Large Manufacturers with Multiple Products Could Pay Hefty Application Fee for ALMM

The Ministry of New and Renewable Energy (MNRE) has issued a clarification regarding the compulsory requirements of registration for solar manufacturers under the Approved List of Models and Manufacturers (ALMM).

The clarification deals with the definition of the model, application fee, and provisions for manufacturers currently exempted from BIS certification for ALMM application purposes.

As per the clarification, the model, as mentioned in the ALMM guidelines, refers to modules or cells of the same nominal power output rating. All BIS approved modules or cells with the same nominal output rating will be treated as one model.

Since a single model of a module has a range of power wattage, the ALMM application form provides for specifying both the mean wattage and the applicable range of wattage. However, such a range of wattage may vary from among manufacturers based on the method used by them for categorizing the model.


The clarification states that all the modules based on the same technology (monocrystalline, multi-crystalline, mono-PERC, bifacial, half-cut, and others) and having the same number of cells and having power ratings within ±5% of the mean wattage will be treated as one model.

The clarification issued by the MNRE states that the applicable range of wattage up to a variation of ±5% of the mean wattage of the module will only be permissible.

So, if two different modules have the same technology, and the same number of cells and identical power ratings or slightly varying within the permissible variation range of ±5% from the mean wattage will be treated as one model. Similarly, if two modules have some differences in technical features, they will not be treated as one model. The same is the case with PV cells, where all the cells based on the same technology and having power ratings within ±5% of the power rating of the mean wattage will be treated as one model.

According to the amendment, the application fee for one model of module or cell will be ₹5,000 (~$70)/MW of the total installed manufacturing capacity for solar PV modules or cells. The amendment also mentions that for PV module manufacturers having total installed manufacturing capacity of modules less than or equal to 50 MW, the application fee for one module will be ₹2,500 (~$35)/MW of the total installed manufacturing capacity of solar modules or cells. Earlier, there was no provision for small PV module manufacturers having capacity less than or equal to 50 MW.

In case an application consists of multiple models, the application fee will be as mentioned above, with an additional 1% for every model.  In case the applicant is already enlisted for a particular model of the solar PV module or cell and applies for another model of solar PV module or cell, then the application fee for the additional model will be 10% of the prevailing normal application fee. However, if in subsequent applications, there are multiple models, then the fee will be 10% of the prevailing application fee and 1% for every additional model.

Modules

If a manufacturer applies to enlist several models of PV modules comprising different technologies and with a different number of cells and power ratings:

  • For the first model: ₹5,000 (~$70)/2,500 (~$35) as applicable multiplied by total installed manufacturing capacity (MW) of modules of the applicant manufacturer manufacturing under the same brand name.
  • For all other models (irrespective of technology, number of cells, and power ratings): ₹5,000 (~$70)/2,500 (~$35) multiplied by 0.01 again multiplied by total installed manufacturing capacity (MW) of modules.

For Cells

If the applicant applies to enlist several models of solar PV cells comprising different technologies and power ratings.

  • For the first model: ₹5,000 (~$70) multiplied by total installed manufacturing capacity (MW) of cells of the manufacturer across different technologies but manufacturing under the same brand name.
  • For all other models: ₹5,000 (~$70) multiplied by 0.01 again multiplied by total installed manufacturing capacity (MW) of cells of the manufacturer across different technologies but manufacturing under the same brand name.

According to the document, the solar PV manufacturers who are exempted from BIS registration are eligible to enlist their solar PV modules. However, the validity of their enlistment in ALMM will be in line with the validity of the exemption from BIS certification.

If the solar PV manufacturer has enlisted his products under ALMM without BIS certification, the manufacturer will have to obtain BIS registration and submit the documents to MNRE at least one month before the date of the expiry of the ALMM enlistment.

Based on the clarification, large manufacturers with multiple product lines will end up paying a hefty fee to enlist under ALMM. The fee structure also punishes innovation by charging fees if companies constantly release new models with increased efficiency or better technology. The fee structure does seem to be fair in its current form and must be further reviewed to encourage innovation and new technologies.

One of the manufacturers told Mercom, “Due to the recent clarification issued by MNRE regarding the ALMM, all the top five suppliers are going to set up a meeting with the MNRE next week in order to bring some liberal policy on this topic.”

In September last year, (MNRE) had issued a notification shedding light on its earlier order regarding the compulsory registration under the Approved Models and Manufacturers of Solar Photovoltaic Modules. The MNRE had then said that the list would consist of List-1, which specifies the models and manufacturers of solar PV modules, while List-II will specify the models and manufacturers of solar PV cells. Both the lists will come into effect from March 31, 2020.

Earlier, it was reported that MNRE had issued a set of guidelines to be followed by solar manufacturers for models of modules that will be utilized in government-owned projects and those set up for the sale of electricity to the government.

Previously, MNRE had issued a memorandum concerning the importance of following BIS certification when it comes to the quality of solar modules.  According to the memorandum, “The lenders involved in financing solar PV power projects must insist on BIS certification regarding the quality of solar modules and not whether the supply of solar modules is from the Bloomberg Tier-I List.”

Mercom had also analyzed how the standardization and quality control measures for cell and module technology to maintain the quality of products being deployed have affected the solar sector. Find out more about it here.