Summary:
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**Key Provisions and Effective Date:**
– **New ALMM List-III (Wafers):** A new list will be created for approved wafer manufacturers.
– **Effective Date:** The mandate to use wafers from this list will come into effect on **June 1, 2028**.
– **Condition for Issuance:** The list will only be issued if there are at least **three independent wafer manufacturing units** (not under common ownership) with a combined annual capacity of at least **15 GW**.
– **Ingot-Waiver Integration:** To be enlisted, a manufacturer must have an **ingot manufacturing capacity equivalent** to the wafer capacity they seek to enlist. This ensures that “wafer manufacturing” capacity in the list truly reflects integrated ingot and wafer production.
### Detailed Business Impact and Implementation
The memorandum creates a cascading compliance requirement and defines several critical dates and exemptions that are crucial for project developers, EPC contractors, and manufacturers.
**1. The Mandatory Supply Chain Cascade:**
– All projects under the ALMM purview must use:
1. **Modules** from ALMM List-I.
2. **Cells** used in those modules must be from ALMM List-II.
3. **Wafers** used in those cells must be from the new ALMM List-III.
– This creates a fully traceable and approved domestic supply chain from wafer to module.
**2. Project Transition Rules & Business Impact:**
The memorandum uses two key dates to determine applicability:
– **’Cut-Off Date’:** 7 days after the initial ALMM List-III for wafers is issued (date TBD, but before June 1, 2028).
– **’Effective Date’:** June 1, 2028.
| Project Bidding / Commissioning Status | Module Requirement (List-I) | Cell Requirement (List-II) | Wafer Requirement (List-III) | Business Impact Summary |
| :— | :— | :— | :— | :— |
| **Last Bid Date on or before the ‘Cut-Off Date’** | **Mandatory** | **Mandatory** | **Exempted** | **Grandfathered Projects:** This is the most critical exemption. Projects that have already bid by the Cut-Off Date are secured against the wafer mandate, even if they commission after June 1, 2028. This protects the pipeline of projects planned before the new rule. |
| **Last Bid Date after the ‘Cut-Off Date’** | **Mandatory** | **Mandatory** | **Mandatory** | **New Projects:** All new tenders/RfSs issued after the Cut-Off Date must explicitly require the full approved supply chain, including wafers. |
| **EPC/Supply Tenders after ‘Cut-Off Date’ (Project Bid before)** | **Mandatory** | **Mandatory** | **Exempted** | **Continuity for Grandfathered Projects:** Even if a project owner issues an EPC tender after the Cut-Off Date, if their original project bid was submitted before it, the wafer exemption remains. |
**3. Special Provisions and Exemptions:**
– **Exemption from Cell Mandate = Exemption from Wafer Mandate:** Any project category already exempt from using ALMM List-II cells is automatically exempt from using ALMM List-III wafers.
– **Net-metering and Open Access Projects:**
– Commissioned **before** June 1, 2028: Exempt from wafer mandate.
– Commissioned **on or after** June 1, 2028: Must use modules, cells, and wafers from all three respective ALMM lists.
– **Behind-the-Meter, Captive Government Projects:**
– Commissioned **before** June 1, 2026: Only modules mandatory (cells and wafers exempt).
– Commissioned **June 1, 2026 – May 31, 2028**: Modules and cells mandatory (wafers exempt).
– Commissioned **on or after** June 1, 2028: Modules, cells, and wafers all mandatory.
– **Thin-Film Technology:** Solar PV modules based on thin-film technology, manufactured in integrated units, are considered to be in **”deemed compliance”** with the cell and wafer mandate. This is a significant exemption recognizing the different supply chain for thin-film technologies.
– **No Relaxation in DCR:** There will be no relaxation in Domestic Content Requirement (DCR) provisions for specific government schemes like PM-KUSUM, PM Surya Ghar, and CPSU Phase-II.
**4. Post-Effective Date Changes to ALMM Lists:**
– From June 1, 2028, any module in the main ALMM List-I that does not use ALMM List-II cells and List-III wafers will be **delisted**.
– New, separate lists will be created for different categories of projects that are exempt from certain requirements (e.g., List-I(a) for modules using non-approved cells/wafers, List-I(b) for modules using approved cells but non-approved wafers). This allows for a structured market for exempted project categories.
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