The Ministry of Environment and Energy Security (MASE) adopts new “Operational Instructions for End-of-Life Management of Incentivized Photovoltaic Modules under the Energy Account Scheme”

With Director’s Decree No. 45 dated 12 March 2025, MASE has adopted the new “Operational Instructions for End-of-Life Management of Incentivized Photovoltaic Modules under the Energy Account Scheme” (hereinafter, the “Instructions”), addressing the “end-of-life” treatment of photovoltaic plant components.

In summary, these Instructions are merely clarifications and adjustments to regulatory updates that have occurred since the last revision of the Instructions, dated October 2023. 

Firstly, two formal modifications have been introduced. Where the previous version referred explicitly to “photovoltaic panels”, the new Instructions use the term “photovoltaic modules”, while retaining the same meaning previously assigned to “panel,” referring to “the photovoltaic panel installed in systems with a nominal power lower than (i.e., in the case of a ‘domestic photovoltaic module’, ed. note) or equal to/greater than (i.e., in the case of a ‘professional photovoltaic module’, ed. note) 10 kW.” Also, where the waste identification code was previously referred to as the “CER code” (European Waste Catalogue), it is now correctly referred to as the “EER code” (European List of Waste).

Beyond these formal amendments, the Instructions implement the updated amount withheld by GSE pursuant to Legislative Decree No. 49/2014. This amount is intended to fully cover the environmentally compliant end-of-life management and disposal costs of photovoltaic modules. Previously, the withheld amount was EUR 10/module for any type of photovoltaic WEEE, whether domestic or professional. Under the new Instructions, this amount is now equal to twice the contribution cost paid to Collective Systems, which is identified as EUR 10/module. Therefore, the new withheld amount is EUR 20/module.

For professional-type plants commissioned between 2006 and 2012, where the withholding process had already begun based on the former EUR 10/module rule, “the increased amount shall apply starting from the remaining installments of the withholding period”, and GSE will proceed with “the rescheduling of the remaining installments of the payment plan.”

Regarding provisions introduced by Legislative Decree No. 118/2020 and subsequent amendments, the Instructions also reflect the clarification introduced by Law Decree No. 13 of 24 February 2023, which states that the contribution payable to the Collective System may be paid in installments over a maximum of five years (and, in any case, not exceeding the remaining incentive period for the specific plant).

The new Instructions also incorporate provisions from Law Decree No. 84/2024, titled “Urgent Provisions on Strategic Critical Raw Materials,” introducing two additional time windows for submitting the application to join a Collective System:

• from 1 April 2025 to 31 May 2025 (currently ongoing);

• from 1 July 2025 to 30 September 2025.

These override the previous application deadline, which was set for 31 December 2024.

As for the timing of refunding previously withheld guarantee amounts by GSE, the Instructions stipulate:

• for domestic-type plants, the refund will be made in the year following the submission of the application to join a Collective System;

• for professional-type plants, the refund will be made within 180 days from the end date of the time window in which the application was submitted.

Lastly, in line with the provisions of Law Decree No. 84/2024, MASE may now rely on GSE to perform verification and control activities over the operations of the Collective Systems.

The annexes to the Instructions remain unchanged, as do the previous provisions, which remain valid following the adoption of Decree No. 45/2025 and the new Instructions for the end-of-life management of incentivized photovoltaic modules under the Energy Account scheme.