The most consequential sentence in Japan’s new solar-recycling debate is a negative one. It is not the threshold, the timetable, or the tiered obligations. It is the list of panel types the proposed rules would not cover at all — and perovskite sits at the top of it.

On October 30, Japan’s Ministry of the Environment and Ministry of Economy, Trade and Industry (METI) presented proposals to a study group drafting the implementing rules for the Act on Promoting the Recycling of Solar Cell Waste, enacted on May 29, 2026 and promulgated on June 5. The ministries proposed that owners of commercial solar installations planning to dispose of 50 metric tons (MT) or more of panels file an advance disposal plan. Silicon, CIGS, and cadmium telluride (CdTe) panels would be covered. Perovskite modules — glass and film alike — would not, alongside gallium arsenide (GaAs) and glass-fiber flexible panels. The reason given is blunt: recycling technologies and processing routes for these types do not yet exist.

The study group took up panel types, weights, and the large-volume threshold at its first meeting on October 30; it is due to turn to certification and processing standards in mid-November and judgment criteria in early December. A joint council will review the proposals from December to March before public consultation, with rules planned for publication around spring 2027, when recyclers can also begin pre-applying for certification. The law must take effect within 18 months of enactment, and the government’s working schedule targets around early December 2027. Every figure in this article is therefore provisional — the shape of a regime being drafted, not the text of one already in force.

What the proposal actually says

Under existing law, panels must be handled as waste, but recycling is not mandatory, and the government says landfill has often been chosen. The new law sets three tiers of obligations. Everyone who disposes of panels has a general duty to promote recycling. Commercial disposers — including rooftop owners who sell their power — would receive guidance and advice under government criteria. Commercial disposers above the threshold would have to file disposal plans in advance and could face government recommendations and orders. The threshold determines which operators face the law’s most stringent requirements: set it low and the regime reaches deep into the small-commercial fleet; set it high and it concentrates on the large operators the ministries consider able to recycle cost-effectively.

The ministries compared three candidate thresholds — 40 MT, 50 MT, and 60 MT — and the comparison is instructive because the headline numbers barely move while the coverage does. All three would capture a similar share of panel waste expected from 2027 to 2050: 38.7% at 40 MT, 38.3% at 50 MT, and 37.9% at 60 MT. The difference is in which plants are covered. At 40 MT, 8,368 facilities would be covered, including 1,263 of 600 kW or less. At 50 MT, the figure falls to 7,398, with none of that size. At 60 MT, it is 6,784. The ministries said 40 MT or 50 MT would capture the majority of plants of 1 MW or more, and argued that 50 MT would avoid excessive regulation of smaller plants while focusing requirements on operators able to recycle cost-effectively. Industry outlet IRU-MIRU reported that most study group members backed 50 MT, while some argued for 40 MT to widen coverage. That reporting is second-hand — the study group’s own minutes, if published, would be the primary record — but the ministries’ preference is clear from the proposal itself.

Two details show the proposal has been thought through as an enforcement instrument. To prevent operators from staying under the threshold by splitting one project into several smaller disposals, the ministries proposed counting panels removed from the same plant during a single decommissioning or repowering within about one year as one disposal. Replacements after disasters or equipment failures, and routine maintenance swaps, would not count as split disposal if documented. And the law would apply only to panels weighing at least 3.7 kg each, a cutoff meant to exclude small products such as calculator cells: the lightest module model installed since 2011 weighs 4.7 kg, and, with one small exception, the lightest earlier model weighs 3.7 kg.

The waste volumes at stake explain the urgency. The government projects end-of-life panel waste will peak at up to about 500,000 MT a year in the 2040s, well above an earlier estimate of 170,000 MT to 280,000 MT a year around 2035 to 2037. Since July 2022, solar projects of 10 kW or more under Japan’s feed-in tariff and feed-in premium schemes have had to set aside funds for decommissioning costs. The new law adds recycling and disposal-plan requirements on top of that. The money for taking panels down is already supposed to be set aside; what has been missing is a system for what happens to the panels once they come down.

What is in, what is out, and why the line is drawn there

The scope proposal divides the panel world in two, and the dividing line is the existence of a processing route — not market share, maturity, or environmental hazard.

Covered: silicon modules, which the ministries said account for about 95% of global production, along with copper indium gallium selenide (CIGS) and cadmium telluride (CdTe) thin-film panels. Single-glass, double-glass, and building-integrated photovoltaic (BIPV) panels would all be included, as the ministries said processing routes exist for these designs. The inclusion of double-glass deserves a note, because it is where readiness is thinnest. Double-glass modules made up 39.3% of Japanese shipments in 2025, based on data from 17 members of the Japan Photovoltaic Energy Association (JPEA). In a survey of 81 waste processors, 46 (56.8%) said they could accept double-glass panels and only 21 (25.9%) said they could accept BIPV panels.

Excluded: organic cells, including both glass and film perovskite, along with gallium arsenide and other specialty compound cells and glass-fiber flexible panels. The ministries said recycling technologies and processing routes for these do not yet exist, and that the scope would be reviewed as technology and markets develop.

That last clause — the review promise — is the most important sentence in the proposal for the perovskite industry, and also the least specific. No review date, trigger, or mechanism is described in the reporting to date. A scope that “would be reviewed as technology and markets develop” is a commitment to revisit, not a timetable. The practical consequence is a grace period of unknown length: perovskite modules installed now will reach end of life in the 2040s and 2050s, by which time the scope will almost certainly have been revised — but the revision could equally arrive in 2028 or 2038, and the difference matters enormously for how manufacturers design for disassembly today.

The timing problem: promoted at the front end, unregulated at the back end

The perovskite exclusion lands in the middle of a deliberate, state-led perovskite push, and the juxtaposition is the story’s sharpest edge.

The government aims to deploy 20 GW of perovskite solar by 2040, a target set in METI’s Next-Generation Solar Cell Strategy of November 2024. In September, the Ministry of the Environment announced plans to exclude conventional silicon panels from newly introduced subsidy programs starting in fiscal 2027, prioritizing perovskite and other next-generation technologies. In October, Panasonic announced that it had begun selling early-production glass-based perovskite panels in September 2026 from its development facility in Moriguchi, Osaka Prefecture, ahead of full-scale mass production planned for April 2029 at Nagahama — one year earlier than the originally planned fiscal 2030 start. Sekisui Chemical has likewise launched a flexible perovskite film business. The product type Panasonic is selling — glass-based perovskite panels — is exactly the type that falls outside the proposed recycling scope.

None of this is a contradiction in the narrow sense. A government can promote a technology’s deployment while acknowledging that its end-of-life infrastructure does not yet exist; that is the normal sequence for a new technology. But the sequence creates a liability that compounds silently. Every perovskite module installed in the 2020s and 2030s becomes a disposal problem in the 2040s and 2050s, and the system now being designed, certified, and capitalized is built around silicon, CIGS, and CdTe. It is that perovskite’s turn arrives after the institutional shape has hardened — after certification standards are written, processor capacity financed, and compliance costs settled — with perovskite still needing its own routes, standards, and economics.

There is also a materials reason the perovskite route cannot simply be borrowed from silicon recycling. A silicon module is mostly glass, aluminum, and silicon, with established mechanical and thermal separation processes. A perovskite module is a thin, solution- or vapor-deposited absorber — in the dominant commercial formulations, a lead-halide compound — sandwiched between charge-transport layers and encapsulation, often on glass or flexible film. The valuable and hazardous fractions are thin and chemically intimate with their substrates. Recovering lead safely, separating the absorber from glass or film without destroying the value of either, and doing so at a cost a recycler can sustain are research problems, not procurement problems. Laboratory demonstrations of perovskite recycling exist; a processing route, in the sense the ministries mean — a certified, permitted, commercially operating route a disposer can actually use — does not.

What this means, and what to watch

For perovskite manufacturers, the immediate consequence is the absence of a compliance obligation — and the presence of a strategic question. No advance disposal plan is proposed for perovskite modules, no certification standard is being drafted for their recyclers, and no compliance cost is yet attached to selling them in Japan. That is a short-term advantage, and it would be a mistake to treat it as permanent. The scope review, whenever it comes, will ask the industry a question it should be answering now: what is the disassembly and recovery route for your module, and can you demonstrate it at a scale a certifier can audit? Manufacturers that design for that question will be ready. Those that treat the exemption as the end of the story will find the review arriving as a retrofit problem.

For researchers, the proposal is a funding signal disguised as a regulation. The ministries have stated, in a public process, that perovskite recycling routes do not exist. That is a gap with a named customer — the certification system that will eventually need routes to certify — and a named timeline, with rules due in spring 2027 and entry into force around December 2027, after which the absence of a route becomes a visible hole in a live regime rather than a footnote in a proposal. Research that produces a demonstrable, auditable perovskite recovery process — one that handles lead safely, recovers glass or film value, and reports its energy and cost balance honestly — is aimed directly at a regulatory opening. The same applies, with less urgency, to BIPV processing, where only a quarter of surveyed processors say they can accept panels the proposal already covers.

The study group’s calendar is the real timetable, and it is short. Certification and processing standards come up in mid-November; judgment criteria in early December; joint council review December to March, then public consultation, with rules planned for spring 2027. Three questions should be asked at each step. Does the threshold stay at 50 MT, or does the 40 MT argument return during consultation? Does the exclusion list change if a credible route for an excluded type emerges? And does the scope review gain teeth — a date, a trigger such as a deployment volume or demonstrated route, or a reporting obligation on perovskite manufacturers? Any of those would convert an open door into a schedule; their absence leaves the exemption open-ended.

The bottom line

Japan’s proposal is, in its way, a model of regulatory honesty: a recycling law that covers what can actually be recycled, sets its threshold by measured coverage rather than round numbers, writes an anti-avoidance rule before anyone has gamed the threshold, and admits openly that the technology it is promoting hardest has no end-of-life route yet. The perovskite carve-out is not a scandal and not a loophole. It is a statement of fact about the state of recycling technology, made in public, inside a process that will publish rules in spring 2027 and take effect around December 2027.

But honesty about a gap is not a plan to close it. Panasonic’s glass perovskite panels are already selling in early production, Sekisui’s films are already in business, and the 20 GW target is already national policy. Every one of those modules will one day need a route that does not yet exist, under a law whose scope review has no date. The question for the study group, between now and spring 2027, is not whether perovskite belongs in the law today — on the ministries’ own criterion, it does not — but what has to be true before it does, and by when.

No investment recommendation is made or implied anywhere in this article.

Sources and further reading

  • pv magazine Global (November 2, 2026), “Japan proposes 50-metric-ton trigger for solar panel recycling plans” — the primary source for the ministries’ proposal, the threshold comparison figures, the 3.7 kg cutoff, the covered and excluded panel types, the study group timetable, the waste projections, and the 20 GW deployment aim. IRU-MIRU’s reporting on study group members’ threshold preferences is cited through pv magazine.
  • pv magazine Global (October 23, 2026), “Panasonic begins sales of glass-based perovskite solar panels” — Panasonic’s September 2026 start of commercial sales of pre-production units from Moriguchi, Osaka Prefecture, the April 2029 full-scale production plan at Nagahama, the November 2024 METI 20 GW by 2040 target, and the September announcement excluding silicon panels from new subsidy programs starting in fiscal 2027.
  • METI, Next-Generation Solar Cell Strategy (November 28, 2024) — the 20 GW domestic perovskite deployment target for 2040, as reported by pv magazine and the Institute for Energy Economics and Financial Analysis.
  • Act on Promoting the Recycling of Solar Cell Waste (enacted May 29, 2026; promulgated June 5, 2026) — the law’s three-tier obligation structure and 18-month entry-into-force window, as reported by pv magazine.

Background on perovskite module structure — thin lead-halide absorber layers, charge-transport layers, and encapsulation on glass or film substrates — is drawn from the standard perovskite device literature rather than any single paper. No threshold, date, facility count, or market figure is stated in this article beyond what the ministries proposed or the cited reporting disclosed, and every proposal figure is identified as proposed, not final, throughout.