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The Ministry of New and Renewable Energy (MNRE) has proposed a significant amendment to the Approved Models and Manufacturers of Solar Photovoltaic Modules (ALMM) Order, 2019, introducing ALMM List-III for solar wafers, with an effective date of June 1, 2028.
The proposed list will only be notified once at least three independent wafer manufacturing units—operating without common ownership or control—are enlisted, with a combined manufacturing capacity of at least 15 GW per annum. To qualify, manufacturers must also have equivalent ingot manufacturing capacity, ensuring that enlisted wafer capacity reflects integrated production capabilities.
In a key clarification, the ministry has allowed thin-film modules manufactured in integrated facilities under ALMM List-I to be deemed compliant with both wafer and cell requirements. US-based First Solar will be a key beneficiary of this.
However, MNRE emphasised that no relaxation will be provided under the Domestic Content Requirement (DCR) provisions for schemes such as PM-KUSUM (Components B & C), PM Surya Ghar: Muft Bijli Yojana, and the CPSU Scheme Phase-II. Procedural guidelines for wafer enlistment under ALMM List-III will be issued separately, it added, noting that the proposal has been approved by the Minister for New and Renewable Energy.
Under the revised framework, all projects covered by ALMM will follow a fully integrated sourcing chain, requiring modules, cells, and wafers to be sourced from ALMM Lists I, II, and III, respectively. Projects exempted from using ALMM-listed cells will automatically be exempt from sourcing ALMM-listed wafers.
A cut-off date mechanism has also been introduced for ALMM-covered projects, including those bid out under central government guidelines. For projects where the last date of bid submission falls on or before the cut-off date—defined as seven days after the issuance of the initial wafer list—the use of ALMM-listed modules and cells will remain mandatory, while wafers will not be required, irrespective of commissioning timelines. This exemption will also apply where bids or PPAs were signed before the cut-off date, even if subsequent EPC or supply tenders are issued later.
In contrast, projects with bid submission dates after the cut-off date must explicitly mandate the use of ALMM-listed modules, cells, and wafers. From June 1, 2028 onwards, only modules using ALMM-compliant cells and wafers will remain eligible under List-I, with non-compliant manufacturers liable for delisting.
To address exempt project categories, MNRE will maintain separate categories, including List-I(a) for modules using non-ALMM cells and wafers, List-I(b) for modules using ALMM cells but non-ALMM wafers, and List-II(a) for cells using non-ALMM wafers.
The notification further clarifies that net-metering and open access projects commissioned before the effective date will be exempt from wafer requirements but must comply with module and cell norms. Projects commissioned after the effective date will be required to comply with all three ALMM lists.
For government-owned captive (behind-the-meter) projects, a phased compliance framework will apply. Projects commissioned before June 1, 2026, will only be required to use ALMM-listed modules. Those commissioned between June 1, 2026, and the effective date will need to use both modules and cells, while projects commissioned on or after the effective date will be required to comply fully with modules, cells, and wafers under ALMM.
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