New Jersey Solar Panel Recycling: What S3399 Requires
New Jersey's landfill ban took effect January 2026. Here's what installers and system owners must do — and how Sunpliance generates the Certificate of Recycling the DEP requires.
See the Certificate in actionWhat the Law Requires
S3399 took effect January 2026
Statewide enforcement: landfill ban on all pv modules applies to all PV modules
Installers and system owners carry the compliance obligation — not manufacturers
Panels must be routed to a NJ DEP-approved recycling facility
A Certificate of Recycling must be filed with the DEP upon decommissioning
Non-compliance exposes operators to dep enforcement action
Who Is Responsible
New Jersey is different from states like California and Washington, where extended producer responsibility (EPR) programs push liability onto panel manufacturers. In New Jersey, the installers and system owners hold the obligation on every job.
That means every contractor doing decommissioning work in New Jersey needs documentation on every job — not just the large ones, not just commercial arrays. The obligation travels with the panel.
What a Certificate of Recycling Actually Means
It's not a form you fill out — it's a documented chain of custody. A defensible certificate must demonstrate:
- Panel origin — where the modules were removed from
- Date of removal and identity of the removing crew
- Transporter identity and handoff timestamps
- Receiving recycler and confirmation of acceptance
- Final disposition — recycling, reuse, or hazmat routing
Sunpliance produces NJ DEP-compliant Certificates of Recycling automatically when you close a job.
How Sunpliance Handles New Jersey Compliance
AI-assisted panel capture at removal — serial, manufacturer, condition recorded in seconds
Chain of custody tracked through every handoff: removal → transport → recycler receiving
S3399-ready Certificate generated as PDF at job close with full audit trail
Certificates stored 7 years by default — exceeds NJ DEP retention expectations
Your documentation is audit-ready from day one.
New Jersey vs. Other States
| New Jersey | California | Washington | |
|---|---|---|---|
| Mandate type | Landfill ban + recycling certificate | Universal Waste classification | EPR manufacturer takeback |
| Responsible party | Installer & system owner | Handler / generator | Manufacturer |
| Documentation required | Certificate of Recycling filed with DEP | 3-year shipment records + annual reporting if >5,000 kg | Stewardship plans + annual reports |
| Effective date | January 2026 | January 2021 | 2030–2031 |
| Penalty exposure | DEP enforcement | Up to $70,000 / day | Up to $10,000 per sale |
New Jersey
- Mandate type
- Landfill ban + recycling certificate
- Responsible party
- Installer & system owner
- Documentation required
- Certificate of Recycling filed with DEP
- Effective date
- January 2026
- Penalty exposure
- DEP enforcement
California
- Mandate type
- Universal Waste classification
- Responsible party
- Handler / generator
- Documentation required
- 3-year shipment records + annual reporting if >5,000 kg
- Effective date
- January 2021
- Penalty exposure
- Up to $70,000 / day
Washington
- Mandate type
- EPR manufacturer takeback
- Responsible party
- Manufacturer
- Documentation required
- Stewardship plans + annual reports
- Effective date
- 2030–2031
- Penalty exposure
- Up to $10,000 per sale
Frequently asked questions
Does S3399 apply to residential solar systems?+
Yes — all PV modules regardless of system size or ownership type. Residential decommissioning is covered by the same landfill ban as commercial and utility-scale work.
What happens if I don't file a Certificate of Recycling?+
Installers and system owners face DEP enforcement action. There is no exemption for small jobs, and the obligation travels with the panel regardless of system size.
Which recyclers are DEP-approved?+
NJ DEP maintains an approved facility list. Sunpliance maintains an in-app recycler directory linked to approved facilities so field crews never have to guess whether a handoff counts.
Does Sunpliance work for contractors operating in multiple states?+
Yes — Sunpliance handles NJ, CA, and WA compliance requirements from one platform. The chain-of-custody record is the same; the certificate output adapts to each state.
How long do I need to keep recycling records?+
NJ DEP requires retention of decommissioning records. Sunpliance stores all certificates and chain-of-custody records for 7 years by default — exceeding typical state retention expectations.
See Sunpliance in Action
We'll show you how a full NJ decommissioning job documents itself — from panel capture to Certificate of Recycling.