Glass for Europe: contribution to consultation on policy options as regards photovoltaic panels

Glass products not only provide light, comfort, style, security and safety, they are also essential to energy-efficient buildings, houses and transport. Windows containing high-performance glass such …

Glass products not only provide light, comfort, style, security and safety, they are also essential to energy-efficient buildings, houses and transport. Windows containing high-performance glass such as low-e insulating glass, which helps keep warmth in, and solar-control glass, which reflects unwanted heat away, help reduce energy consumption. Solar-energy glass helps enhance the production of renewable sources of energy. Better use of building glass alone could help reduce Europe“s CO2 emissions by 100 million tonnes annually hence Glass for Europe“s plea for an ambitious and robust European energy-efficiency policy. Glass for Europe would like to take the opportunity offered by this consultation to remind European policy makers of the strong commitment of the flat glass industry to the recycling of flat glass products, some of which are used in photovoltaic modules (PV). In fact, glass recycling has the greatest environmental benefits since it helps the flat glass industry to further reduce its energy consumption and associated CO2 emissions. From a sustainable policy standpoint, it makes only sense to our industry that products aimed at providing renewable sources of energy are properly recycled. On average, one tonne of cullet saves 230kg of CO2 and one tonne of raw materials. In order to increase the recycling rate of products deriving from flat glass, it is necessary to develop stable and efficient waste management infrastructures across the EU for the collection and treatment of PV modules. Flat glass manufacturers are ready to contribute to this work thanks to their expertise in recycling, particularly in automotive glass which is an equally complex glass product integrated to other components to offer a final product. Against this background, Glass for Europe would like to make the following comments on the policy options suggested in the report. Glass for Europe disagrees with the policy recommendation expressed in the Study on photovoltaic panels supplementing the impact assessment for a recast of the Waste Electrical and Electronical Equipment Directive (WEEE)“ and urges the Commission to support the moves being proposed by the industry to further strengthen an industry led recycling scheme. This position finds its roots in the concerns expressed below. Glass for Europe members are aware of the importance of glass in the mass of a photovoltaic panel and are therefore willing to take their share of the recycling responsibility. Glass for Europe would nevertheless like to stress that PV module recycling should not all be centred on glass as they are other components originating from other suppliers, which should even more so be recycled due to their rare or hazardous nature. These other products are not necessarily integrated by glassmakers. Regardless of instruments put in place to achieve high recycling rates and regardless any legal responsibility, it is important to involve all industry stakeholders to guarantee maximum recycling. Glass for Europe disagrees with the proposal to include all photovoltaic panels in the scope of the WEEE Directive. It must be borne in mind that this EU directive was never intended to cover such kind of products, which are not domestic portable“ equipments but should rather be considered as installed“ products which become part of buildings. It must be highlighted in this context that attempts to establish standards on building integrated photovoltaic are a joint effort of the electronic industry and the construction industry. As a result, Glass for Europe believes that the treatment of domestic photovoltaic panels should not be regarded as a simple extension of existing domestic electronic equipment. All the more, due to the integration of PV modules within construction, one can actually question the optimistic assumption that legislation would de facto achieve an 85% collection rate as of 2030. Glass for Europe would like to draw the Commission“s attention on the fact that a mere extension of the WEEE Directive to cover other hybrid“ types of products such as PV modules could jeopardise the credibility of this policy instrument by creating many legal and practical difficulties. Glass for Europe deplores the fact that the proposals made by the industry (PV Cycle) of a voluntary collection and recycling scheme for the photovoltaic industry have been disregarded. In the study, the industry appears to be criticised because it has not yet reached a final position on the legal structures required to make an industry led initiative work for an issue that has not yet arisen and is unlikely to become a major issue for the next 10 years. It must be borne in mind that this is a new industry willing to engage positively to resolve a future issue. Different projects are being tested and all initiatives involve all parts of industry to make sure that workable and efficient schemes can be put in place. The rejection of the proposal to establish an industry led recycling scheme is premature given the willingness and already demonstrated efforts of the photovoltaic industry to transform the recycling of PV module into a reality. Glass for Europe believes that what matters most in today“s infancy period is to develop practical and efficient recycling solutions and that this objective should prevail over any juridical debate on the comparative added-value of legal requirements versus industry-led initiative. Glass for Europe is convinced that a more cooperative approach is likely to be more fruitful to establish a viable and robust solution. As stability is key to the development of recycling infrastructures, a suitable solution would be for regulators to support and, if deemed appropriate, to advice the industry on its current programmes. Only such a cooperative approach would support the development of both recycling and the European PV industry. It is all the more important that hurdles on the development of PV should be avoided to guarantee coherence with other EU policies on energy and climate change. Glass for Europe believes that the EU should focus first on the development of practical solutions and second assess their impact when they reach a scale allowing proper conclusions and return of experience. Only at this stage, may legal obligation usefully complement industry initiative with tangible chances of providing concrete results. Glass for Europe is the trade association for Europe“s manufacturers of flat glass. Flat glass is the material that goes into a variety of end-products and primarily in windows and faades for buildings, windscreens and windows for automotive and transport as well as glass covers, connectors and mirrors for solar-energy equipments. It is also used in smaller quantities for other applications such as furniture, appliances, electronics, etc. Glass for Europe has four members: AGC Glass Europe, NSG-Group, Saint-Gobain Glass and Sisecam-Trakya Cam and works in association with Guardian. Altogether, these five companies represent 90% of Europe“s flat glass production.