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The Ministry of New and Renewable Energy issues clarification on Approved Models and Manufacturers of Solar Photovoltaic Modules (Requirements for Compulsory Registration) Order, 2019

The Ministry of New and Renewable Energy (“MNRE”), vide Office Memorandum (“OM”) dated October 14, 2024[1], issued clarification on ‘Approved Models & Manufacturers of Solar Photovoltaic Modules (Requirement for Compulsory Registration) Order, 2019’ dated January 2, 2019 (“ALMM Order”). Notably, MNRE has reiterated its earlier clarification that ALMM Order will not be applicable for open access and net-metering renewable energy (“RE”) projects where the first application has been made before October 1, 2022, to any relevant entities, for grant of:

in-principle approval; or
No Objection Certificate (“NOC”); or
government order; or
any other approvals, as may be required for open access and net-metering of RE projects.

The OM clarifies the following:

under the ALMM Order, MNRE inter alia provided that:
- models and manufacturers of Solar Photovoltaic (“Solar PV”) cells and modules will be enlisted, after due inspection of manufacturing facilities. A list namely Approved List of Models and Manufacturers (“ALMM”) will be published and will consist of:
  - LIST-I specifying models and manufacturers of Solar PV modules; and
  - LIST-II specifying models and manufacturers of Solar PV cells;
- models and manufacturers included in ALMM will be eligible for use in the Government/Government assisted projects/projects under Government schemes and programs, installed in the country;
MNRE had issued a similar clarification earlier vide an order[2] dated October 7, 2022, in response to representations received for further clarity on MNRE’s earlier OMs[3] dated January 13, 2022[4] and March 28, 2022[5]. In this regard, MNRE had inter alia clarified that amendments to ALMM Order, vide the OMs dated January 13, 2022, and March 28, 2022, shall not be applicable for open access and net-metering renewable energy projects where the first application has been made before October 01, 2022, to any relevant entities.
the term ‘relevant entities’ includes distribution licensee(s)/State transmission utility/Central Transmission Utility of India Limited/State Load Despatch Centre/National Load Despatch Centre/Regional Load Despatch Centre/Grid Controller of India Limited/State Nodal Agency for RE (power/energy/RE department of the State/Union Territory).

Conclusion

MNRE by issuing the said clarification has emphasised on the cut-off date (i.e., October 1, 2022) for the applicability of the ALMM Order and subsequent amendments on RE projects which have applied for open access and net metering facility. Such clarification by MNRE is crucial since this will:

not only ensure that there is a proper compliance of the ALMM Order by the Project Developers who have submitted their bid after the cut-off date;
but also provide clarity for project developers who have initiated their projects prior to the ALMM Order with respect to applicability of the ALMM Order and subsequent amendments on their respective projects.

The prism is prepared by:

Anupam Verma
Partner

Rahul Kinra
Partner

Girdhar Gopal Khattar
Associate

For more details, please contact [email protected].

[1] O.M. No. 283/54/2018-GRID SOLAR-Part(2).

[2] O.M. No: 283/54/2018-GRID SOLAR-Part (5).

[3] O.M. No. 283/54/2018-GRID SOLAR-Part(2) dated January 13, 2022, and O.M. No. 283/54/2018-GRID SOLAR-Part(2) dated March 28, 2022.

[4] MNRE vide OM dated January 13, 2022, had inter alia amended ALMM Order to include ‘net metering’ and ‘open access’ projects and provided that the amendment shall be applicable to RE projects which have applied for open access and net metering facility from April 1, 2022.

[5] MNRE vide OM dated March 28, 2022, had inter alia extended the applicability of amendment dated January 13, 2022, from April 1, 2022, to October 1, 2022.