Activ Group supports solar stewardship. Let’s make it open, independent and start it now.

By Helen Jarman, Founder and CEO, Activ Group | 11 November 2026 | 12 min read

Activ Group supports mandatory solar stewardship in Australia. Solar stewardship can’t wait. Activ Group is calling for a national approach that accelerates panel recycling, encourages competition and innovation, and builds on systems already in place. Our framework sets out a practical way forward.

Australia needs solar stewardship, and we need to get it right. Now.

Australia urgently needs an effective solution for end-of-life solar panels. As solar deployment continues to accelerate, so does the volume of panels that will need responsible collection, transport, reuse and recycling. Every month without a national scheme, more panels go to landfill, into stockpiles or overseas, sending valuable resources with them.

At Activ Group, we believe stewardship plays an essential role in solving this. But we also think it’s important to ask a difficult question:

Are we designing a system that maximises collection and recycling outcomes, with the whole industry taking part, innovating and building for the future? Or one that creates unnecessary cost, administration and market distortion?

That question led us to develop and publish our Solar Stewardship Framework.

Why we published our solar industry stewardship framework now

Australia is at a turning point. Decisions about how solar stewardship will work are being made now, and once this scheme’s design is set, some unintended consequences are set with it. They are hard and slow to undo.

We have a small window to get this right. Solar is too important an industry, and end-of-life panels too important a problem, to settle for the bare minimum.

Our view comes from experience, not commercial interest. This is the seventh product stewardship scheme we’ve been involved in, and we’ve seen what happens when design flaws are built in from the start. We can see the same patterns emerging in solar.

We fully support the Department and the consultation process. We are giving Ministers the independent, whole-of-industry advice they deserve. Collectors, transporters, installers, reuse operators, asset owners and households all have a stake in solar stewardship, and all of their voices need to be heard alongside recyclers.

“We’re not raising this issue to slow anything down. We’re raising it because there’s only a small window to get it right, and we’ve seen what happens when it’s missed.”

Helen Jarman, Founder and CEO, Activ Group

Activ Group supports solar stewardship: clearing up the biggest misconception

The most common misconception about our position is that we’re against stewardship.

We’re not. Activ Group does not oppose stewardship. Activ Group supports mandatory stewardship: national, enforceable and starting as soon as possible.

Our position isn’t a commercial play, and we’re not here to be a blocker. We’ve spent 28 years making stewardship work, and we take seriously our responsibility to speak up when we see a better way.

We support:

• Responsible end-of-life management
• Higher collection, recovery and recycling rates
• Strong, independent oversight and reporting
• Chain-of-custody requirements
• Landfill diversion
• Accredited collectors, reuse operators and recyclers
• Data transparency, tracking and reporting
• Industry accountability, with checks and balances built in

Our framework doesn’t argue against stewardship. It contributes to the discussion about how stewardship should work.

What stewardship means to Activ Group

We all agree on the principles. The healthy debate is about how we get there, and that debate is part of good policy-making.

For us, stewardship isn’t one thing. It’s a value shared, in different forms, by everyone in the solar supply chain, from manufacturers and installers to collectors, recyclers and asset owners. It needs to be designed for each product, learn from the schemes that came before it, and keep evolving. There’s no one-size-fits-all model, and stewardship shouldn’t default to a tax on compliance.

Our track record in product stewardship

We helped set up the National Television and Computer Recycling Scheme (NTCRS). We sat on its stakeholder reference group, contributed to its standards and were the only party who could provide eight years of real-time data. We helped build an important scheme, which initially worked well in practice. As a part of this, we also established ANZRP and TechCollect.

We’ve stayed committed to that goal for decades, and built our business model on innovation, research and development, and fair play.

Two principles every solar stewardship scheme needs

Our framework isn’t all or nothing. Each design element stands on its own and can be adopted independently, within a levy-funded scheme or any other. Take what works.

But two principles shouldn’t be compromised in any model:

1. Independent oversight. The scheme should be overseen by a truly independent body at the level of a national EPA, working with the Clean Energy Regulator’s existing records. That oversight shouldn’t sit with a recycler, a commercial operator or an industry body.
2. Open participation. Every provider that meets the standard should be able to take part: collectors, transporters, assessors, reuse operators and recyclers. Closed procurements led by a single, powerful administrator decide winners and losers, and leave much of the industry on the sidelines.

With independent oversight and clear rules in place, a scheme doesn’t need multiple network operators or complex arrangements to manage competition. The guardrails do that job. That keeps costs down and lets the scheme adapt as the market changes, with regulation updated only where it needs to be.

Why Activ Group has concerns about levy-funded stewardship

Our concern isn’t the objective. It’s the mechanism.

Many stewardship schemes are set up with the best intentions. But experience across several industries shows that levy-funded schemes can bring unintended consequences:

• Locked markets, where an administrator decides the winners and losers
• Less competition, and less incentive to innovate and invest
• Price distortion, with levies set too high or too low
• More administration and higher compliance costs
• Slow, cumbersome mechanics that are hard to correct or future-proof
• Less equity, and less of a voice for smaller participants

For solar, those risks land on everyone. A levy on new solar adds cost for the families and businesses installing panels, at a time when cost of living matters. Pricing that’s wrong can push compliant operators out of the market altogether.

A Queensland pilot reporting put costs at about $38–$90 per panel before IT and administration. That’s several hundred dollars on a typical 8–12 panel home system, and several times today’s recycling gate fees of around $5–$15 per panel.

The biggest risk isn’t the idea of a levy. It’s how slowly a levy corrects. In voluntary schemes we’ve worked in, a contribution set too low at the start took years to fix. By then the market had moved: compliant collectors had dropped out, and operators large enough to absorb the shortfall had gained ground that others couldn’t recover.

If a levy is chosen, it should be set at full cost from day one and reviewed often.

What experience has taught us

We helped build the NTCRS, and in its early years it worked well. Many of the problems people raise today came later, as arrangements changed and the market consolidated. We can see the same risks in how solar stewardship is being shaped.

B-cycle, Australia’s battery stewardship scheme, got important things right. But limited recycler participation, administrator decisions and early market arrangements shaped who could compete, and how.

What Activ Group proposes: the model in plain English

Get the rules right first. Then let the market deliver.

Activ Group isn’t proposing less regulation. We’re proposing different regulation. Government sets the principles and the mechanics: who is responsible, what standard must be met and how recovery is verified. Accredited providers then compete to deliver collection, logistics and recycling. Government shouldn’t need to design the trucks and the routes; a competitive market will find better ways to do that.

Here’s how it works:

1. Every removal is recorded. A licensed electrician removes the panels, and every removal opens a decommissioning certificate tied to existing electrical and Clean Energy Regulator records. Installers record panel serial numbers in the apps they already use on site.
2. Responsibility stays put. The electrician or deinstaller stays responsible until an accredited party accepts the panels.
3. Every panel is accounted for. Each panel must be certified as recycled, reused or retained, and the certificate must close within 90 days.
4. A simple national register flags any panel that isn’t accounted for.
5. The cost is met when a panel comes down, at the market price for that job and location, by whoever caused it to come down.
6. Bans with real penalties. Landfill and export bans carry real penalties. A capped, time-limited fund covers genuinely dumped or orphaned panels.
7. Independent oversight checks recovery and publishes the data.

No levy to calculate, no fund to set up, no administrator to appoint and no new IT system to build before the first panel is collected.

Why competition matters

Open, real-time market pricing keeps innovation and investment high. When providers compete for every job, they find better, cheaper ways to collect, transport and recover panels, without sacrificing recovery outcomes. And because the price reflects the real cost of each job and location, nobody is paying for someone else’s inefficiency.

What this means for recyclers and the solar industry

Recyclers need certainty to invest in infrastructure, technology, people and long-term capability. The question isn’t whether recyclers should be supported. It’s how that support is best delivered.

Certainty comes from a mandatory requirement and clear standards, not from a levy. Under our model, every panel taken off a roof must be certified as recycled, reused or retained. That’s guaranteed volume from day one, and recyclers compete for it directly.

For recyclers and reuse operators:

• Direct access to every job, paid at market price by whoever is responsible
• No administrator taking a margin or deciding who gets the volume
• Standards that stop low-quality operators undercutting compliant recyclers
• A clear signal to invest privately

For collectors, transporters and assessors: open participation for every accredited provider, in the city and the regions, with no membership required to take part.

For installers and electricians: keep using the apps you already use on site. No new IT system is needed.

For households and businesses buying solar: no levy added to the price of new solar.

What should recyclers do now? Nothing changes today. Keep recycling to a high standard and keep good records. Under this model, verified recovery is what gets rewarded, and the operators already doing it properly are best placed. The framework is open for comment, and we want to hear from you.

Is Activ Group trying to delay solar stewardship? No. We want it sooner.

This is the most important question our framework raises, so here’s a plain answer.

No. Activ Group wants solar stewardship to start sooner, not later.

The fastest wins don’t need a levy, a fund or an administrator. A national landfill ban, a decommissioning certificate and a recovery standard can all start using systems that already exist.

The full framework could commence by 1 January 2028.

And if government chooses a different model? We’ll still support it. Whatever model government chooses, Activ Group will continue to support efforts that increase responsible solar recycling across Australia.

“We’re putting forward ideas, not standing in the way.”

Helen Jarman, Founder and CEO, Activ Group

Solar stewardship in Australia: frequently asked questions

Does Activ Group support solar stewardship?

Yes. Activ Group supports solar stewardship, including a mandatory, national scheme that starts as soon as possible. We’ve worked in product stewardship for 28 years, including helping to set up the National Television and Computer Recycling Scheme (NTCRS), so we know what makes a scheme work. Our Solar Stewardship Framework draws on that experience, with practical ideas to improve competition, affordability, accountability and recovery outcomes. Each element can be adopted on its own.

Does Activ Group support solar recycling?

Yes. Activ Group supports solar recycling and higher collection, recovery and recycling rates across Australia. Our framework requires every panel removed from a roof to be certified as recycled, reused or retained within 90 days, tracked on a national register and independently verified, with real penalties for landfill and illegal export.

Is Activ Group opposed to solar recycling schemes?

No. Activ Group supports solar recycling schemes. What we’re concerned about is a poorly designed scheme with integrity gaps, such as a closed scheme where a single administrator decides who can take part. We believe any scheme needs independent oversight and open participation for every accredited provider.

Why does Activ Group oppose levy-funded stewardship?

Our concern isn’t the goal, it’s the mechanism. A levy on new solar adds cost for families and businesses, and levies are slow to correct when they’re set wrong. Under- or over-collection can push compliant operators out and distort the market. We favour paying at the point of removal, at real market price. If a levy is chosen, it should be set at full cost from day one and reviewed often.

Is Activ Group trying to stop or delay the solar stewardship scheme?

No. Activ Group wants solar stewardship to start sooner. The fastest steps, including a national landfill ban, a decommissioning certificate and a recovery standard, could start within 12 months using existing regulation and systems, with the full framework able to commence by 1 January 2028. Whatever model government chooses, we’ll continue to support efforts that increase responsible solar recycling.

What stewardship model does Activ Group support?

Activ Group supports an independent, open, well-designed and high-integrity model. Government sets the rules, a truly independent regulator oversees the scheme, and every accredited provider can compete to collect, transport, reuse and recycle panels. The cost is met when a panel comes down, at the market price for that job, by whoever caused it to come down.

How would Activ Group’s model stop solar panels being dumped?

Every removal by a licensed electrician opens a certificate linked to existing electrical and Clean Energy Regulator records. It must close within 90 days, and a national register flags any panel that isn’t accounted for. Responsibility stays with the electrician or deinstaller until an accredited party accepts the panels. Landfill and export bans carry real penalties, and a capped fund covers genuinely orphaned panels.

What does this mean for solar recyclers?

Guaranteed volume from day one, because every panel removed must be certified as recycled, reused or retained. Recyclers get direct access to every job at market price, with no administrator taking a margin or deciding who gets the volume, and standards that stop low-quality operators undercutting compliant ones. Nothing changes today: keep recycling to a high standard and keep good records.

What would success look like for Australia?

In five years: every panel tracked from roof to recovery; landfill and illegal export close to zero; recovery rates around 80%; a competitive market of accredited providers in the city and the regions; no levy on new solar; and recovery data published for everyone to see.

Looking ahead

Australia has an opportunity to build a solar stewardship system that delivers real environmental outcomes, supports investment in recycling capability and stays sustainable for the industries that fund it.

Our Solar Stewardship Framework doesn’t claim to have every answer. It’s there to encourage discussion about how we reach those outcomes in the most effective way possible.