FAQ

The provision relating to the super-reduced rate reduces the scope of application to the level of the type of building that will be equipped with solar panels, namely “on private housing, housing and building, public and others, used for activities of general interest, and in close proximity to these”.

As far as “private housing” is concerned, this is housing of which at least three quarters of the total surface area is reserved for living purposes. The same rule applies to housing and public buildings and others used for activities of general interest: at least three quarters of the total surface area must be reserved for these purposes.

A definition of this is provided in the grand-ducal regulation of 23 December 2022 amending: 1° the grand-ducal regulation amended on 21 December 1991 determining the limits and application conditions of the reduced, super-reduced and intermediate rates of value added tax; 2° […], and the following explication is provided by bulletin No 816 issued by the Registration Duties, Estates and VAT Authority: “private housing and buildings used by public authorities not subject to tax for activities carried out as such or used by those subject to tax for activities of general interest exempt from VAT without the right to deduct input tax (notably hospitals, schools, children’s nurseries, youth hostels and retirement homes)”. The provision of cultural services is added to the latest list.

The delivery and installation of photovoltaic solar panels close to housing or buildings referred to above does not interfere with the application for the super-reduced VAT rate of 3 % as long as the delivery and installation takes place on adjoining or separate properties but located close to private housing or housing and buildings, public and others, used for activities of general interest and as long as such photovoltaic solar panels are connected to the thermal and/or electrical network of the housing or buildings in question.

The grand-ducal regulation of 23 December 2022 amending: 1° the grand-ducal regulation amended on 21 December 1991 determining the limits and application conditions of the reduced, super-reduced and intermediate rates of value added tax; 2° […] defines in the context of the reduction of the VAT rate the “delivery and installation of solar panels” as follows: “work on a property consisting of the delivery of solar panels and their installation”.

As a result, all the parts necessary for this installation and its operation also come under the super-reduced rate, which implies the following parts of the photovoltaic solar panels: photovoltaic panels (or hybrid solar collectors), fixing rails, DC and AC electric cabling connected directly to the photovoltaic installation, inverter, electrical protection devices, bidirectional meter; and for the thermal solar panels: thermal solar collectors, fixing rails, insulated pipework, solar storage reservoir, calorimeter, peripheral equipment (power feed, regulation, heat exchangers); as well as, of course, the costs of installation.

For the photovoltaic solar panels, a storage installation (battery) is therefore not involved.

It is also important to note that the super-reduced rate only applies to such installation work on a solar power plant. Bulletin No 816 issued by the Registration Duties, Estates and VAT Authority defines this notion of “work on a property” as follows: “Therefore, there is reason for understanding this new provision not as the delivery of solar panels or the installation of such panels carried out separately, but as work on a property that consists of a delivery of solar panels with installation”.

Applications for obtaining financial aid must be submitted no later than 12 months after the last invoice was issued in connection with the investment.

Yes, it is possible to recycle these batteries. It is regulated by the amended Law of 19 December 2008 on batteries and accumulators and waste batteries and accumulators, which enacts European Directive 2006/66/EC into Luxembourg law. This directive requires at least 50% of the weight of batteries other than lead-acid and nickel-cadmium types, i.e. lithium-ion batteries, to be recycled.

The components that are currently most attractive for recycling are cobalt, nickel, copper and aluminium. In the medium term, the lithium recycling rate should improve to ensure supply.

For more information or instructions relating to the recycling of these batteries, which are considered to be industrial accumulators, please contact either SuperDrecksKëscht or the Ecobatterien asbl association.

To assess the environmental impact of batteries, it is necessary to take into account the rare and partly at-risk resources (lead, lithium, etc.) consumed, their origins and the mix of electricity used in the production of the batteries.

Lithium-ion batteries are made of cobalt, nickel, copper, aluminium and lithium, as well as other materials. Among these materials, the availability of lithium in particular is a hot topic. Over the short term, reserves are sufficient to guarantee the manufacture of the batteries; nevertheless, it will be necessary to improve the recycling capacity of lithium to ensure supply over the medium term.

Analysis of the environmental impact of these batteries is currently a major topic of research. Although there have already been positive developments in terms of cost effectiveness, performance and the environmental impact of batteries, they are still under intense development and significant progress is expected in the near future.

Thin-film panels (i.e. cells made of copper, indium, gallium and selenium, known as CIGS, and CdTe) are becoming increasingly common. This technology allows for greater energy savings and reductions in environmental impact than the current types, as the production method is simpler and the need for raw materials is lower. These cells are already showing yields higher than 20%. In addition, owing to their slimness, these modules offer more flexibility in terms of installation, allowing for curved shapes or easier integration into a façade or roof.

Beyond current technologies, the development of what are known as multi-junction cells promises even higher levels of efficiency through the stacking of single-junction cells. These cells are composed of two or more different active layers that enable different parts of the solar spectrum to be captured.

Thin-film modules are already available on the market; however, these technologies are still being developed. Commercial maturity can be expected in the next few years. These multi-junction cells are currently still under development but should be available on the market shortly.

Yes, in general it is possible to repair them, with the exception of broken glass.

Currently, most panels destined for recycling are faulty panels or panels that have been damaged during transport. Where possible, therefore, repair is the best method of giving panels a second life, thereby extending the life cycle of panels that would otherwise be recycled.

According to the law of 9 June 2022 on waste electrical and electronic equipment, the producer is responsible for the collection and processing of photovoltaic panels.

Producer means any natural person or legal entity who manufactures photovoltaic panels in Luxembourg or initially imports them onto the Luxembourg market. Any person established in another Member State or in a third country who, on a professional basis, supplies photovoltaic panels directly to a user in Luxembourg is considered a producer. In practice, in the majority of cases, this is the installer of the photovoltaic plant in Luxembourg.

Possibilities for owners to dispose of their old photovoltaic panels 

For photovoltaic panels put on the market before 13/08/2005 :

• in case of replacement of the photovoltaic panels, the take back of the old panel is free of charge and must be ensured by the company supplying the new equipment
• in case of dismantling of the photovoltaic panel (non-replacement of the panel), the removal by a professional collector is done against payment by the user

For photovoltaic panels placed on the market after 13/08/2005 :

• free take-back by the producer who bears the costs of collection and recovery of the photovoltaic panels. 

In general, all photovoltaic panels are recyclable.

Indeed, there are risk-free procedures for silicon-based panels as well as for thin-film panels containing cadmium. Moreover, recycling is regulated by the European Directive 2012/19/EU on waste electrical and electronic equipment, which is transposed into national law by the law of 9 June 2022 on waste electrical and electronic equipment: this framework currently requires at least 80% of the mass of a photovoltaic panel to be prepared for reuse or recycled, and 85% of the mass to be recovered.

The recycling rate of photovoltaic modules is nevertheless close to 100%, considering that the modules are generally composed mainly of glass, aluminium and other metals. Net modules usually contain very limited amounts of synthetic materials, such as silicon or other minerals. However, it is technically possible to recycle these elements, even if the processes for extracting them are not yet cost-effective. Thus, these materials are currently mainly used for thermal recovery.