Solar Panel Regulations in the European Union: An Overview

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Solar Panel Regulations in the European Union: An Overview
Solar panels imported or manufactured in the European Union are subject to various regulations, directives and standards. Ensuring compliance requires that the solar panels meet certain technical requirements. In addition, solar panels must be correctly labelled, documented, and tested.

This guide explains how requirements from regulations and directives, such as the General Product Safety Regulation and the Low Voltage Directive, apply to solar panels sold in the European Union.

Note: This guide only covers solar panels (also referred to as “solar modules” or “photovoltaic modules”). It does not cover the entire solar or photovoltaic system, which may contain components such as frames, battery packs, and inverters.


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General Product Safety Regulation

The General Product Safety Regulation sets safety requirements for consumer products. This would include solar panels, which may be subject to requirements concerning their mechanical safety – for instance, ensuring that the solar panels are securely affixed to a roof and do not result in the product falling off (e.g. due to snow).

Solar panels may also be subject to electrical safety requirements under the regulation, if they are designed for use under 50 volts AC and 75 volts DC (while electrical safety of equipment with an higher voltage is covered by the Low Voltage Directive). Note that during our research, we found that most solar panels, or solar modules, operate under 50 volts.

The regulation generally mandates that you:

a. Test your products against relevant standards to make sure they comply with the regulatory requirements

b. Provide user instructions and technical documentation

c. Label your product (e.g. with traceability information, warnings, and age suitability)

Standards

The General Product Safety Regulation mandates that you use harmonised standards when they exist. Following harmonised standards requirements allows you to ensure that your product complies with the requirements set by the regulation.

We could not find any solar panel standards that are harmonised under the regulation. In this case, you should still use relevant EN standards to ensure product compliance. The next section covers several examples of EN standards for solar panels.

Documentation

This section lists the key documentation requirements set by the regulation.

Title Description
Technical documentation The regulation requires you to provide technical documentation, which should contain:

  • The product’s description
  • The product’s essential characteristics
  • Potential risks and mitigations for the product
  • List of applied standards
  • Test reports
Instructions and safety information You should provide instructions and safety information with your product regarding its:

  • Assembly
  • Installation
  • Use
  • Maintenance
  • Safe use
  • Disposal
Register of complaints Importers and manufacturers should keep a register of complaints – e.g. sent by their customers – about defective and dangerous products.

They can then use the information to investigate possible compliance issues.

Test reports Solar panels need to undergo testing against the requirements of the regulation and applicable standards. The regulation mandates the provision of a test report as part of the technical documentation.

Labelling requirements

The regulation requires you to correctly label your product, packaging, or accompanying documents, such as the instruction manual.

Title Description
Product traceability information
  • Manufacturer name, registered trade name, or trademark
  • Manufacturer electronic and postal address
  • Product type, batch, or serial number
Warnings You should provide product-specific warnings with your product. Note that some warning requirements may come from certain standards.

Standards for solar panels

This section lists several examples of standards for solar panels. Some standards set requirements such as those for performance, mechanical safety (e.g. load tests), and electrical safety. Note that you can find more solar panel standards on the CENELEC website.

EN IEC 62938 – Photovoltaic (PV) modules – Non-uniform snow load testing

EN 62716 – Photovoltaic (PV) modules – Ammonia corrosion testing

EN IEC 61215-1-1 – Terrestrial photovoltaic (PV) modules – Design qualification and type approval – Part 1-1: Special requirements for testing of crystalline silicon photovoltaic (PV) modules

EN IEC 61215-1-2 – Terrestrial photovoltaic (PV) modules – Design qualification and type approval – Part 1-2: Special requirements for testing of thin-film Cadmium Telluride (CdTe) based photovoltaic (PV) modules

EN IEC 61215-1-3 – Terrestrial photovoltaic (PV) modules – Design qualification and type approval – Part 1-3: Special requirements for testing of thin-film amorphous silicon based photovoltaic (PV) modules

EN IEC 61215-1-4 – Terrestrial photovoltaic (PV) modules – Design qualification and type approval – Part 1-4: Special requirements for testing of thin-film Cu(In,GA)(S,Se)2 based photovoltaic (PV) modules

Low Voltage Directive

The Low Voltage Directive establishes requirements for electrical equipment that operates between 50-1000V AC. and 75-1500V DC. As such, it would apply to solar panels – or their systems – that operate between those voltage ranges.

The directive generally requires you to ensure that:

a. Your products comply with the safety requirements in order to do no pose a danger to humans, property, or pets when used as intended

b. You perform the necessary testing to prove compliance

d. Affix the CE marking and traceability information

e. Prepare necessary documentation (Declaration of conformity, technical file, instructions)

Harmonised standards

We could only find the following two harmonised standards that focus on solar panels (or photovoltaic modules):

EN IEC 61730-1 – Photovoltaic (PV) module safety qualification – Part 1: Requirements for construction

EN IEC 61730-2 – Photovoltaic (PV) module safety qualification – Part 2: Requirements for testing

Note that we found more standards, but they cover entire solar panel systems or related components.

Documentation

Here are the key documentation requirements set by the directive.

Title Description
Declaration of Conformity The directive requires importers and manufacturers to create a Declaration of Conformity, which should contain the items listed in Annex IV.
Technical documentation The manufacturer needs to create and provide technical documentation, which should contain the items listed in Annex III.
User instructions The directive requires the provision of user instructions with the product. The user instructions need to be clearly written.
Test report Manufacturers need to provide test reports as part of the technical documentation.

Labelling

Here are the labelling requirements that we found in the directive.

Title Description
CE marking CE mark

The directive mandates manufacturers to permanently affix the CE marking to each electrical equipment or its data plate or its packaging and accompanying documents.

Traceability information
  • Product type, batch, serial number
  • Manufacturer name, registered trade name or trademark
  • Manufacturer postal address

Electromagnetic Compatibility (EMC) Directive

The Electromagnetic Compatibility Directive sets requirements for the electromagnetic compatibility of electronic apparatus and fixed installations. This may include solar panels.

‘Apparatus’ means any device or combination sold as a single unit for end-users that can cause or be affected by electromagnetic disturbance. ‘Fixed installation’ refers to a combination of various devices assembled and installed for permanent use at a specific location.

You need to ensure that the covered products:

a. Meet the essential requirements set out by the regulation

b. Undergo a conformity assessment and product testing

c. Are accompanied by appropriate documentation:

  • Declaration of Conformity (DoC)
  • User instructions
  • Technical documentation
  • Test reports

d. Are labelled with:

  • CE marking
  • Product type, batch, or serial number
  • Name, registered trade name or trademark
  • Postal address
  • Contact information

Note that the EMC Directive guidance document specifically mentions that you need to provide instructions for the installation, use, and maintenance of solar or photovoltaic systems. For fixed installations, the accompanying documentation should indicate its electromagnetic compatibility characteristics and precautions taken while incorporating the device into a fixed installation.

RoHS Directive

The RoHS Directive restricts the usage of some substances in electric and electronic equipment. However, it exempts from its requirements professionally installed photovoltaic panels used for permanent energy production at defined locations for residential, commercial, and other applications.

Though the directive exempts certain solar panels from its requirements, those requirements may still apply to:

  • Solar panels that do not fit the above definition
  • Electronic accessories or components that come with the panel

The directive mandates that you ensure that your products:

a. Comply with the substance restrictions listed in Annex II

b. Undergo lab testing to ensure compliance

c. Come with the following applicable documentation:

  • Declaration of Conformity (DoC)
  • Technical documentation
  • Test report

d. Are properly labelled with:

  • CE marking
  • Product type, batch, serial number
  • Manufacturer name, trade name or trademark
  • Manufacturer address and contact information

Waste Electrical and Electronic Equipment (WEEE) Directive

WEEE Mark

The WEEE Directive sets requirements regarding the management of electronic and electrical waste products and materials. As such, it would also apply to solar panels.

The directive requires importers and manufacturers to:

a. Affix the separate collection symbol onto their product

b. Provide information to users (e.g. regarding product disposal)

c. Register in the EU member state where they sell their product

d. Submit to the national authorities a report containing the quantity and type of product they manufacture, distribute, and sell

e. Take responsibility for collecting and treating their waste products (e.g. by using a waste management company)

Recalls and compliance risks

Solar panels may pose risks and cause injuries to people if they do not comply with safety requirements, such as those outlined in this guide. Non-compliant solar panels would be subject to recalls from the market.

The EU’s Safety Gate website features examples of recalled solar panels and the reasons for the recall. For instance:

a. Solar panel from China – recalled for violating the RoHS Directive

b. Solar panel from the Netherlands – recalled for violating the Low Voltage Directive

c. Solar panel from China – recalled for potential fire and burn risk caused by electrical arc due to incorrectly connected cables

Lab Testing

Some regulations and directives, such as the Low Voltage Directive, require products to undergo testing. Other regulations may not specifically mandate it. Nevertheless, you should still test your product against appropriate standards and regulatory requirements to make sure your product is safe. If your product passes testing, you should receive a test report that proves your product complies with the requirements.

Regulation Lab testing
General Product Safety Regulation The regulation generally requires that you subject your products to testing to ensure electrical and mechanical safety, for instance. Here are some examples of tests that solar panels can undergo:

  • High temperature testing
  • Component testing
  • Non-uniform snow load testing
Low Voltage Directive The directive mandates that you comply with electrical safety requirements. Here are several examples of tests that photovoltaic modules should undergo:

  • Electrical shock hazard test
  • Fire hazard test
  • Mechanical stress test
  • Environmental stress test
Electromagnetic Compatibility Directive The directive requires covered products to undergo testing to prove that they are electromagnetically compatible with other electric and electronic products and immune to external radio emissions from other devices.
RoHS Directive The directive mandates that you subject your electrical and electronic products to tests to make sure that they do not contain restricted substances over the limits specified in Annex II.

For instance, you should have your solar panels tested to prove they do not contain more than 0.01% of cadmium.

Solar panel testing companies

Here are several companies that claim that they can test solar panels to some of the above standards, directives, and regulations:

  • Intertek
  • SGS
  • TÜV Rheinland
  • Eurofins
  • TÜV Nord

Additional Requirements

This section lists other regulations that may apply to solar panels.

Regulation Description
REACH Regulation This regulation sets substance restrictions on articles, which would include solar panels. Solar panels may contain restricted substances such as:

  • Lead
  • Cadmium)
  • Chromium VI
Construction Products Regulation This regulation sets requirements for construction products, which are defined as any item or kit made for permanent use in construction that would affect its performance.

Given the definition, it may be possible that the regulation could apply to some types of solar panels, even though we were not able to find:

a. Any harmonised standards for solar panels

b. Any mention of solar panels or similar products in the product areas listed in Annex IV.

POPs Regulation The Persistent Organic Pollutants (POPs) Regulation sets restrictions on POPs and products that may contain those substances.

For instance, solar panels or photovoltaic modules may contain:

  • PCB
  • PFOS

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    Disclaimer: The Site cannot and does not contain legal advice. The legal information is provided for general informational and educational purposes only and is not a substitute for professional advice. Accordingly, before taking any actions based upon such information, we encourage you to consult with the appropriate professionals. We do not provide any kind of legal advice. THE USE OR RELIANCE OF ANY INFORMATION CONTAINED ON THE SITE IS SOLELY AT YOUR OWN RISK.

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    Sources: Our articles are written in part based on publicly available information, and our own practical experience relating to product compliance. These are some of the primary sources we use:

    • European Commission - europa.eu
    • EUR-Lex - eur-lex.europa.eu
    • European Chemicals Agency - echa.europa.eu
    • eCFR - ecfr.gov
    • U.S. Consumer Product Safety Commission - cpsc.gov
    • U.S. Federal Trade Commission - ftc.gov
    • U.S. Federal Communications Commission - fcc.gov
    • GOV.UK
    • Legislation.gov.uk
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