MNRE Amends ALMM Regulations With New Data Collection and Traceability Requirements for Solar PV Manufacturers

Introduction

On August 7, 2024, the Ministry of New & Renewable Energy (MNRE) introduced a critical amendment to the Approved Models and Manufacturers of Solar Photovoltaic Modules (ALMM) regulations.[1] Originally established in 2019, these regulations are essential for the compulsory registration of solar PV manufacturers in India. The recent amendment introduces significant changes aimed at improving the regulation and monitoring of the solar PV manufacturing sector, reflecting the Indian government’s commitment to transparency, accountability, and the promotion of domestic content in renewable energy projects.

Explanation (Key Points)

The amendment introduces two new clauses and modifies an existing one within the ALMM regulations:

1. Clarification on Provisional Enlistment:
   The key modification was made to sub-para 1.2.2 of Para 1.2, which governs the conditions under which provisional enlistment of solar PV manufacturers becomes final. Previously, the enlistment process required factory inspections and final decisions to be completed within two months of receiving the application. If this deadline was not met, provisional enlistment was automatically deemed final. The amendment clarifies that this automatic finalization will now only occur if the National Institute of Solar Energy (NISE) has completed the inspection but has not yet submitted its recommendations to MNRE. Importantly, if delays are attributed to the manufacturers themselves, their provisional enlistment will be revoked. Additionally, all cases of deemed enlistment will be subject to review, with NISE required to report the causes of any delays to MNRE within two months.
2. Introduction of Data Collection Portal (Clause 1.7):
   A new Clause 1.7 has been added, mandating the use of a dedicated portal operated by NISE for the collection of production, sales, and export data from solar PV manufacturers. This requirement applies retroactively to data from April 2023 onwards. Manufacturers already enlisted under ALMM are required to enter this data within four weeks of the issuance of the Office Memorandum (O.M.). Non-compliance will result in delisting from ALMM, emphasizing the government’s strict approach to data accuracy and transparency. Future applications for enlistment, renewal, or model additions must also include a certificate from the manufacturer confirming that data entry on this portal has been completed. Failure to include this certificate will lead to the rejection of the application.
3. Implementation of a Traceability Portal (Clause 1.8):
   Clause 1.8 introduces a portal designed to ensure the traceability of domestically manufactured solar PV cells and modules. This portal will be integral in verifying compliance with the Domestic Content Requirement (DCR) for solar PV modules used in India. Manufacturers already enlisted under ALMM must register their facilities and start entering data on the solar cells and modules they produce within one month of the O.M.’s issuance. The portal will become the sole mechanism for DCR verification, and any module failing the verification process may result in penalties as per MNRE’s guidelines issued on October 16, 2023. Moreover, all future ALMM applications must be accompanied by a certificate confirming the completion of data entry on the portal; non-compliance will result in application rejection.

Conclusion

The amendment to the ALMM regulations underscores the Indian government’s dedication to enhancing the regulatory framework governing the solar PV manufacturing sector. By introducing stringent data collection and traceability requirements, the MNRE aims to ensure greater transparency, accountability, and adherence to domestic content standards. These measures are expected to strengthen the integrity of the solar PV manufacturing process, support the growth of India’s renewable energy sector, and contribute to the nation’s broader sustainability goals. The directive, endorsed by the Hon’ble Minister of New & Renewable Energy, calls for strict compliance by all stakeholders, highlighting the government’s resolve to bolster the reliability and sustainability of India’s solar energy infrastructure.

[1] https://cdnbbsr.s3waas.gov.in/s3716e1b8c6cd17b771da77391355749f3/uploads/2024/08/202408141102670518.pdf