Analysis: a capacity number and a revenue number that are three orders of magnitude apart

The two figures that matter most in this filing sit far apart. The plant is rated at up to 100,000 tons of processed waste per year and over 3 million panels. The business feeding it recognized $586,280 of group revenue in six months. Nothing in the filing bridges that gap with a contracted volume, a price per ton or a signed offtake, and the company itself lists securing larger and longer term supply contracts as an unfinished 2026 objective. Rated capacity is an engineering statement about equipment. It is not a statement about panels arriving at the gate.

The accounting policy is the second thing worth reading closely. Comstock defers recycling revenue until the panels are actually processed and a certificate of destruction is issued, which is why $1,799,142 of the $2,309,422 billed at June 30 had not reached the income statement. That policy is conservative and it makes deferred revenue a better forward indicator here than billings. It also means that commissioning a plant does not by itself convert the backlog. Processing throughput does. The first quarter in which deferred revenue falls while recognized metals revenue rises will be the first hard evidence that the plant is doing work rather than being ready to.

The demand case rests on an industry that is genuinely early. The Environmental Protection Agency’s own description of solar panel recycling says elements of the process exist in the United States but that it is not yet happening on a large scale, and that researchers are still examining how to commercialize recovery of most of a panel’s components. The agency notes that glass makes up about 75 percent of a panel’s weight and is straightforward to recycle, while silver and internal copper are valuable but present in very small amounts. That is the economic problem Comstock’s upgrading line and its one ton per day silver pilot are aimed at: without a higher specification glass product or recovered metals, the mass being handled is mostly low value material.

Funding is the part that has changed most. The mining sale closed on August 24, 2026 and brings $20,000,000 of cash at closing plus a $7,000,000 deferred tranche, against a plant that cost $14.5 million and a six month loss of $34,851,818. Comstock says it intends to fund the next twelve months from existing cash, the mining proceeds, monetization of other non-strategic assets, solar recycling revenue and deferred revenue, and subsidiary-level equity issued by Bioleum. That list names five funding sources, and the filing does not quantify how much is expected from each. A careful reader should watch the third quarter report for the date the plant was actually placed in service, the movement in deferred revenue, and whether any supply contract is disclosed with a term and a volume attached.

What the documents say

Comstock Inc. (NYSE American: LODE) told the Securities and Exchange Commission in its quarterly report for the period ended June 30, 2026 that all equipment for its industry-scale solar panel recycling facility had been received and was expected to be placed in service in the third quarter of 2026 with the commissioning of the plant. The facility sits in Silver Springs, Nevada, on the same campus as the demonstration-scale plant the company has operated since 2024. Comstock states that the cost of equipment, installation and expanded storage capacity was $14.5 million, and that its subsidiary Comstock Metals has completed all permitting requirements for the site.

The scale of the waste stream the plant is being built for remains modest by national standards: the Department of Energy’s Solar Energy Technologies Office cites an International Renewable Energy Agency projection that cumulative photovoltaic waste in the United States will reach between 0.17 and 1 million tons by 2030, and states that the total cost of recycling a module in the United States is still generally greater than the cost of disposing of it in a landfill.

What the filing says the plant is designed to do

Comstock puts the rated throughput of the new plant at over 3 million panels per year, representing up to 100,000 tons of processed waste materials per year. The company describes the recycling process as one that creates no waste, generates no landfilled materials, and results in clean recycled products safe for reuse. Offtake from the existing demonstration plant already includes aluminum, copper, glass and secondary salable materials that the company says include precious and other metals.

The eight objectives Comstock set its metals segment for 2026 are listed in the filing: finish installing the commercial plant equipment, commission the plant, secure larger and longer term supply contracts, select second, third and fourth sites and begin permitting on two of them, order the equipment for the second industry-scale facility, finalize the design for downstream recovery of solar tailings, extend and operate an upgrading line capable of making high specification glass materials, and operate a one ton per day pilot recovering silver products. State-level permits for a second industry-scale plant in southern Nevada have been selected and submitted. The wider network described in the filing includes storage and logistics sites in California and Ohio.

Separately, on March 4, 2026 the company entered a sponsored research agreement with a metal development company to evaluate and process solar panel tailings for the recovery of valuable metals, funding research of up to $1,997,377 through December 31, 2026, of which $1,005,740 had been spent by June 30, 2026.

The revenue base the plant is being built on top of

The demonstration facility is small. Comstock reports that it generated revenues of $0.6 million in the six months to June 30, 2026 against $1.1 million in the comparable period of 2025, the fall driven by lower decommissioning work after a large emergency decommissioning in the first quarter of 2025. Group revenues for the three months to June 30, 2026 were $272,824, down $66,722 from $339,546 a year earlier. For the six months, group revenues were $586,280 against $1,125,361.

Much of what Comstock Metals has billed has not yet been earned. At June 30, 2026 it had billed $2,309,422, of which $510,280 was for decommissioning services, recycling fees and offtake revenue and $1,799,142 sat in deferred revenue because the recycling services were not complete. Revenue is recognized only when a certificate of destruction is issued. Customer concentration is heavy: two customers, Atlantic Iron & Metals and Illuminate, each accounted for over 10 percent of revenues in the first half, and at June 30, 2026 two others, Kiewit and Next Era Energy, each accounted for over 10 percent of accounts receivable.

The group carried an accumulated deficit of $413,579,326 at June 30, 2026 and recognized a net loss of $34,851,818 for the six months. Cash and cash equivalents rose to $31,405,235 from $16,951,645 at December 31, 2025, and the company reports no outstanding debt.

Where the money is coming from

On June 21, 2026 Comstock agreed to sell Comstock Mining LLC, Comstock Processing LLC, Comstock Exploration and Development LLC and Comstock Real Estate Inc. to Mackay Precious Metals Inc. and its parent. The stated consideration is $20,000,000 in cash, 2,000,000 shares of Mackay Parent common stock, $7,000,000 payable within 18 months, and a contingent $10,000,000 in cash if a construction decision or change of control occurs within seven years of closing. Comstock retains a 1.5 percent net smelter returns royalty that Mackay may buy back for $3,500,000, rising to $7,000,000 if the seven year contingent payment period lapses unpaid. The sale excludes the Silver Springs real estate. Comstock announced on August 24, 2026 that the transaction had closed.