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New Jersey now has a statewide solar panel recycling law on the books. Governor Murphy signed S3399 into law on January 12, 2026, codified as P.L. 2025, c.211, putting the Garden State among the first states to formalize end-of-life rules for solar and photovoltaic facilities. This article explains what the new law requires, when its operative duty actually starts, and what it means for New Jersey solar owners across PSE&G, JCP&L, ACE, and Orange & Rockland service territories.

As of April 30, 2026: New Jersey has signed S3399 into law as P.L. 2025, c.211. The act took effect immediately upon signing, but the recycle-or-refurbish duty is not yet operative — it begins 180 days after the New Jersey Department of Environmental Protection (NJDEP) publishes a finding that recycling facilities are widely accessible and available in the State.

At a glance

• What it requires: The owner, producer, distributor, or manufacturer of a solar/PV facility, including solar in Edison, must remove and recycle or refurbish the system (and related equipment) after termination of use, per S3399 / P.L. 2025, c.211.
• When it takes effect: The act took effect on signing (January 12, 2026), but the recycle-or-refurbish duty does not begin until 180 days after NJDEP publishes its facility-availability finding.
• Who must comply: Responsibility is shared across four named parties — owner, producer, distributor, and manufacturer — not pinned only on homeowners.
• Refurbishment is allowed: Reusing or refurbishing equipment is an explicit, legal alternative to recycling under Section 1.a of the statute.
• Penalties: Violations are enforced as Solid Waste Management Act violations under C.13:1E-9 by the NJDEP Commissioner — there is no flat $1,000 per-panel fine in the enacted law.
• Federal context: The federal Section 25D Residential Clean Energy Credit was repealed in 2025, so this state law operates without a federal residential offset for owner-installed systems.

What does New Jersey's new solar panel recycling law actually require in 2026?

New Jersey's new solar panel recycling law requires the owner, producer, distributor, or manufacturer of a solar or photovoltaic facility to remove and recycle or refurbish the system — and any related equipment — when its use is terminated. That is the operative sentence in Section 1.a of P.L. 2025, c.211, and it applies regardless of whether the facility is a single-family rooftop array, a large rooftop on a warehouse, or a ground-mount commercial installation.

The core duty: remove and recycle or refurbish

The statute uses the disjunctive "or" — recycle or refurbish. That is intentional. A working array taken off a roof for an upgrade does not have to be ground into glass cullet to satisfy the law; it can be cleaned, tested, and reinstalled or resold. Refurbishment is a peer option to recycling, not a workaround.

What counts as a "solar or photovoltaic energy generation facility"

The law speaks in broad terms — "solar or photovoltaic energy generation facility or structure." That phrasing reaches both the modules on a typical New Jersey home and the ground-mounted arrays at commercial and utility-scale sites. The statute does not carve out residential systems.

Why "related equipment or infrastructure" matters

Section 1.a expressly includes "any related equipment or infrastructure." That means the duty isn't limited to the photovoltaic modules themselves — it can reach inverters, racking, wiring, combiner boxes, and similar components that come down with the array. For most homeowners, this is what their installer is already taking off the roof during a system removal. The law just makes clear that those components are on the same end-of-life track as the panels.

When does the solar recycling mandate take effect in New Jersey?

The act took effect on January 12, 2026, but the recycle-or-refurbish duty itself does not begin until 180 days after NJDEP publishes a finding that recycling facilities are widely accessible and available in New Jersey. Until that finding appears in the New Jersey Register and on NJDEP's website, the operative compliance clock has not started — full stop. (See P.L. 2025, c.211.)

Effective date vs. operative date

Section 2 of the law says simply "this act shall take effect immediately." That makes the act legally effective as of the signing date. But effectiveness and operative duty are different things — Section 1.a builds in a separate trigger for when the recycle-or-refurbish obligation actually kicks in. Reading them together is the only way to get the timing right.

The NJDEP "widely accessible and available" finding

Section 1.c directs NJDEP to "frequently evaluate the availability and accessibility of recycling facilities for solar or photovoltaic energy generation facilities, or components thereof, within the State." Once NJDEP determines those facilities are widely accessible and available, it must publish that finding in the New Jersey Register and on its website within 30 days. There is no statutory deadline for NJDEP to make the finding — only for publishing it once made.

The 30-day publication window and the 180-day countdown

Once the finding is published, Section 1.a starts a 180-day countdown. After that 180 days runs out, the recycle-or-refurbish duty is operative for the named parties. As of April 30, 2026, NJDEP has not published the finding, so the operative date remains undetermined. Industry observers covering S3399 have suggested the finding may not come until late 2026 at the earliest, given current in-state recycling capacity and logistics constraints.

Who is on the hook to comply: homeowners, installers, manufacturers, or all of them?

All of them, by statute — the law names four responsible parties: owner, producer, distributor, or manufacturer. That language matters because it puts the supply chain on notice, not just the resident whose roof carries the panels. The disjunctive "or" gives NJDEP flexibility to address a violation against any party in the chain.

The four parties named in the statute

"Owner, producer, distributor, or manufacturer" is the literal list. The law does not assign primary or secondary responsibility among them — each is named directly in Section 1.a. That structure reflects the reality of how solar systems actually move through commerce: the manufacturer ships modules, a distributor moves them to an installer, and the homeowner or commercial customer ends up as the legal owner.

What this means for residential solar owners

For a typical homeowner with a fully-purchased rooftop array, the resident is the "owner" for purposes of the statute. In practice, most homeowners will satisfy the duty by working with their installer or a take-back program when the system is eventually removed — not by personally hauling panels to a recycling facility. The law gives the homeowner a clear hook to ask the installer how end-of-life will be handled.

What this means for commercial owners, installers, and lease/PPA arrangements

For a commercial array — a warehouse rooftop, a ground-mount on a farm, a community solar site — the "owner" is usually a corporate entity, and the practical compliance burden sits there. Lease and PPA systems are an important wrinkle: even though the panels are on a residential roof, the system is owned by a commercial entity (the leasing company or PPA provider). That means the resident is generally not the "owner" under the statute, and the leasing company carries the recycle-or-refurbish duty. Confirm that obligation in the lease or PPA contract.

What does "termination of use" mean for a New Jersey solar system?

"Termination of use" is not defined in the statute, so the plain-English reading is that the duty is triggered when the facility is permanently taken out of service. The law does not draw a line for short outages, seasonal shutdowns, or routine maintenance — it focuses on the point at which the array stops being used as a generation facility.

What the statute does (and doesn't) say

The statute uses the phrase "after the termination of its use" without further definition. There is no list of triggering events, no time threshold, and no carve-out for partial removals. That silence is meaningful: until NJDEP provides interpretive guidance through rulemaking, the plain reading governs.

Practical scenarios that likely qualify

Several real-world scenarios fit comfortably within the plain meaning:

• Panels reach end-of-life and are replaced with new modules.
• The homeowner upgrades to a higher-wattage system and the original modules are retired.
• A roof is replaced and the array is permanently taken down.
• The property is demolished and the system is decommissioned.
• A commercial site is decommissioned (lease ends, owner exits the business).

By contrast, a roof replacement where the same panels are lifted, the roof reshingled, and the same panels reinstalled is functionally a continuation of use — the facility goes back into service rather than being terminated.

Why NJDEP rulemaking matters here

Section 1.b authorizes NJDEP to adopt rules under the Administrative Procedure Act, but the language is permissive — "may," not "shall." NJDEP could clarify "termination of use" through rulemaking, including edge cases like long-term outages or partial decommissioning. Until then, the duty exists regardless of whether rules are issued, and the plain meaning controls.

Can a New Jersey solar owner refurbish panels instead of recycling them?

Yes — refurbishment is explicitly listed as a legal alternative to recycling under P.L. 2025, c.211. Section 1.a uses the disjunctive "recycle or refurbish," which makes refurbishment a peer outcome rather than a fallback. Working modules can be tested, cleaned, and put back into service either at the same site, at a different site, or through a refurbisher's secondary market.

Refurbishment vs. recycling under the law

The two options serve different end-of-life realities. Recycling is for modules that have failed, are damaged, or have aged past usable performance. Refurbishment is for modules that still produce reliable power but no longer fit the owner's needs — a homeowner upgrading from an older system, a commercial owner consolidating to higher-density modules, or a roof replacement where the array is being downsized.

When refurbishment makes sense

Refurbishment is most attractive when the array is removed for a reason unrelated to module health — a roof replacement that downsizes the array, a commercial owner upgrading to higher-wattage modules, or a homeowner moving and selling the system to a refurbisher. In each case, the modules still work; the facility's use at that location simply ended.

Documentation a NJ owner should keep

The statute does not impose a "chain of custody" requirement (that phrase is not in the law), but documentation is still the easiest way to prove compliance. Keep records of who removed the system, where the modules went, the recycler or refurbisher's name, dates, and serial numbers when available. If NJDEP later asks how an end-of-life event was handled, paperwork is the answer.

What are the penalties for improperly disposing of solar panels in New Jersey?

Improper disposal is treated as a Solid Waste Management Act violation under C.13:1E-9, enforced by the NJDEP Commissioner — not a single flat fine. Section 1.d of the enacted law cross-references the Solid Waste Management Act, P.L.1970, c.39 (C.13:1E-1 et seq.), and authorizes the Commissioner to use "any of the actions or penalties provided for in section 9 of P.L.1970, c.39 (C.13:1E-9), in order to address the violation."

Solid Waste Management Act enforcement

The Solid Waste Management Act gives NJDEP a broad enforcement toolkit. The Commissioner can issue administrative orders, pursue civil and civil administrative penalties, and seek injunctive relief. That toolkit is the same one NJDEP uses for other improper disposal of regulated waste — and now it covers solar/PV facility violations under P.L. 2025, c.211.

What C.13:1E-9 actually authorizes

Rather than a flat dollar figure, C.13:1E-9 authorizes a tiered enforcement approach. The Commissioner can match the response to the severity of the violation, the harm caused, and whether the violator has been on notice. That flexibility is the point — a one-time disposal incident is treated differently from a pattern of dumping panels in a landfill.

Why the rumored "$1,000 per violation" figure is wrong

Early coverage of S3399 frequently cited a "$1,000 per panel" or "$1,000 per violation" fine. That language was in the first reprint of the bill and was removed before final passage. The version Murphy actually signed (the 2nd reprint, codified as P.L. 2025, c.211) replaces that flat-fee language with the Solid Waste Management Act cross-reference. Anyone planning compliance should ignore the $1,000 figure — it is not in the law.

How does this law change cost and planning for New Jersey solar owners in 2026?

In 2026 it does not change costs at all, because the recycle-or-refurbish duty has not yet been triggered by NJDEP. There is no new fee schedule in force, no operative mandate, and no compliance line item for solar quotes today. The law is on the books, but its operative date is gated on a NJDEP factual finding that has not been published.

Short-term: no immediate price change in 2026

If you receive a New Jersey solar quote today, the price reflects existing market conditions — module costs, labor, racking, inverters, interconnection, and any state incentives in effect — not a new recycling fee. NJDEP has not yet adopted rules and has not yet published its facility-availability finding, so installers cannot pass through compliance costs that don't yet exist.

Medium-term: NJDEP fees and product stewardship

Section 1.b authorizes NJDEP to adopt rules that include a fee schedule sized to cover the agency's full implementation costs. The rulemaking is permissive, but if NJDEP exercises that authority, fees could eventually flow through to industry pricing. The same section also lets NJDEP consider establishing a product stewardship program — a model in which manufacturers contribute to end-of-life management — or adapt programs from other states. Those are future-state developments, not 2026 line items.

Long-term: end-of-life as a line item in your solar plan

Solar systems are designed for 25-plus years of service, which means today's installations will be retired well after the recycle-or-refurbish duty becomes operative. Treating end-of-life as a planning topic now — rather than a surprise later — is the most useful response to P.L. 2025, c.211. Use the checklist below as a starting point.

End-of-life planning steps for New Jersey solar owners

1. Confirm system ownership in writing — purchase, lease, or PPA — and identify which entity is the "owner" for end-of-life purposes.
2. Keep an equipment record: module manufacturer, model, serial numbers, inverter make and model, installation date, and installer.
3. Ask your installer about take-back or end-of-life programs and whether they partner with a recycler or refurbisher in New Jersey.
4. Save warranty documents and any manufacturer end-of-life guidance — manufacturers sometimes offer module take-back through their own channels.
5. If you ever remove or replace the array, document the disposition (recycled, refurbished, resold) including the receiving facility's name, location, and date.
6. Re-check NJDEP's website and the New Jersey Register periodically to see whether the "widely accessible and available" finding has been published.
7. Add a placeholder line for end-of-life handling to any long-term financial plan for the system, even if you cannot price it yet.

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Frequently Asked Questions About New Jersey's Solar Panel Recycling Law

When exactly does New Jersey's solar panel recycling law start being enforced?

The act took effect on January 12, 2026, but the recycle-or-refurbish duty does not begin until 180 days after NJDEP publishes a finding (in the New Jersey Register and on its website) that recycling facilities are widely accessible and available in New Jersey. NJDEP must publish that finding within 30 days of making it. Until publication, the operative clock has not started.

Do I have to recycle my old solar panels myself as a New Jersey homeowner?

No — the statute names four responsible parties (owner, producer, distributor, or manufacturer), so responsibility is shared across the supply chain. For a typical homeowner-owned rooftop array, the resident is the "owner," but most homeowners will satisfy the duty by working with their installer or a take-back program. For leased or PPA systems, the commercial system owner usually carries the practical compliance burden.

Is it legal in New Jersey to reuse or refurbish working solar panels instead of recycling them?

Yes. Section 1.a of the law explicitly authorizes "remove and recycle or refurbish," so refurbishment is a peer alternative to recycling, not a workaround. A working array taken off a roof for an upgrade can be refurbished and reinstalled or resold and still meet the requirement.

What happens if a homeowner just throws solar panels in the regular trash in New Jersey?

Under Section 1.d of P.L. 2025, c.211, that would be treated as a Solid Waste Management Act violation under C.13:1E-9, and the NJDEP Commissioner can pursue any administrative action or civil penalty available under that statute. The framework is significantly broader than a single $1,000 fine, and it does not have a flat per-panel charge.

Will the New Jersey solar recycling law make new solar installations more expensive in 2026?

Not in 2026. The recycle-or-refurbish duty has not yet been triggered by NJDEP, and the agency's authority to adopt a fee schedule under Section 1.b is permissive ("may"), not mandatory. Any future fees or product stewardship program would only flow through to pricing after rulemaking.

Does the new law apply to solar panels I already own, or only to panels installed after January 12, 2026?

It applies to existing panels too. The statute ties the duty to "termination of use," not the install date — so panels installed years ago are covered when they are eventually retired, once NJDEP's facility-availability finding makes the duty operative.

Where can I read the actual text of New Jersey's solar panel recycling law?

The official text is P.L. 2025, c.211 (originating as Senate Bill 3399 of the 2024 session). The New Jersey Legislature publishes the bill page and the final reprint at njleg.state.nj.us — those are the canonical sources.

How Powerlutions Helps New Jersey Solar Owners Plan for End-of-Life Compliance

Powerlutions designs every New Jersey solar project so that recycle-or-refurbish compliance under P.L. 2025, c.211 is straightforward — not a future surprise. We treat end-of-life planning as part of the install conversation, not an afterthought, because the homeowner who has clean documentation today is the homeowner who has the easiest decision when it is time to remove or replace the system.

End-of-life planning in every Powerlutions design proposal

When we propose a system, we walk you through what happens decades from now: who owns the equipment, how it would come down, and what your refurbishment-versus-recycling options would look like. That conversation is short — but it is the conversation that turns P.L. 2025, c.211 from a worry into a checklist item.

Documentation we keep on every install and removal

Module manufacturers, model numbers, serial numbers, inverter details, and installation dates — we keep that record for every Powerlutions project. Because P.L. 2025, c.211 spreads responsibility across owner, producer, distributor, and manufacturer, that documentation lets you clearly identify the supply chain when it is time to remove or replace the system. It is the difference between a smooth refurbishment-versus-recycling decision and a scramble.

Talk to a Powerlutions advisor about your existing system

If you already have solar in New Jersey — installed by us or anyone else — and you are thinking about a roof replacement, a system upgrade, or simply want to understand how the new law affects your specific setup, we can help you plan the path forward. Email info@powerlutions.com or call 732-987-3939 and ask for an end-of-life-aware assessment. We will walk through your equipment, your ownership structure, and your options under P.L. 2025, c.211 — and we will tell you what you actually need to do today (often: keep your paperwork, watch for the NJDEP finding, and plan rather than panic).