DS 22/2025: what it requires from solar plant owners

Supreme Decree (DS) 22/2025 sets the collection and valorization targets of Chile’s Extended Producer Responsibility law (Ley REP, Law No. 20,920) for portable batteries, electrical and electronic equipment and photovoltaic modules. It was published on 2026-05-07 and its targets are enforceable 24 months later, in May 2028. For modules the target starts at 10% in year three, in 2030, and reaches 50% in year ten, in 2037.

Updated October 9, 2026 · Reviewed by the EcoBaterías technical team.

Sources: DS 22/2025, Ministry of the Environment, Official Gazette (opens in a new tab) · Ministry of the Environment, Res. Ex. 3413/2025, final proposal of DS 22/2025 (opens in a new tab) (annual report) · 2026-09-26

The categories in the decree and their targets

DS 22/2025 is not a solar decree: it is the decree for electrical and electronic equipment, and photovoltaic modules are one of its categories. The distinction matters because the other categories share the same calendar and the same management systems as the modules.

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Sources: DS 22/2025, Ministry of the Environment, Official Gazette (opens in a new tab) · Carey summary (opens in a new tab) · País Circular, 2026-09-09 (opens in a new tab) · 2026-09-26

What is not in this decree are the large batteries. Units of 5 kg or more and every lead-acid battery fall under their own decree, still being drafted: the detail is in Chile’s EPR law and batteries. If your plant has modules and a storage system, you are dealing with two decrees and two calendars.

Why module targets are measured against estimated waste

For most priority products the target is measured against what the producer placed on the market. That does not work for photovoltaic modules: a panel installed in 2026 does not become waste that year or the next, but at the end of a power purchase agreement or of its technical life, two or three decades later. Measuring against annual sales would punish whoever grows and reward whoever stopped selling.

So the decree measures against the estimated waste of the year. The operational consequence is that estimating how many modules reach end of life stops being an academic exercise and becomes the basis of compliance.

• 756photovoltaic plants in operation covered by the analysis
• ≈34.9 millionmodules installed in Chile
• ≈1.0 Mtof modules that will reach the end of their service life
• 6,016 tof broken modules already generated

Source: EcoBaterías Solar Observatory · as of 2026-09-11

The flow does not arrive evenly. Between now and 2029 it runs at 55,000 to 80,000 modules per year, almost all of it breakage and replacement; in the years when supply contracts expire — 2030 and 2033 to 2035 — the range jumps to 400,000 to 850,000 modules per year. The Ministry of the Environment, for its part, estimates about 11,000 t of module waste in 2024, mostly from damage in transport, installation and operation: these are two different series with different methods, and they are not added together.

Sources: EcoBaterías Solar Observatory (as of 2026-09-11) and Ministry of the Environment, Res. Ex. 3413/2025 (opens in a new tab) · 2026-09-26

Who is the producer when the plant imports its own modules

A producer is whoever manufactures in Chile or first imports the product into the national market. In solar this happens far more often than people assume: when the project owner — or its EPC contractor, depending on how the contract is written — imported the modules directly, that party is the producer of those units, even if it never sold them to anyone.

The practical question is documentary rather than philosophical: whose name is on the import? That answer defines who carries the target, who must join a management system and who answers if decommissioned modules end up at an unauthorized site. It is worth settling before the first repowering, not after.

The annual report of industrial consumers

Law No. 20,920 and its decrees do not stop at producers: industrial consumers report too. Under the final proposal of DS 22/2025, industrial consumers of panels and photovoltaic installations above 1 MW will have to report every year to the RETC (Chile’s Pollutant Release and Transfer Register), before May 31, the panels in use, in units and weight, and their projected waste. For a plant that means keeping a record of how many modules were removed, which manager took them, under which transport document and which certificate came back for each batch.

Source: Ministry of the Environment, Res. Ex. 3413/2025, final proposal of DS 22/2025 (opens in a new tab) · 2026-09-26

In practice the record that serves for reporting is the same one that serves for an audit: dispatch notes, per-batch weighing, a test report when the module is reused and a valorization certificate when it is recycled. Without that file, the report is a claim with nothing behind it.

Management systems and the role of the authorized manager

A producer can comply through an individual management system, organized and financed on its own, or by joining a collective system that groups several producers. In both cases the system files its management plan with the Ministry of the Environment and contracts managers for collection, storage and treatment.

The manager is the link that turns a target into evidence. What you should demand is not a logo but documents: a current health permit for the waste stream to be received, authorized transport, per-batch weighing and a valorization certificate issued to the obligated party. Ask any manager you assess for those documents, including us: the status of our permits is published under compliance and permits, and the criteria to assess a manager are in what an authorized waste manager is.

Take-back duties for retailers

DS 22/2025 itself requires retailers of the products it covers to take back from the public end-of-life units equivalent to those they sell, without requiring a new purchase. That duty comes from the text of DS 22/2025 and should not be confused with the take-back duties proposed in the draft battery decree, which belong to a different instrument that is not yet in force.

For a module or equipment distributor the consequence is the same as for the producer: you need a manager under contract and a collection point with sensible storage conditions, because broken photovoltaic glass is sharp and a whole module is bulky.

How does a solar plant comply with EcoBaterías?

The route for a batch of decommissioned modules does not start at recycling: it starts at testing, because part of the batch usually still produces power. In a repowering, at least half of the removed modules are usually in good enough condition for reuse, according to the European QUASAR project.

1. Inventory the batch. Model, year, quantity, reason for removal and location. That determines whether to test at the plant or move the batch first.
2. Testing and grading. Every module is measured through solar panel testing and graded: P1 at 85% or more of nameplate power, P2 between 80% and 85%, P3 between 70% and 80% (off-grid uses, subject to SEC requirements) and below 70% to recycling.
3. Reuse, repair or recycling. Whatever clears the threshold follows the reuse route for decommissioned panels or is sold as a refurbished panel; whatever has a repairable fault goes to repair; the rest goes to solar panel recycling.
4. Pickup and traceability. We coordinate pickup with licensed hazardous-waste carriers, with a declaration document in SIDREP, Chile’s national hazardous-waste declaration and tracking system. Details are in battery and solar panel collection.
5. Certificate. Each batch receives the valorization certificate issued by the authorized receiving facility, which is what supports the report and the target.

Sources: grades P1–P3 from the EcoBaterías test protocol (our own classification, not a standard) · QUASAR D2.2, 2025 (opens in a new tab) · 2026-09-26

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If you also manage batteries, the applicable framework is in Chile’s EPR law and batteries, and the published price for recycling lithium-ion batteries, managed with authorized receiving facilities, is in the recycling price. Every service is listed in services for lithium batteries and solar panels, and market context is in the Chilean battery and critical minerals market.

Frequently asked questions

More answers in the FAQ on lithium batteries and solar panels.

Sources

• Ministry of the Environment, DS 22/2025, published in the Official Gazette (opens in a new tab) on 2026-05-07.
• Carey, decree setting collection and valorization targets for batteries and EEE (opens in a new tab) (2026).
• País Circular, photovoltaic panels, the only EPR target measured against estimated waste (opens in a new tab) (2026-09-09).
• Ministry of the Environment, Res. Ex. 3413/2025, final proposal of the decree on targets for batteries and EEE (opens in a new tab): annual report by industrial consumers and installations above 1 MW, and module waste by 2024.
• QUASAR project (EU), deliverable D2.2, reuse and repowering guide (opens in a new tab) (2025-06-11).
• Library of the National Congress of Chile, Law No. 20,920 (opens in a new tab).
• EcoBaterías Solar Observatory, as of 2026-09-11: plants, installed modules, end-of-life mass and estimated annual flow.
• Publishable figures and their attribution: datos/estadisticas.json from EcoBaterías, as of 2026-09-18.