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

Supreme Decree (DS) 22/2025 sets the collection 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 on 2026-09-18 · Reviewed by the Ecobaterías technical team.

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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Source: DS 22/2025, Ministry of the Environment, Official Gazette (opens in a new tab) · 2026-09-18

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 on the order of 11,000 t per year of early module waste: these are two different series with different methods, and they are not added together.

Sources: Ecobaterías Solar Observatory (as of 2026-09-11) and the Ministry of the Environment (opens in a new tab) · 2026-09-18

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. For a solar 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.

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. Ecobaterías runs its plant in Santiago with a health permit from the Seremi de Salud (Chile’s regional health authority) of the Santiago Metropolitan Region for the hydrometallurgical process.

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 a solar plant complies 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 within its power band.

1. Inventory the batch. Model, year, quantity, reason for removal and location. That determines whether testing happens on site or at the plant.
2. Testing and grading. Every module is measured and graded: P1 at 85% or more of nameplate power, P2 between 80% and 85%, P3 between 70% and 80% (off-grid systems only) and below 70% to recycling.
3. Reuse or recycling. Whatever clears the threshold follows the testing and reuse route for used modules; the rest goes to recovery.
4. Certificate and traceability. Each batch receives its valorization certificate with the associated traceability, which is what supports the report.

If you also manage batteries, the applicable framework is in Chile’s EPR law and batteries, and the published lithium-ion intake price is in the intake price. Market context is in the Chilean battery and critical minerals market.

Frequently asked questions

When do the DS 22/2025 targets become enforceable?

The decree was published in the Official Gazette on 2026-05-07 and its targets are enforceable 24 months later, that is, from May 2028. For photovoltaic modules the first target lands in year three, in 2030.

My plant imported its own modules. Am I a producer?

Yes. A producer is whoever manufactures in Chile or first imports the product into the national market, even if it never sells it. A solar plant that imported its own modules is the producer of those units and answers for their targets.

Are the storage system batteries covered by DS 22/2025?

No. Batteries of 5 kg or more and every lead-acid battery fall under the battery decree, which is still being drafted. DS 22/2025 covers portable batteries, electrical and electronic equipment and photovoltaic modules.

What are photovoltaic module targets measured against?

Against the estimated waste of the year, not against what was placed on the market. It is the only reasonable way to measure a product installed today and removed twenty or thirty years later.

What evidences compliance?

The valorization certificate for each batch, with its traceability: who collected the modules, how many there were, how much they weighed and what was recovered. Ecobaterías issues that document with every intake.

Sources

• Ministry of the Environment, DS 22/2025, published in the Official Gazette (opens in a new tab) on 2026-05-07.
• 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.
• Ministry of the Environment (opens in a new tab), estimate of early photovoltaic module waste.
• Publishable figures and their attribution: datos/estadisticas.json from Ecobaterías, as of 2026-09-18.