Solar panel recycling regulation in Brazil: PNRS, Decree 10.240 and Ordinance MMA 1.560/2026

The rules that govern solar panel disposal

None of these texts was written only for solar panels. Together, they set out who is responsible, which documents must exist and what happens to those who do not comply.

PNRS: the generator is responsible for the waste

Under Law 12.305/2010 (in Portuguese), a generator is anyone who generates solid waste through their activities, including consumption (art. 3, IX). A plant that replaces modules broken by hail is a generator. An O&M company that removes defective modules may also be one, depending on the contract.

Art. 20 requires a solid waste management plan (PGRS) from anyone who generates hazardous waste or waste that, by its nature, composition or volume, is not comparable to household waste. The plan describes the origin, volume and characterization of the waste, including environmental liabilities (art. 21). Broken modules sitting in the yard are a liability and count toward that plan.

The article that weighs most is art. 27, § 1: hiring a company for collection, transport or final destination does not exempt the generator from liability for damage caused by improper management. If the contractor disappears with the batch, the problem goes back to the generator.

Decree 10.240/2020: solar panels are on the electronics list

The PNRS requires manufacturers, importers, distributors and retailers of electrical and electronic equipment to set up reverse logistics (art. 33, VI), and Decree 10.240/2020 (in Portuguese) organizes that system for household use. "Photovoltaic panel" is in Annex I, the list of products. Annex II sets the targets, which reached 17% by weight of the products sold in 2025, the fifth year (art. 49, § 1).

The limit is in the decree itself. Household use means personal, residential or family use, exclusively by an individual (art. 3, XVII). Corporate, industrial or commercial use and large volumes from large generators are excluded (art. 5). For those cases, art. 6 allows reverse logistics to be arranged by contract with the product supply chain and requires the final destination to be set out in the generator's PGRS.

The result: a residential panel falls under the electronics system. A module from a solar plant follows the general rule of the PNRS.

Ordinance MMA 1.560/2026: targets kept while the rule is revised

The schedule in Decree 10.240 ended in 2025. Ordinance GM/MMA 1.560/2026 (in Portuguese), dated January 2 and published in Brazil's Official Gazette on January 5, 2026, kept the 2025 targets of Annex II of the decree for 2026 "until a new regulation is issued" ("até que sobrevenha novo regulamento"). The system remains bound to the same targets while the government prepares the new rule.

Decree 10.936/2022 and the documents that prove the destination

Decree 10.936/2022 (in Portuguese), the current regulation of the PNRS, requires those responsible for a PGRS to report every year on how the plan is being carried out (art. 58). The day-to-day document comes from Ordinance MMA 280/2020 (in Portuguese): since January 1, 2021, a generator subject to a PGRS issues a waste transport manifest (MTR) for each shipment, and the receiving facility issues the certificate of final disposal (CDF) in the same system. The step by step is in MTR, CDF and destination report (in Portuguese).

Who is responsible for what

The generator issues the MTR and is responsible until the final destination is proven. The other links in the chain are responsible for the part they carry out.

What the law requires from plants, EPCs and O&M companies

1. 1

   Put the modules in the PGRS

   Origin, estimated volume, storage and final destination of discarded modules, including what has already piled up in the yard.

2. 2

   Classify the waste

   The class defines storage, transport and the license required from the receiving facility. See the guide are solar panels hazardous waste? (in Portuguese).

3. 3

   Define the generator in the contract

   In EPC and O&M contracts, put in writing who removes the modules, who issues the MTR and who keeps the documents.

4. 4

   Hire a licensed receiving facility

   The license must cover receiving and treating the waste. Hiring does not transfer responsibility (art. 27).

5. 5

   Issue an MTR for every load and keep the CDF

   Together with the batch report, the MTR and the CDF answer inspectors, lenders and ESG auditors.

What about solar panels at home

For household consumers, responsibility ends when the product is returned through reverse logistics (art. 28 of the PNRS). The path is to return the module through the electronics system, by contacting the installer or the retailer, or to hand it to a licensed recycler. Regular trash and construction debris dumpsters are not an option.

Check first whether the drop-off point accepts modules. A panel is large and heavy, and its glass cuts when it breaks, so most electronics collectors do not take them. SunR collects with no minimum volume and has drop-off points for small volumes in Porto Alegre, Araranguá, Florianópolis, Cascavel, São Carlos, São Paulo and Brasília. You drop the modules off at the nearest point, or they are collected at your address (check with us).

What happens to those who do not comply

Art. 51 of the PNRS refers violations to the penalties of Law 9.605/1998 (in Portuguese) and keeps the obligation to repair the damage, with or without fault. For hazardous waste, art. 56, § 1, II, of that law, added by the PNRS itself, covers anyone who stores, transports or disposes of waste in a way other than that set out in law or regulation.

In day-to-day practice, inspectors, lenders and auditors ask for the same thing: the document that shows where the modules went.

What is still being written

As of October 2026, there is no specific federal rule for modules from utility-scale plants and commercial systems. There are bills in Congress and in the Minas Gerais state legislature, tracked in bills on solar panels (in Portuguese), and the state of Mato Grosso already has Law 12.919/2025 (in Portuguese), which encourages reverse logistics for photovoltaic panels.

In 2025, the Ministry of Environment (MMA) also held a public consultation (in Portuguese) to replace Ordinance 280/2020, which regulates the MTR. Until the new rule is out, Ordinance 280 applies. There is no legal vacuum: anyone who removes modules from a plant needs to be able to show where they went.

Guides on this topic

• Are solar panels hazardous waste? (in Portuguese): classification under the Brazilian standard ABNT NBR 10004.
• MTR, CDF and destination report (in Portuguese): who issues each document and what to require from your recycler.
• Bills on solar panels (in Portuguese): what is moving through Congress and the states.
• Solar panel disposal in Brazil: the practical step by step.
• Glossary (in Portuguese): MTR, CDF, PNRS, generator, receiving facility and other terms.

The documents SunR delivers

SunR, the first photovoltaic panel recycler in Latin America, has been recycling modules since 2020 and works under state environmental licenses and in partnership with PV CYCLE, the European photovoltaic recycling association. Every collection leaves with an MTR. At the end, the client receives the CDF, a destination report with the quantity, weight, dates and destination of each material, and a video of the process.

The reverse logistics service serves everything from homes to utility-scale plants, and waste management for EPC and O&M standardizes the documents across projects.