Extended Producer Responsibility Implementation Differences between American and European Solar Waste Management Policies

This paper inventories American and European implementations of extended producer responsibility (EPR) solar waste management programs in order to understand the factors responsible for effective waste collection and successful collection financing by producers. Analysis of the legislation reveals that American solar waste policy places almost all of the onus of waste collection on producers, while European countries more tightly integrate collection with existing municipal systems. Earlier research has shown that the integrative approach is associated with collection efficacy, while the producer approach better shifts costs onto producers. These results suggest a similar split in outcomes might emerge from the differences between the European and American policy implementations; policymakers introducing solar waste management ought to consider which outcome is preferred and apply the corresponding European or American system as a model to guide legislation. In addition, the findings show generally more comprehensive regulations from the European policies, including guidelines on product design and consumer protections not found in American policy.