India’s Approved List of Models and Manufacturers (ALMM) didn’t just add a compliance step to solar procurement — it rewrote who gets to sell into the market at all. Government-funded projects, PSU tenders, open-access installations, and net-metering schemes can now draw panels only from ALMM-listed manufacturers, and getting listed requires verified domestic manufacturing capacity, not just a recognisable brand.
That isn’t a tariff nudging prices upward. It’s an eligibility filter that removes imported panels from a large slice of demand outright, regardless of what they cost — and it is working exactly as designed: module imports fell from roughly USD 4.35 billion in FY2024 to USD 2.15 billion in FY2025, even as domestic manufacturing capacity scaled up more than twelvefold over the same broader window.
But one segment of that same supply chain is moving in the opposite direction. The autonomous robots that keep those panels clean once they’re installed face no equivalent policy. There is no approved list for cleaning robots, no eligibility filter, no domestic-manufacturing mandate — and demand is climbing fast off a genuinely low base. Estimates for exactly how fast vary widely depending on the source, which is itself telling: unlike modules, this equipment isn’t tracked under its own dedicated trade category, so nobody has a clean, agreed-upon number for it yet. What every estimate agrees on is direction, not magnitude.
What’s hot, what’s not
The reasons demand is climbing aren’t hard to see. Dust and soiling alone can cut panel efficiency by 20 to 40 percent, and in India’s dustiest solar regions, losses compound by more than one percent a day.
Manual cleaning solves the efficiency problem but creates a water one — tens of thousands of litres per megawatt annually, in exactly the water-stressed states where much of India’s utility-scale capacity sits.
Robotic cleaning addresses both at once, while cutting labour costs by more than half compared with manual crews. With robotic-cleaning penetration of utility-scale capacity still in the single digits, modules are the settled story in this supply chain right now; robotics is the one still being written.
It would be reasonable to assume that as one segment cools and another heats up, the compliance burden might ease somewhere in the mix. It hasn’t. If anything, the opposite is true — customs scrutiny on renewable equipment, across every category, is only getting tighter, and customs is no longer a post-shipment formality. India’s customs process has digitised rapidly over the past two years, and with it has come a level of scrutiny that didn’t exist before. Online video examinations, once rare, are now routine for certain cargo categories, and documentation errors that used to be absorbed as minor friction now trigger additional verification, added cost, and delay.
Classification itself is more exacting than commonly assumed. Both Indian and Chinese customs apply the same underlying logic: goods are assessed first in the condition they are presented in — whether complete, incomplete, unassembled, or disassembled, and whether they carry the essential character of the finished product. Intended purpose or end-use is considered only where the relevant tariff heading, legal notes, exemption, or regulatory requirement makes it material.
The stakes of getting that sequence right show up clearly with cleaning robots. Correctly classified, they fall under India’s tariff heading for industrial robots — automated, purpose-built machines performing a defined task, in the same family as welding, palletising, and inspection robots used across manufacturing — which carries a meaningfully lighter duty burden than modules and cells themselves face. Classified instead as a generic mechanical tool, or folded into a household-appliance category built for vacuum cleaners and kitchen equipment, the same physical shipment faces a different duty rate, and potentially a different certification pathway entirely. The hardware doesn’t change between those outcomes. Only the paperwork does.
That second possibility is about to get a live test. A new quality-control order covering household, commercial, and similar electrical appliances takes effect on 1 October 2026, requiring BIS certification and the ISI mark across ninety appliance categories, including battery-operated cleaning equipment. Nothing in the order names solar-panel robots specifically, and nothing about how it interacts with equipment already treated as industrial machinery has been tested in practice yet. Importers bringing in this equipment over the coming months are making a defensible judgment call, not following settled precedent.
Layered on top of classification is a second, less understood challenge: figuring out who is responsible for which compliance document. BIS certification is generally the shipper or manufacturer’s responsibility, though it can be furnished instead by a licensed Indian representative of that shipper. Extended Producer Responsibility obligations — covering plastics, e-waste, and lithium batteries, all common in solar and storage equipment — sit with the consignee instead. Consider how this plays out in practice: a shipment of autonomous cleaning robots includes battery components that aren’t separately declared, an omission that is rarely malicious so much as habitual. The gap surfaces only after the container has arrived and customs opens it for examination, by which point reconstructing the paperwork trail quickly is difficult, and penalties and delay costs are added to the bill. It’s avoidable, but only if the declaration is checked against the full bill of materials before the container is sealed, not after it’s opened at an Indian port.
The same discipline applies to money, not just paperwork. Shipments moving under DDP terms depend on duty being remitted from the exporting country and received in India in time to clear customs without penalty — a transfer that typically takes a minimum of 24 hours on working days after currency conversion, with a weekend or holiday widening that window considerably. And even when the paperwork and payment are both right, physical infrastructure can still force costly detours: port congestion at major gateways has, on more than one occasion, pushed cargo destined for a nearby port onto a route nearly double the distance, with transport costs to match.
“Customs and compliance should start at the PO stage itself”
That’s the real shift underneath both stories — the shrinking one and the growing one. Whether it’s a panel now sourced domestically because of ALMM, or a cleaning robot imported because nothing else fills that role yet, the paperwork that used to get resolved after the container landed now has to be settled before the purchase order is even signed. Classification decided, certification pathway confirmed, BIS and EPR responsibilities assigned, payment timelines built around India’s clearance calendar rather than the exporter’s. The equipment moving through India’s solar supply chain keeps changing. That discipline doesn’t — and the manufacturers who build it in from the PO stage will find this market considerably easier to operate in than those still learning it one shipment at a time.
Fulcrum International is a Chennai-based freight forwarding and logistics company working on cross-border equipment movement, including for the renewable energy sector.
The views and opinions expressed in this article are the author’s own, and do not necessarily reflect those held by pv magazine.
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