The MMA (Ministry of Environment and Climate Change) published on January 2nd the Ordinance No. 1.560, which maintains the targets set for 2025 in the Phase 2 schedule of the reverse logistics system for electronic products, established by Decree No. 10.240/2020, to also be in effect throughout 2026 until the enactment of a new regulation.
The measure aims to ensure regulatory continuity, predictability, and legal certainty during the regulatory review, which extends until 2030.
Among the hundreds of products listed in Annex II of the decree are photovoltaic panels, string boxes and direct current converters, equipment present in the distributed and centralized solar energy generation market.
Including these items in the schedule reinforces the responsibility of manufacturers, importers, distributors, and retailers to structure, implement, and finance the reverse logistics of these products, from collection to proper final disposal.
Challenges
The current reverse logistics structure for electronic products was regulated by Decree No. 10.240/2020, which implements provisions of the National Solid Waste Policy (Law No. 12.305/2010) for household equipment and its components. The main target number covers 400 municipalities, including the capital cities.
The document organizes the implementation in phases, providing for the creation of operational mechanisms, collection points, management entities, communication and environmental education, as well as annual collection and disposal targets.
Although the decree includes equipment such as photovoltaic modules and converters, Brazil is still seeking to improve the policy applied to these products, especially in light of the rapid growth of solar power generation in the country.
Experts and industry stakeholders point out that there are still significant challenges in the practice of reverse logistics for photovoltaic modules, especially larger ones from power plants and commercial systems, which still lack a fully consolidated regulatory and market structure for their recycling and reuse.
The energy transition demands a new perspective on the end-of-life of solar modules.
These devices present technical complexities for recycling because they contain materials such as silicon, glass, aluminum, and precious metals, requiring specific processing technologies for material recovery and proper disposal.
This reality has fueled debates about the need for a clearer and more efficient regulatory framework, including policies that encourage the creation of recycling chains, funding for collection points, and incentives for advanced recycling, leveraging the value contained in recoverable materials.
Sustainability
By extending the 2025 targets to 2026, the Ministry of the Environment (MMA) seeks to avoid regulatory gaps that could harm the reverse logistics of electronic products. The measure aims to provide security to companies and agents involved, allowing existing systems to continue operating without interruptions and with clear performance targets.
The solar energy sector is closely monitoring the progress of this regulatory discussion, aware that a robust reverse logistics policy will be essential not only to reduce environmental impacts, but also to consolidate the sustainability of the solar generation chain in Brazil, ensuring that equipment nearing the end of its useful life is treated in an environmentally sound and economically viable manner.
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