Skip to Content

Search tceq.texas.gov

Questions or Comments: IHWRules@tceq.texas.gov

Renewable Energy Component Recycling: Reporting Requirements

Annual reporting requirements for facilities that accept, process and repurpose components from wind turbine generators, solar energy devices, or battery energy storage systems (BESS) components.

Overview  

House Bill 3229, effective Sept. 1, 2025, establishes annual reporting and financial assurance obligations for recycling facilities in Texas under Health & Safety Code (THSC) Chapter 376 . These recycling facilities are those that accept, process, or repurpose components to recover valuable materials from wind turbines, solar energy devices, or battery energy storage systems.   

The annual reporting and financial assurance requirement help ensure that facilities remain financially responsible for proper recycling or disposal of renewable energy components. They also ensure that materials stored on-site can be appropriately managed if a facility stops operating. 

Annual Reporting Requirements:  

Facilities subject to THSC Chapter 376 must submit an annual Facilities report to TCEQ no later than Jan. 15 each year. The report must include:  

    1. Inventory of Components: A complete inventory of all unrecycled renewable energy components (wind turbine, solar, or BESS) the facility has accepted and not yet recycled. The inventory must include items the facility has taken title to or assumed control of, regardless of where they are located.  Include this information in the Annual Report Form linked to below.
    2. Estimated Recycling or Disposal Timeline: A projected timeline for the facility to recycle or dispose of the inventoried components. Include this information in the Annual Report Form linked to below.
    3. Third-Party Cost Estimate: An itemized cost estimate prepared by an independent, third-party professional engineer licensed in Texas. The estimate must reflect the full cost of recycling or final disposal of the unrecycled inventory. 
    4. Financial Assurance Documentation: Documents showing the facility has secured financial assurance equal to 100% of the cost estimate. (Read more below.) 

TCEQ recommends that facilities calculate their unrecycled inventory before Jan. 15 to allow enough time to obtain a third-party cost estimate and set up the required financial assurance.

Financial Assurance Documentation  

Facilities must maintain financial assurance equal to 100% of the independently estimated cost to recycle or dispose of the unrecycled inventory. Acceptable financial assurance mechanisms include:  

    1. Parent Company Guaranty: From a parent company with a minimum investment-grade credit rating issued by a major domestic credit rating agency.  
    2. Letter of Credit: An irrevocable standby letter of credit in favor of TCEQ.  
    3. Bond: A surety bond, performance bond, or payment bond in favor of TCEQ.  

The financial assurance mechanism must be specified in TCEQ rules, with instructions in parenthesis replaced by the facility’s information and parenthesis deleted. The required wording can be reviewed and downloaded from 30 TAC Chapter 37, Subchapter D , from these sections:  

Reporting Forms and How to Submit  

To submit your annual report, you need to complete these two forms: 

Email the forms, including the cost estimate and financial assurance documentation, to ihwper@tceq.texas.gov.  
 
In addition, mail the original copy of the cost estimate and evidence of financial assurance to: 

Texas Commission on Environmental Quality  
Attn: Financial Assurance Unit, MC-184 
P.O. Box 13087 
Austin, TX 78711-3087 

Record Keeping Requirements 

Facilities must keep all related records for a minimum of three years, in addition to following any local, state, or federal recordkeeping requirements. Records include:  

    • Manifests and bills of lading
    • Quantities of components recycled on-site or off-site  
    • Waste disposal record 

List of Renewable Energy Components Recycling Facilities  

Beginning February 2026, TCEQ will publish a list of renewable energy components recycling facilities that submit annual reports and maintain financial assurance. This list will be available on this website.