Solar Decommissioning Documentation Requirements Under NJ S3399

Proper documentation is not an afterthought under New Jersey’s solar recycling law — it is the compliance itself. S3399 requires a complete chain-of-custody record that follows every panel from removal through final disposition at a certified recycler. Here is exactly what that record looks like and how to organize it.

Pre-decommissioning records

Before removal begins, document the system you are removing. Pre-decommissioning records should include:

• A complete inventory of panels — make, model, quantity, and serial numbers where available
• System location and installation address
• Contractor credentials — license number, insurance certificates, and any relevant certifications
• Planned recycling facility and confirmation of their certified status

During removal records

As removal proceeds, the following should be documented:

• Date of removal
• Panel count removed — matched against the pre-decommissioning inventory
• Condition of panels at removal (functional, damaged, or end-of-life)
• Any components left on-site and the reason for retention

Transport documentation

Once panels leave the site, transport documentation takes over. This includes:

• Hauler name and credentials
• Date and time of pickup
• Panel count and weight confirmed at pickup
• Destination facility name and address
• A signed manifest acknowledging receipt of the panel batch

Final disposition — recycler records

The recycling facility closes out the chain of custody. Required records from the recycler include:

• Certificate of Receipt — confirming panels arrived at the facility
• Certificate of Recycling — confirming panels were processed in compliance with applicable standards
• Material recovery report — documenting what materials were recovered and in what quantities
• Date of processing

Volume tracking — pick one method and keep it consistent

S3399 allows two approaches to volume tracking. Choose one and apply it consistently across the entire project:

• Weight-based tracking: Total weight of panels removed, transported, and processed. Useful for large commercial projects where individual panel tracking is impractical.
• Panel-count tracking: Individual panel count tracked at each stage. Better for smaller projects or where panel-level documentation is preferred.

Mixing methods mid-project creates documentation gaps. Establish your approach before removal begins and confirm it with your contractor and recycler.

How long to keep records

Keep all decommissioning documentation for a minimum of five years from the date of removal. Commercial operators with ongoing regulatory relationships should consider longer retention. Store records in a format that can be produced quickly — a documentation request during an audit or property transaction requires fast access.

What Blue Flag provides

Every Blue Flag Solar removal includes a complete documentation package delivered at job completion — pre-removal inventory confirmation, removal records, transport manifests, recycler certificates, and Certificate of Recycling. You receive everything in one package, organized and ready to file.

Frequently asked questions