The recent reimposition of the Approved List of Models and Manufacturers (ALMM) regulation by the Ministry of New and Renewable Energy (MNRE) has once again raised questions for existing and aspiring solar manufacturers on the elaborate process for getting ALMM-enlisted.

The ALMM mandate is back in force from April 1, 2024, clearing the confusion caused over the exemption of open access and private rooftop solar power projects in MNRE’s previous order.

Following the reimposition order, MNRE added 4.1 GW of new solar module capacity to the ALMM.

Mercom India delves into the important points solar manufacturers must consider while applying for ALMM enlistment or renewal.

• To be included in the ALMM, the solar modules must be registered/certified by the Bureau of Indian Standards (BIS) as per the “Solar Photovoltaics, Systems, Devices, and Components Goods (Requirements for Compulsory Registration) Order, 2017” or any amendment thereof.
• Applications for inclusion or renewal must be submitted to the ALMM Cell established at the National Institute of Solar Energy (NISE) in association with the MNRE.
• Alongside the applicable fee, manufacturers must provide documentary evidence of their financial and physical manufacturing capabilities over the previous three years or the duration of the existence of such units, whichever is shorter. This evidence includes details of raw material purchases, production and sales, profit and loss accounts, and asset and liability statements.
• The applications, along with the fees (or proof of payment) and submitted documents, will be forwarded to the ALMM cell of the Implementation Support Agency, i.e., NISE, for further processing. If required details are already submitted under different laws/regulations in the country, such documentary evidence may suffice for preliminary assessment.
• In cases where such details are not submitted under existing laws or regulations or where units operate beyond the jurisdiction of Indian laws, necessary documentary evidence may be unavailable for preliminary assessment. In such cases, units will undergo preliminary inspection by the Implementation Support Agency upon payment of inspection charges.
• After satisfactory verification of the unit’s physical establishment and operations, the applicant must provide monthly details of raw material purchases, production, sales, bank statements reflecting transactions, performance recommendation certificates from buyers, and bank solvency certificates for one year. Units meeting assessment criteria qualify for site inspection.
• To expedite and ensure transparency, applications should be submitted online through a dedicated portal, with hard copies of documents provided separately until the portal is operational. Required certified documents include the Certificate of Incorporation, authorization document for the signatory, BIS registration/certification copies, standards declaration certificates from accredited labs, affidavit and indemnity bond in prescribed formats, and documents as per requirements.
• The approved list of models and manufacturers will be published on the MNRE website and updated quarterly. Enlistment is valid for four years from the approval date and can be renewed following the specified procedure.
• Provisional ALMM enlistment for new modules by already listed manufacturers is granted within seven days of BIS certification, and a time limit of two months will be provided for factory inspection and final enlistment, failing which the provisional enlistment will be deemed the final enlistment.

Application Fees

The application fees for solar module/cell enlistment are as follows:

• For solar module and cell manufacturers having a total installed capacity less than or equal to 50 MW/year, the application fee has been set as ₹500 (~$6)/MW of the total installed production capacity of the applicant.
• For solar modules and cell manufacturers with a total installed capacity of more than 50 MW/year, an application fee of ₹1,000 (~$12)/MW of the total installed capacity of solar modules and cells will apply.
• A “model” refers to modules/cells with the same nominal power output rating, and all modules/cells approved by the Bureau of Indian Standards (BIS) with the same rating are considered one model.
• If the application includes multiple models, the fee is calculated based on the capacity of one model plus an additional 1% for each extra model.

If an applicant is already enlisted for one model and applies for enlistment of another:

• The fee for additional models is 10% of the standard application fee. However, if the application includes multiple models, the fee is calculated based on the capacity of one model plus an additional 1% for each extra model.
• Enlisting additional models does not affect the validity of the original enlistment/renewal, and the validity expiry date remains the same for all models.

Manufacturers can withdraw their applications before factory inspection with a refund of 90% of the application fee.

Inspection Fees

Applicants also must pay the inspection charges of the applicant’s premises. The application fees are as follows:

For manufacturing sites located in SAARC countries:

• Up to 100 MW: ₹150,000 (~$1,792)
• More than 100 MW and up to 500 MW: ₹500,000 (~$5,975)
• More than 500 MW: ₹1.5 million (~$17,924)

For manufacturing sites located in non-SAARC countries:

• For all capacities: ₹3 million (~$35,849)

If the applicant has multiple manufacturing sites or sources finished products from other manufacturers and sells them under their brand:

• All manufacturing sites, including the applicant’s own, will be inspected. The inspection fee for each site follows the rates mentioned above.
• Additional sites within the same country incur an inspection fee of 50% of the standard fee for each site.
• If additional sites are in different countries, the standard inspection fee applies to each site.

The Ministry has provided an exemption from factory inspection in the case of enlistment of additional models in the ALMM list, similar to those already enlisted by the applicant but with a lower voltage. However, factory inspection will be done if the wattage of models proposed to be enlisted is higher than that of already enlisted models.

Separate inspection fees are required for preliminary and final inspections. All inspection fees should be paid to NISE.

Co-branding

Inspection may not be required if an ALMM enlisted model of a brand owner is manufactured under a co-branding arrangement in the ALMM enlisted manufacturing facility of another Original Equipment Manufacturer (OEM) using the same manufacturing process and bill of materials.

The exception will also apply if an ALMM enlisted model of an OEM is manufactured under a co-branding arrangement in the OEM’s ALMM enlisted manufacturing facility using the same manufacturing process and bill of materials but bears the brand name of another ALMM enlisted manufacturer.

Both the brand owner and the OEM must be enlisted in ALMM. The brand owner should submit the application to MNRE with a copy of the agreement between the OEM and the brand owner.

The agreement should specify the details of the brand owner and the OEM and the manufacturing capacity in MW/annum for which the co-branding arrangement has been executed. Additionally, the agreement should include the date of execution and the date until the agreement is valid.

If the brand owner wishes to enter into co-branding arrangements with different OEMs, they must submit separate applications for each OEM. Each application should be accompanied by the corresponding agreement between the brand owner and the OEM and the application fee of ₹1,000 (~$12).

The brand owner must provide an undertaking that the label of each model must display the name of the brand Owner and OEM, as well as the location of the OEM’s manufacturing unit where the model was produced. The application fee remains the same regardless of the capacity specified in the OEM and brand owner agreement.

The co-branded models will be listed under the brand owner’s name in addition to their existing entries on the ALMM List.

The ALMM enlistment of co-branded models will be valid until two years from the enlistment date, the date of expiration of the validity of the agreement between the brand owner and OEM, or the date of expiration of any ALMM enlisted model of the brand owner, applicable only in cases not requiring inspection.

Quality Checks

Quality assurance procedures entail random quality checks and tests on enlisted models and manufacturers. These checks may include inspections of manufacturing facilities. If enlisted manufacturers fail to meet standards or comply with regulations, they will be removed from the Approved List of Models and Manufacturers (ALMM).

Additionally, inspections and audits of production and sales records may be conducted if necessary to address any complaints. Enlisted units must reimburse the costs incurred for such inspections or audits within one month. Failure to do so will result in removal from the ALMM lists.

Renewal

The process for renewing enlistment in ALMM mirrors that of fresh enlistment, requiring submission of relevant documents and payment of renewal fees, set at 50% of the current application fee. All conditions, procedures, and inspection fees for fresh enlistment also apply to renewal.

When applying for renewal, manufacturers must provide all necessary documents required for a fresh application. Upon renewal, enlistment is extended for another two years. The validity of enlistment is unaffected by the enlistment or renewal of additional models.

Module efficiency

MNRE introduced significant changes to the ALMM by enlisting cadmium telluride thin film-based models in addition to the existing crystalline-silicon models from manufacturers that adhere to Bureau of Indian Standards norms and meet specific minimum module efficiency criteria. The minimum efficiency listed for cadmium telluride thin film-based modules is as follows:

• Category I (grid-scale power projects): minimum module efficiency of 19%
• Category II (rooftop and solar pumping): minimum module efficiency of 18.5%
• Category III (solar lighting): minimum module efficiency of 18%

The minimum module efficiency for crystalline-silicon models is 20% for utility-scale projects, 19.5% for rooftop and solar pumping, and 19% for solar lighting.