2014
Scoping Guide for PV Panels
17-07-2014
Guide for PV Panels
Contents
1
Objective ............................................................................................................................... 3
2
Why the Directive and MS national laws? ............................................................................ 3
3
Which companies have to register? ...................................................................................... 3
4
Which equipment is in scope? .............................................................................................. 4
5
Which equipment should be reported and in which stream? .............................................. 4
6
Are there PVP out of scope due to some explicit exclusion? ................................................ 5
7
Registration responsibilities .................................................................................................. 5
7.1
Retroactivity .................................................................................................................. 6
8
Decision Tree ......................................................................................................................... 6
9
Glossary ................................................................................................................................. 7
10
About the Registration ...................................................................................................... 8
11
Technical Information ....................................................................................................... 8
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Guide for PV Panels
1
Objective
This document has the aim to clarify the scoping of Photovoltaic Panels (PVP), which are from
now on considered Electric and Electronic Equipment (EEE), under WEEE2 and under the
Portuguese Law No 67/2014.
The purpose of this guide is to analyze the characteristics of PVP, as well as understand its
interaction with all the system of collection/conversion of solar energy in to electric power,
and how this equipment works within the system.
At the end of the document, companies will be able to know if they ought to register next to
their national entities and what kind of equipment they should report.
2
Why the Directive and MS national laws?
To answer a problem that has been present since 2002, which is the generation of waste of
EEE and its sound treatment, the European Commission (EC) created a Directive for the
management of WEEE, which was recasted in to a new Directive2012/19/EU – the WEEE2.
By adopting WEEE2, all MS have guidelines to regulate the placement, take-back and
treatment of WEEE in their national territories, guaranteeing that this management is
equitable and procedures are harmonised among in all European Union, avoiding market
asymmetries’.
WEEE2 introduced PVP in its scope, with immediate effects after transposition to the
correspondent MS national laws. In Portugal, PVP is in scope from 8th of May of 2014 forward.
ANREEE is founder of the European WEEE Register Network - EWRN - which gathers all major
European register entities, with presence in the main countries of the EE sector.
The experience gained with the registration and EEE classification, allows EWRN to concert
common positions between all countries, and this guide a result from this knowledge sharing.
The EC casted two documents of Frequently Asked Questions (FAQ WEEE2)1 and (FAQ RoHS2)2,
which were used to help the interpretation of the definitions explained on this document.
3
Which companies have to register?
All companies that place PVP in their national territory, for professional or domestic use, that:




1
2
Manufacture PVP under own name or trade mark
Resell within the national territory, under own name or trademark, PVP produced by
other suppliers
Place into national territory PVP from a third country or from another Member State
Sell of PVP by means of distance communication directly to end users in Portugal,
regardless of whether the company is established in another country of the European
Union or a third country.
Consult the link of the European Commission official website
Consult the link of the European Commission official website
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Guide for PV Panels
4
Which equipment is in scope?
Regardless of where this equipment will destined to be used – in a professional or domestic
context – all PVP are in scope, as well as the elements that usually are part of a system for the
generation of electric energy.
Until 14th of August of 2018, all PVP are under Category 4-Consumer equipment and
Photovoltaic Panels, with indicative examples in Annex I of the Portuguese law.
After that, the categories will change from 10 to 6. Nevertheless, PVP continue to be under
category 4, but the designation will be Large Equipment, with indicative examples in Annex II
of the Portuguese law.
5
Which equipment should be reported and in which stream?
Along with PVP, there is a panoply of elements that are part of the collection/conversion of
solar energy in to electric energy, which can or cannot be electric and electronic equipment
and/or batteries.
The following picture shows a generic scheme of PVP functioning and some elements that can
be found:
PV Cell
PV Cell
PV Panel
Charge Controller
Fixed Mount
Inverter
Batteries
Solar Tracker
Each Photovoltaic Panel (PVP) is considered an unitary equipment.
A fixed structure (e.g. on roofs) and a solar tracker (have a stepper motor and follow the path
of the sun to optimize energy capture) are ways of grouping several PV panels, that is, multiple
unitary equipment.
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Guide for PV Panels
Considering the elements of the scheme above, it is considered to be in scope the following
products:





PVP – EEE Stream
Solar tracker (if exists) –EEE Stream
Charge controller – EEE Stream
Inverter – EEE Stream
Batteries - B&A Stream
Other elements belonging to this system of power generation, such as metal structures, poles,
cables for interconnection between equipment3, parts to fix, are excluded from the legislative
scope and should not be considered for registration purposes.
6
Are there PVP out of scope due to some explicit exclusion?
As the PV panels are installed along with other equipment (see previous point), there may be a
tendency to consider PFV as a Large Scale Fixed Installation, which is an explicit exclusion
under the national law.
A Large Scale Fixed Installation (LSFI) may have one of the following indicative criteria:
a)
b)
c)
d)
Exceed 44 tonnes of weight;
Exceed 5,71m x 2,35m x 2,39m of dimension (Length x Width x Height);
If heavy-duty cranes are needed for installation or de-installation;
If an installation does not fit within a normal industrial environment, where the
environment requires structural modification;
e) If an installation has a rated power greater than 375 kW;
However, any equipment that is not purposely designed and installed to be used in that
installation and is able to perform its functions outside of that installation is included in the
scope.
As this is the case of all PVP and other electric equipment that are part of a photovoltaic
system, even if it is IFGD, all these devices are never out of the scope.
7
Registration responsibilities
1. In a power generation system, two streams of products are involved: electric and
electronic equipment and batteries.
The obligation to register falls on the entity that provides electric and electronic
equipment (EEE) and / or batteries (B&A) into the Portuguese territory (already
described in Section 3 of this document);
3
Although interconnect cables are excluded, the terminated cables, marketed individually are
considered themselves EEE
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Guide for PV Panels
2. If an entity acquires EEE and changes the brand of the supplier for its own brand,
then that entity is considered a reseller under its own brand and has obligation to
register;
3. If an entity acquires EEE in Portugal and resells them without changing the brand of
the supplier, then the entity has no obligation to register.
4. Along with the registration, the law also requires to companies that they should have
a solution for the treatment of EEE waste (WEEE). This condition can be met by
joining a WEEE collective scheme or constitution of a self-management system.
7.1
Retroactivity
The legislation came into force on May the 8th of 2014 and is not retroactive. Therefore,
photovoltaic panels placed on the Portuguese territory should be declared thereafter.
It should be noted that the remaining products - charge controllers, inverters and batteries were already considered as covered by the respective legislation, since the date the law came
into force. Therefore and for reporting purposes, inverters and charge controllers are covered
since 2005 regarding EEE law and batteries are covered since 2009 under B&A law.
8
Decision Tree
UNTIL 14/08/2018
Category 4
EEE Stream
Photovoltaic
Panels
Category 9
EEE Steam
- Inverters
- Charge Controllers
S
Category 4
EEE stream
Category 6
EEE Stream
Category 2
P&A Stream
Solar Trackers
Batteries
N
Dimension ≥ 50 cm?
Category 2
P&A Stream
Category 4
EEE Stream
Category 5
EEE Stream
FROM 15/08/2018
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Guide for PV Panels
9
Glossary
Equipment
Photovoltaic
panel
Fixed Mount
Solar Tracker
Inverter
Charge
Controller
Batteries
Cables for
interconnection
between
equipment
Metal structures
(poles, armours,
etc.)
Parts to fix a
structure
ANREEE
Stream
Classification
until
2018/08/14
Classification
from
2018/08/15
Report in
EEE
Subcat 4.10
Category 4
Report in
EEE
Subcat 4.10
Category 4
Report in
EEE
Subcat 6.9
Cat 4 ou 5
(depends on
dimension)
Report in
EEE
Subcat 9.4
Cat 4 ou 5
(depends on
dimension)
Report in
P&A
Subcat 2.1
Subcat 2.1
Used to transfer electricity, from
an element to the other, inside
the solar system
Out of
scope
-
-
Metal structures (aluminium or
other material)
Out of
scope
Screws, clamps, washers and all
the parts to fix a metal structure
Out of
scope
Definition
Set of PV cells, that collect solar
energy and convert it into electric
energy, through the PV effect.
Set of PV panels, mounted in a
metal structure or armour, which
it’s fixed, e.g., on a roof top.
With an electromagnetic motor,
that can be controlled by digital
signals, whose precision and
tuned positioning adjustment
allows following the solar
rotation and position, taking full
advantage of solar energy.
Also known as converter, it is
used to convert direct current
(batteries) in to alternative
current, used in most common
electric products.
The function of a charge
controller is to monitoring the
transfer of energy from and to
batteries, in order to prevent
fully discharges or overcharges.
Additionally, it can protect
batteries from abrupt current
peaks. Promotes a longer lifespan
to batteries and the components.
Batteries conceived for solar
energy conversion systems and
storage of energy. Also called
Deep-Cycle – because are
designed to deliver less energy
for longer time. Are prepared to a
frequent cycle.
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Guide for PV Panels
10 About the Registration
All information on the procedures of registration, tutorial videos and guides are available in
ANREEE’s website, which we invite you to consult in www.anreee.pt
11 Technical Information
Technical Information
Date of Document
Date of version
Date of last review (*)
July 2014
Version 1
July 2014
(*)Document reviewed and validated by Environment Portuguese Agency
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July 2014
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