Recycling isn't free. Currently it costs 20-30x more to recycle a panel than to dump it in a landfill. Maybe the aluminum frame, the glass and polymer sheets, and the junction box containing the copper wiring are relatively straightforward to recycle, but it takes much more complicated (see: expensive) machines to get to the smaller parts like the intra-cell wiring and the silicon itself. And the silicon wafers aren't really recyclable. There's some specialized companies that can melt them down to reclaim the silicon cells and various metals within but this takes a lot of energy (and/or chemicals if it's a chemical treatment) and money.
The reason solar panels are hard to recycle isn't really because of their materials. The hardest part is separating all those materials, which all have their own unique recycling needs.
The EU requires solar recycling; Japan, India, and Australia have some minimal regulation around it; but in the US it's the wild west (except in Washington). Which means there's almost no recycling infrastructure in the US
All of this is the reason recycling a solar panel is so much more expensive than dumping it right now. Regulation will definitely help, but getting to the point where it's economically feasible to recycle them will require technology that hasn't actually been developed (yet, hopefully).
Umm, it's not just that. The most advanced company in the world at recovering precious materials from solar panels is a French company that uses a chemical treatment to recover the silver intra-cell wiring. Even they are not really economically feasible. The reason the EU recycles is because they have to. Not because of economics
So no, it's not just solar panels in the US. The technology to make recycling solar panels feasible just doesn't currently exist
The reason solar panels are hard to recycle isn't really because of their materials. The hardest part is separating all those materials, which all have their own unique recycling needs.
The EU requires solar recycling; Japan, India, and Australia have some minimal regulation around it; but in the US it's the wild west (except in Washington). Which means there's almost no recycling infrastructure in the US
All of this is the reason recycling a solar panel is so much more expensive than dumping it right now. Regulation will definitely help, but getting to the point where it's economically feasible to recycle them will require technology that hasn't actually been developed (yet, hopefully).
Some readings:
[0] https://grist.org/energy/solar-panels-are-starting-to-die-wh...
[1] https://news.energysage.com/recycling-solar-panels/
[2] https://www.researchgate.net/publication/342671383_Metal_dis...