Slip by six months the deadline by which, for photovoltaic installations over 10 kW, one must notify participation in a consortium for the disposal of WEEE.

This is provided for in the conversion into law of the Milleproroghe 2023 decree (dl Dec. 29, 2022, no. 198) now under consideration by the House after being approved by Palazzo Madama, where this amendment was introduced.

Article 11, paragraph 8-quater, introduced by the Senate, in fact stipulates that for photovoltaic systems with a nominal capacity greater than or equal to 10 kW, which entered into operation in the years from 2006 to 2012, the deadline by which the responsible parties may communicate the choice to participate in a collective system for the end-of-life disposal of the relevant materials is set at June 30, 2023.

Mite Directorial Decree No. 54 of August 8, 2022 (now sub judice at the Lazio Regional Administrative Court due to the appeal filed by the E-Cycle Consortium) stipulated that, in order to avoid the withholdings, plants should proceed no later than the last quarter of 2022 with the ex novo registration (€10/panel) or adjustment (estimated value of €6/panel) of the financial guarantee.

“It seems clear,” notes the E-Cycle Consortium in a note commenting on the new extension, “that the obligations imposed, for those wishing to avoid the deductions, were excessive with respect to the rationale and the dictate of Article 24-bis of Legislative Decree 49/2014 in that they were highly burdensome for operators. So it is highly likely that pressure from the latter and a feared flight from the model of managing WEEE through the Collective System, which is clearly less attractive under these conditions, have prompted Mase to revise the terms by giving some oxygen to the responsible parties. While only a first small step, toward an inevitable revision of the chatty August Gse Instructions, that bodes well.”