decision no. Η.Π. 23615/651/Ε.103/2014, published in volume B of the Greek Government Gazette on 9 May 2014 under no. 1184, as amended by Ministerial Decision no. ΥΠΕΝ/ΔΔΑ/81490/1650/2021 published in volume B of the Greek Government Gazette on 22 September 2021 under no. 4382, in conjunction with Law 4819/2021.
- The operation of Fotokiklosi was approved in February 2009 by Ministerial Decision no. 116764/2009 (Government Gazette 317/B/20.02.2009). In July 2020, by virtue of EOAN decision no. 171.2/16.07.2020 (ΑΔΑ: Ω82846Ψ8ΟΖ-ΑΡ6), the approving decision for the operation of Fotokiklosi was renewed and expanded in order to include the treatment of PV modules as well.
- EOAN decision no. 220.4/23.05.2025 (ΑΔΑ: ΡΔΩΣ46Ψ8ΟΖ-Η02).
- EOAN decision no. 220.5/23.05.2025 (ΑΔΑ: ΕΒΦΦ46Ψ8ΟΖ-Δ01).
- EOAN decision no. 220.6/23.05.2025 (ΑΔΑ: 6ΖΡΟ46Ψ8ΟΖ-Ψ7Υ).
- Fotokiklosi requires monthly declarations.
- It remains to be seen how Directive (EU) 2024/884, considering WEEE resulting from PV modules before 13 August 2012 as historical, will be transposed into national law. Said directive came to bring clarity on the treatment of historical WEEE following a ruling of the Court of Justice of the European Union. On 25 January 2022, the EU Court of Justice in its judgment in Case C-181/20, declared article 13(1) of Directive 2012/19/EU to be invalid insofar as it concerns photovoltaic panels placed on the European market between 13 August 2005 and 13 August 2012, by reason of non-justified retroactive effect.
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