Government Clarifies ALMM Enlistment Guidelines for Co-branded Solar Modules
New regulations ask OEMs and brand owners to apprise the ministry of their pact
March 24, 2023
The Ministry of New and Renewable Energy (MNRE) has modified the Approved List of Models and Manufacturers (ALMM) guidelines and provided exceptions to broaden the qualification criteria for modules produced under agreements between an Original Equipment Manufacturer (OEM) and a brand owner.
The amended rules have come after the implementation of the ALMM order for the financial year 2023-24 has been put on hold by the government. As a result, solar projects commissioned by March 31, 2024, will be exempted from the requirement of procuring modules listed under ALMM.
Under the revised guidelines, if an applicant has multiple manufacturing sites or sources the finished products from other manufacturers and sells them under their brand name, all manufacturing sites, including the applicant’s own, must be inspected unless an exception applies.
An exception applies if:
- An ALMM enlisted model of a brand owner is manufactured under a co-branding arrangement in the ALMM enlisted manufacturing facility of another OEM using the same manufacturing process and bill of materials.
- 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.
A co-branding arrangement is a partnership between two companies where the brand owner and OEM share manufacturing facilities. The brand owner uses the OEM’s manufacturing facility to manufacture products but uses its brand name.
The companies execute an agreement about the co-branding arrangement, and the brand owner gives an order to the OEM for a specific capacity.
The existing guidelines stated that if an applicant has multiple manufacturing sites or sources of finished products from other manufacturers and sells them under their own brand name, all manufacturing sites, including the applicant’s own, must be inspected.
The new clause mandates that 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 clearly 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 as an addition to their existing entry in 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.
The inspection fee for each additional site in the same country will be 50% of the original inspection fee. If additional sites are located in different countries, the inspection fee for each site will remain the same.
The ALMM mandate has resulted in delays in project development. India could only add 13 GW of solar capacity in 2022, against 10.2 GW installed in 2021, according to the 2022 Q4 & Annual India Solar Market Update.