Frequently Asked Questions

Why was the NTSA founded?

Solar photovoltaics (PV) is one of the key industries in the 21st century and at the forefront of a multi-billion clean and green technology sector that seeks solutions to the critical environmental issues that threaten the planet. The solar PV industry has seen tremendous growth in the past decade and continues to expand. Given the projected high growth rates of solar cells and installations globally, it is critical that the solar PV industry itself is truly safe and sustainable.

NTSA was founded to promote such thinking in the European Union after many conversations with policy makers, scientists and NGOs who were concerned about attempts to reach an exclusion for the solar industry from the critical EU environment Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment 2002/95/EC (RoHS).

What is NTSA e.V.'s budget and how is it funded?

For NTSA e.V.'s budget please see our entry in the voluntary EU Register of Interest representatives. NTSA's costs have been covered by Bohnen Kallmorgen & Partner who regard this as a good long-term investment in the right cause and for their positioning in the solar sector.

The Research Group of the NTSA operates separately from NTSA e.V., both financially and legally. Members of the Research Group do not receive any financial compensation or financial benefits from NTSA e.V.

What kind of substances is NTSA concerned about?

NTSA is calling on the European Union and the solar industry to endorse regulation that substitutes all toxic materials currently used in the production of PV modules with non-toxic alternatives, as soon as possible

Why should solar photovoltaic (PV) panels be included in the RoHS directive if there are no risks?

Lead, Cadmium as well as its compounds Cadmium-Sulfide and Cadmium-Telluride are scientifically classified as "toxic" or “harmful” by the EU Dangerous Substances Directive (67/548/EEC).

The use of toxins in PV modules could lead to unforeseeable risks for the environment, society and the economy. An inclusion in RoHS seems logical in particular as the need to shift towards renewable energy sources will increase demand for solar panels and hence toxic substances unless properly regulated. Based on current scientific knowledge, the safe usage of toxic substances in PV modules cannot be guaranteed. There are no independent public studies available that prove with certainty that the use of toxic substances in PV modules constitutes no risk. Risk factors to be considered include leakage, breakage and fire, as well as washout in sour and alkaline water.

Aren’t current recycling schemes for solar panels sufficient to take care of any toxic substances?

All producers should adhere to voluntary industry initiatives for the recycling of solar cells. However, industry efforts for recycling PV modules containing toxic materials require a sufficient safety guarantee. Doubts arise because of the potentially inadequate volume of the necessary financial provisions. Keeping modules containing toxic substances in a closed cycle over decades constitutes a significant challenge.

ChemSec, The International Chemical Secretariat, a reputable non-profit organization working for a toxic free environment, shares this view: “A closed loop for toxics in PV products can never be guaranteed."

Most importantly, without RoHS covering the PV industry, low-standard manufacturers will be encouraged to use technologies containing toxic materials. Such producers may have little incentive to comply with voluntary standards, neither at the production stage nor at the end of the long life cycle of PV products.

Do we already have clean solar alternatives that do not rely on the use of toxins?

There are many PV technologies in compliance with RoHS that do not contain any of the toxic materials currently restricted by the directive. It is important to understand, that Cadmium Telluride (CdTe) is only one of several thin film technologies available. There are viable alternatives besides crystalline Silicon such as amorphous Silicon or cadmium free CIS/CIGS available right now and more manufacturers are getting ready to enter the market. RoHS should be about safety as well as supporting technological progress and about giving incentives to substitute toxic substances wherever possible.

Manufacturers of non-toxic solar technologies may suffer competitive disadvantages from the current regulatory environment. A level playing field is needed, where all are treated fairly by the same standards. A consequent application of the logic of the RoHS recast would have accelerated and strengthened research and development in non-toxic PV technologies. As their volumes increase, cleaner technologies will be producible at the same or even lower costs than those relying on toxins.

Doesn’t advocating inclusion of panels in the directive divide the solar industry and compromise the EU’s climate goals?

It is ironic that, of all sectors, cleantech and renewable energy are excluded from environmental legislation such as RoHS. The solar industry should be at the vanguard of compliance with the highest environmental standards. Differences of opinion exist in every industrial sector and the PV industry will emerge strengthened from this debate. A well-regulated non-toxic PV industry has both capacity and know-how to meet the EU’s 2020 climate goals. A future inclusion of PV panels under RoHS will have no adverse effects on the industry’s ability to meet demand. The existence of large overcapacities in the short run, and the availability of competing alternative technologies will allow for a strong carbon-free power generation capacity.

What about the carbon-footprint?

All PV manufacturers should be encouraged to reduce the energy required to manufacture solar cells, but a so-called “carbon-footprint” is not the right benchmark for the ecological impact of PV-technologies, as the local energy-mix used for production is the key to the amount of CO2 produced.

Module production in countries with a high percentage of fossil fuels, such as Australia, Denmark or the Netherlands, will result in a large carbon-footprint, while production in Norway for instance, a country that covers its energy needs almost entirely by hydropower, will result in close to zero CO2 emissions. Furthermore, an evaluation of the energy needed to produce a module, depends heavily on the primary and intermediate products used as well as the steps of the life-cycle and disposal actually incorporated into the calculation.

How does inclusion of PV panels in RoHS effect global market development?

The renewables industry will continue to be successful through its high capacity for technological innovation and our common understanding that we need to reduce CO2 emissions in the EU and worldwide. By setting the right standards, the EP will create an incentive for the PV sector to be at the leading edge of technology. As clean technologies become more and more available they are also scrutinized by the end-consumer. Those who choose to invest in green technologies deserve to know that the products they buy comply with EU environmental regulations and are correctly labeled. What is a requirement for every household appliance should also be applied to solar panels installed on roofs and on the ground. Rather than asking for exclusions the renewables industry should set environmental standards by committing not to use toxic substances.

The rules we set in the EU are closely followed by partners in Asia and the US. Early adoption of high environmental standards will secure a leading position for EU businesses at home and abroad and allow consumers to make their choice for renewable energy generation with the greatest confidence.

Why should any phase-out of toxins in photovoltaics be as short as possible?

There are indications that manufacturers of Cadmium Telluride cells may be devoting resources towards alternative technologies such as CIGS. RoHS should set incentives to support this path. Exempting the entire solar industry or allowing a transitional phase of ca. eight years or longer allows low-standard manufacturers to continue using toxic substances while others seem to be making the transition to clean and non-toxic PV. A sufficiently short phase-out of maximum three years would have been long enough to safeguard companies’ interests as they plan the transition and short enough to incentivize change.