The All India Solar Module Manufacturers (AISMM) has urged Union Minister for New and Renewable Energy (MNRE) Pralhad Joshi to provide an 18-month, output-linked transition for the mandatory use of solar cells listed under the Approved List of Models and Manufacturers (ALMM) List-II across all project categories.

In a letter, it proposed a joint audit using Ministry records and real-time operational data to verify actual domestic cell production and merchant availability. AISMM also sought transparent assessments of captive consumption, merchant supply, TOPCon capacity, M10R and G12R compatibility, quality, efficiency, reliability, and pricing.

The association also sought annual assessments of merchant cell availability and the inclusion of independent module manufacturers in future technical and policy consultations. It also sought a meeting with the Prime Minister to present its case for an extension.

AISMM alleged that standalone module manufacturers were not adequately consulted while framing the ALMM List-II implementation framework or before issuing the July 18 memorandum, despite representing the segment most directly affected by domestic cell availability.

AISMM represents more than 140 standalone module manufacturing units with approximately ₹360 billion (~$3.73 billion) of largely bank-funded investment, around 75,000 jobs, and nearly ₹100 billion (~$1.04 billion) of ALMM-compliant module inventory that could be stranded.

The manufacturers said that while they support domestic cell production and the government’s self-reliance objectives, they were asking for additional time to align the mandate with actual production rather than listed nameplate capacity.

Cell Supply Gap

India has approximately 199 GW of listed module capacity under ALMM List-I, compared with 30.508 GW of listed cell capacity across 13 companies under the seventh revision of ALMM List-II dated April 30, 2026.

Cell capacity is equivalent to only about 15% of listed module capacity.

AISMM said domestic cell lines operate at approximately 50% to 55% utilization while several facilities remain under ramp-up. At 55% utilization, estimated usable cell output falls further down to 16.779 GW.

The association estimated actual annual domestic cell production at approximately 12 GW to 13 GW, compared with solar installations of around 60 GW during the previous year.

It said MNRE must distinguish between nameplate capacity, operational output, and merchant availability. Merchant supply is lower because vertically integrated manufacturers use cells in their own module factories.

AISMM said nine integrated manufacturers have approximately 53.5 GW of module capacity and 24 GW of cell capacity. As their module capacity exceeds their cell capacity, they are likely to consume most cell production internally, leaving limited supply for over 140 independent module manufacturers.

Limited Exemption

The Ministry’s July 18, 2026, memorandum allows net-metering and open access projects commissioned by December 31, 2026, to use ALMM List-I modules without complying with the ALMM List-II solar cell requirement.

The association said the exemption provides limited temporary relief but does not resolve shortages in domestic merchant cell availability, technology and format compatibility, cell quality, and pricing.

AISMM said the exemption excludes utility-scale projects, government programs, and other segments that account for most module demand.

It estimated that net-metering and open access projects could commission only a few gigawatts during the exemption period, compared with India’s approximately 200 GW module manufacturing base.

The association also said the practical window is shorter than the five and a half months between July 18 and December 31. Nearly three and a half months coincide with the monsoon and its extended spell across several states, when rooftop and ground-mounted installations could be affected.

Modules would need to be delivered by the end of November 2026 to allow time for installation, distribution company inspection, metering, testing, and grid synchronization. This leaves four to four and a half months for order execution, including three and a half monsoon-affected months and barely one month of relatively unhindered installation activity.

AISMM said manufacturers cannot plan capacity utilization, working capital, employment, contracting, or production on this limited window. From January 1, 2027, projects in the exempted categories will again be required to use domestic cells, returning the industry to the same supply constraints.

It said the government had previously provided only a narrow exemption for advanced-stage projects meeting conditions such as substantial land possession, financial closure, connectivity approvals, and significant project completion, which it argued benefited only projects nearing commissioning.

Government Program Demand

AISMM estimated domestic cell demand of approximately 30 GW from government programs alone.

PM Surya Ghar: Muft Bijli Yojana could require around 18 GW for approximately six million pending residential installations. The program targets 10 million homes by the financial year 2027, with around four million solarized and six million pending.

Components B and C of PM-KUSUM could require another 4 GW to 5 GW, while the Central Public Sector Undertaking Program II and other domestic content requirement programs could require 7 GW to 8 GW.

The estimated 30 GW demand exceeds the 12 GW to 13 GW of actual production and the estimated usable output of 16.779 GW.

AISMM said these programs would absorb most domestic production, leaving little supply for commercial and industrial, open access, group captive, retail, and other projects.

Technology and Format Constraints

Of the 30.508 GW listed capacity, 16.201 GW is Mono-PERC, 9.636 GW is TOPCon, 1.238 GW is heterojunction, and 3.433 GW is thin-film.

AISMM estimated that approximately 13.25 GW, or 54%, of available capacity is Mono-PERC, while about 9.6 GW, or 39%, is TOPCon.

It said module demand has shifted toward high-efficiency TOPCon products, particularly modules using G12R cells and ratings of 600 W and above.

Much of the available TOPCon capacity uses the M10R format, while many domestic module lines are configured for G12R cells.

Switching formats could require production line changes, testing, certification, bill-of-material revisions, and customer approvals.

AISMM asked whether India would have around 60 GW of commercially available TOPCon cell capacity by January 1, 2027, after accounting for captive consumption by integrated manufacturers.

Quality and Warranty Risk

Module manufacturers typically provide performance warranties of 25 to 30 years. AISMM said cell quality is central to those warranties and directly affects manufacturers’ warranty, reputational, and financial risk.

The association warned that manufacturers could be compelled to use cells without adequate choice regarding efficiency, reliability, format, quality, or operating history.

It cited cell efficiencies of 25.27% for Adani Solar and 24.62% for Emmvee. Newly commissioned cell lines may require approximately eight months to stabilize efficiency, yield, wastage, and breakage.

It asked the Ministry to evaluate proven quality and merchant availability rather than relying only on listed production capacity.

Cell Manufacturing Timelines

A module manufacturing line takes approximately six months to construct and commission and another three months to achieve rated quality and yield. AISMM estimated the capital cost at approximately ₹1 billion (~$10.36 million) per GW.

A solar cell line requires approximately 24 months for construction and commissioning, followed by six to eight months of ramp-up.

Each 1 GW cell line requires around 15 acres of contiguous land, approximately 10 MW of dedicated electricity supply, substation infrastructure, and substantial industrial water allocation. The estimated capital cost is approximately ₹6 billion (~$62.16 million) per GW.

AISMM said the total construction and stabilization period is around 30 months.

ALMM List-II was notified on December 9, 2024, for implementation from June 1, 2026, providing approximately 18 months. Several module manufacturers developing cell facilities could require another 18 months to two years to begin production and secure ALMM listing.

An additional 18 months would provide a total implementation period of approximately three years.

AISMM also cited the phased implementation of ALMM List-I, noting that module requirements were introduced gradually and temporarily kept in abeyance before being reinstated. It argued that an 18-month transition for ALMM List-II would similarly align implementation with actual domestic manufacturing readiness rather than reverse the policy objective.

Cell Prices and Manufacturer Profitability

AISMM said imported Chinese cells cost approximately 4 cents/W to 4.8 cents/W, while domestic cells compliant with domestic content requirements cost around 14 cents/W to 16.5 cents/W.

It said Chinese cells remained available at around 4 cents/W despite the withdrawal of a 9% export incentive.

The 13 enlisted manufacturers have combined listed cell capacity of 30.508 GW and estimated usable output of 16.779 GW. They received combined production-linked incentive awards of ₹107.01 billion (~$1.11 billion).

AISMM reported combined revenue of ₹677.10 billion (~$7.02 billion), EBITDA of ₹167.94 billion (~$1.74 billion), and profit after tax of ₹118.17 billion (~$1.22 billion).

The aggregate EBITDA margin was approximately 27.6% for nine companies reporting EBITDA, based on revenue of ₹607.42 billion (~$6.29 billion). The aggregate profit margin was approximately 17.5%.

The financial figures include modules and other business segments and do not represent cell operations alone.

Adani Solar had 4.237 GW of listed capacity, Waaree Energies 5.251 GW, TP Solar 4.813 GW, First Solar 3.433 GW, Premier Energies 3.282 GW, ReNew Photovoltaics 1.766 GW, Jupiter International 1.770 GW, Emmvee Energy 1.553 GW, Reliance Industries 1.238 GW, Websol Energy 1.202 GW, Evervolt Solar Technology 1.074 GW, RenewSys India 452 MW, and Fujiyama Power 437 MW.

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