Absolute Ecosystem for Solar Success: MNRE Issues Guidelines for Module Testing
28 Jul 2021
Absolute ecosystem needed to secure India’s solar success
Indian govt’ must create a complete ecosystem to ensure the effective on-ground execution of its ambitious solar program. This includes investing in lab infra, & skills for technical due diligence, energy yield assessment & forecasting. Solar businesses across country welcomes the GoI’s push to position its RE market as a global leader. However, a complete ecosystem must be created to ensure its plans are successfully achieved.
Testing, standardization & certification requirements
India has taken global leadership in the solar sector, & the govt’ has challenged itself to meet & surpass the 100 GW target for solar by 2022. While the ambitious vision to transform India as a renewable superpower is laudable, we must also be vigilant about the performance of the projects in the long run. Quality control order for solar products introduced by the MNRE, which will be enforced from August this year, is a necessary step to secure the quality & reliability of renewable power in the country. In light of the legislation announced last year, both pvt. as well as govt’ laboratories have ramped up their capacity to meet demand that will arise from mandatory in-country testing. Currently, solar energy is contributing to 21 GW of the RE mix. We need to add 12-15 GW every year to realize India’s solar dream. Govt’ is also contemplating expansion of solar tech. with hybrid projects & floating solar parks. Even as these initiatives are welcome, there should be a complete ecosystem in place to ensure the success of the solar program whether in terms of lab infra, the registration scheme & the ability of manufacturing community to show compliance. Govt’ must hence invest in expanding the lab infra, as well as skilling for technical due diligence, energy yield assessment & forecasting to enable on-ground execution of the program. We also need system-level standards to protect grid stability, which the CEA is working on.
Challenges in testing, standardization & certification
Even before the announcement of the quality control order that mandates in-country testing as per the Indian standards, the MNRE defined guidelines for solar products in accordance with the IEC Standards, to ensure quality of products deployed in India. As the Indian standards for solar PV modules, inverters devices & batteries are harmonized with IEC, the main challenge is to ensure compliance to the standards. With the element of surveillance introduced by the BIS in the new regulation, there will be greater accountability on part of the players, both domestic & international, to ensure the supply of quality products for projects in the country. To support a fledgling industry like solar, it is imp. that regulations act as a complimentary force that sustains growth rather than inhibit players from participation. A graded approach to enhance intensity of mandatory compliance is necessary, & it is heartening that the govt’ has chosen the right path in this regard. This is a serious issue, which the govt’ is contemplating. There is a BIS committee already in place to evaluate the IEC standard for transportation & shipping of solar panels, & customize it to Indian road & labor conditions. Presently, from the lab perspective, CoS perform electroluminescence (EL) imaging before proceeding with testing to evaluate whether the sample is free from breakages or scratches. The EL camera acts like an X-Ray & detects damages that cannot be seen by the naked eye. We can issue reports on damaged panels for developers to claim insurance or use warranty.
Adhering to guidelines
India’s low tariff driven solar PV program is hugely attractive to a wide spectrum of players in the industry. While some manufacturers are quality conscious & ensure uniformity across the product line, some would be diligent in compliance only with the ‘golden sample’ the product they submit for testing. To gain competitive edge in the tender process, they may not ensure quality compliance as a norm for mass production, as compliance is a time-consuming effort. While market surveillance will address this issue, it is vital to create a quality culture in the manufacturing community, like in the pharma sector, where players view compliance not as one-time phenomenon, but as a business priority that will provide them with greater market access. Govt’ could also, at a later stage, introduce pre-dispatch inspections, where a batch of products, rather than a single product of a consignment, is tested for quality assurance before these are deployed in a project.
Indigenousness
Before the quality control order, the testing industry mainly catered to Indian players. Now, with the introduction of mandatory in-country testing, nearly 80% of the demand comes from international players, primarily because compliance is the essential first step to gain market access. Like other high-demand sectors, such as medical devices & electronics, developing a robust manufacturing ecosystem for components is essential to increase the share of the local manufacturing community in the vibrant market for solar energy in the country.
Comparing cross country standards
A basic requirement for export is that the product must be compliant with relevant standards or regulations. The fact that a small number of Indian manufacturers cater to the export market for solar products is proof that Indian players have the ability to gain market entry abroad. With India being among the top three nations for renewable power, it is natural that the market for solar is here & local manufacturers are hence keen on addressing the local demand. It is critical to note that Indian standards across sectors are always harmonized with international norms, & with country deviations that address specific local conditions. In the case of solar, while Indian standards are concurrent with the IEC Standards, the regulator may introduce variations in testing for certain environmental & climatic conditions, like dust & mist, & do away with certain requirements, like testing for hail storms. The international community is gearing up to adopt the 2016 revision of the IEC Standards, which takes into account the impact of increased UV radiation over the past decade & also calls for evaluation of power & changes in sequence of testing, among other considerations. It is also appreciable that the govt’ is conscious of upgrading the Indian standards in the solar sector to the latest changes in the international standards, but in a phased manner, depending on the ecosystem & market considerations of the stakeholders involved.
Efficiency of PV Systems
As a price conscious segment, it is essential that consumers in rooftop solar are educated about the inverse relationship between price & quality, & are made aware of the long-term implications of poor quality installations. The biggest risk befalls small consumers, whose power requirement is limited to one or a few kilowatts. To assuage consumer fears, the govt’ must create a robust ecosystem for standards & certification, both at the individual product as well as the systems level. To ensure quality & reliability of power, there must be a surveillance mechanism for the entire manufacturing supply chain along the lines of empanelment of solar developers that is present now. Another mechanism is to have a fair price benchmark that would ensure no compromise on quality & performance of the rooftop solar assets. There must be a transparent system for consumers to access a list of all manufacturers in the market & the prices they supply at. The California Energy Commission in the United States is a good model to follow.
Incentives and Opportunities
Currently, the laboratories in India are only testing, & are not involved in certification. Private laboratories, to maintain their non-partisanship, do not need incentives or support. It is, however, imp. that the govt’ invests in research & development for components, provides incentives like tax sops & depreciation allowance to boost the manufacturing community. This is essential for Indian players to reap the dividend of ‘Make in India’, as they are now assemblers & not end-to-end solution providers. The govt’ must also create country-specific standards for solar cells, which is missing right now. To realize the goal of ‘Make in India,’ we need research-based test laboratories that can guide & advise the manufacturing community for both development, as well as compliance testing. Laboratories can especially play a prominent role in handholding the component sector. As a co-founder of the International Solar Alliance (ISA), member countries will look up to India for support in standards & testing as well, creating additional need for expansion of the testing, inspection & certification (TIC) industry. While the opportunities for testing are vibrant, it is imp. for new entrants to realize that TIC is not a profiteering sector, it is rather driven by the value. TIC companies have a unique privilege of bringing value to every stakeholder in the manufacturing ecosystem, from the component to the end product stage. We are able to engage with each touchpoint in the supply chain & bring stakeholders together with no agenda other than to better safety, quality & performance outcomes & build consumer trust. As the solar sector, like the wind industry, undergoes consolidation & witnesses the entry of new players which do not have the expertise to perform the health assessment of projects, this has created new service opportunities for technical due diligence. Given that solar power is ultimately about the performance of the projects & not just installed capacity, technical due diligence should be the first layer, before commercial & financial diligence.
New guidelines for conducting lab tests on Solar PV modules
MNRE has issued a series of guidelines for conducting tests on solar PV modules - crystalline & thin film, including bifacial type. Tests are to be conducted by test labs for compulsory registration with the BIS for the implementation of the Solar Photovoltaics Systems, Devices & Component Goods Order 2017. Guidelines are also issued to facilitate labs & manufacturers for approval of the ‘product family’. Typically, all models which are included in the family have common design, construction, parts, or assemblies imp. to ensure conformity with applicable requirements. According to the guidelines for quantitative selection of samples, a total eight modules will be taken at random from a production batch. All these modules should have been manufactured from the specified materials & components in accordance with the relevant drawings & process sheets. Every module should contain- name, monogram or symbol of manufacturer, model no, unique serial number, nominal wattage, year & country of origin, & brand name if applicable.
MNRE has instructed test labs to not accept the modules for testing without the above details. Similarly, guidelines for PV modules’ safety qualification & requirements for testing & constructions have also been issued by the govt’. In case of change in cell tech. or modification in system, back sheet material, junction box, power output, module size etc., govt’ has made provisions for retesting to maintain the certification. Retesting guidelines permits increase in module size by 20% in length & width but there is no limit to decrease in module size. Apart from these, the guidelines also mandate that different brands should register separately. In line with the changing dynamics of the Indian solar sector, the MNRE recently brought battery energy storage system (BESS) under the ambit of the Solar Photovoltaics, Systems, Devices, & Component Goods (Requirement for Compulsory Registration under BIS Act) Order 2017 in Sep’17. In Apr’18, MNRE had also issued the schedule of implementation of the Quality Control order. Recently, Mercom reported about the dearth of test centers in the country in face of rapid expansion of the domestic renewable industry. Interactions with various project developers & manufacturers in the country revealed that the widespread sentiment of the industry was that the announced National Lab Policy & Quality Control Order are adding a new wrinkle that could slow down project commissioning. The National Lab Policy for RE testing & accreditation was created to improve quality & reliability of RE projects in India. MNRE believes that the country’s target of 175 GW of RE by 2022 has made it necessary to develop & update the standards for various RE systems & their related components & set up performance testing & certification facilities to ensure their quality.
MNRE has also issued a notification stating that the date of self-certification by solar module manufacturers of six products included in the Schedule order No. 2183 (E) has been extended from June 30, 2018 to 4 Sep’18. In Sep’17, MNRE has issued “Solar Photovoltaics, Systems, Devices & Components Goods (Requirements for Compulsory Registration) Order to come into force from September 5, 2018. But the date was advanced to 16 Apr’18 after consultation with various stakeholders including the BIS on condition of self-certification by manufacturers. The order was applicable until 30 Jun’18, but the industry needed more time to comply with the order. Hence, the date has now been extended. Module manufacturers with an annual capacity of less than 50 MW are exempted from the BIS certification for 2 years (till 4 Sep’20). To avail this benefit, they should have a valid IEC Certificate (either 2005 or 2016) for the period & it should have been obtained before 16 Apr’18. There will be an exemption from BIS certification in case the products are required for replacement or as part of commitment or warranty in a previous project. But to get this benefit, there should be a valid IEC certification for the product & only up to two such products would be allowed to be replaced per project per annum. In case, the replacement is more than two products, the manufactures will have to get the product tested in test labs as per Indian standards. The announced National Lab Policy & Quality Control Order are adding a new wrinkle that could slow down project commissioning, according to solar project developers & manufacturers in the country.
Conclusion
After months of rapid growth, India’s solar energy sector is staring at a round of policy & legal uncertainty, & tariff hikes. On 30 July’18, GoI notified a 25% safeguard duty on imported solar panels for a period of 2 years. The duty, typically imposed during import surges, is meant to protect domestic manufacturers. It is now bound to hike solar power tariffs in India since around 90% of panels the sector uses are made in China & Malaysia. There will be an increase (of) close to 30 paisa (Rs.0.31) or 35 paisa. While we are seeing tariffs of around Rs.2.44 per unit, the lowest going forward should be around Rs2.75 per unit. But there’s more to it than just tariff hikes. In Dec’17, a group representing them had sought protection from rising imports. Following a probe, the directorate of safeguards under the finance ministry recommended in Jan’18 a steep 70% duty. In July the directorate brought this figure down to 25%. However, even this was challenged in the Orissa HC by Gurugram-based RE producer ACME Solar & other solar power developers. Last week, the high court passed an order against any such duty being imposed till 20 Aug’18.
So the govt’ may be in contempt of court, implying future legal tussles. This will become a full-blown legal case now. What people will do is they will go to courts; somebody will file a case against (the safeguard duty). It brings in certain uncertainty into the whole programme. All this comes just as the govt’ is chasing a target of 100 GW of solar power in India by 2022. As of today, the installed capacity is only around 22 GW. Whether such duties will serve their purpose at this stage is unclear. India has around half-a-dozen makers of solar cells & modules, with a total capacity of around 3,000 MW. This is hardly enough to meet the country’s burgeoning demand. India will auction close to 25-30 GW a year. Domestic manufacturers are not in a position to manufacture over 3 or 4 GW. Going forward, at least 80% will be imported. So we don’t see the domestic players, in the short term at least, replacing imported ones. While the safeguard duty now puts locally-made panels on par with imported ones in terms of cost, the domestic sector needs to do a lot more to be effective. For instance, it will have to go down the supply chain & make the input components locally instead of importing them & putting the modules together here. Tech., too, needs to improve. In fact, the MNRE admitted in a research note last year that the domestic sector was not being fully exploited because of obsolete tech. The price of solar equipment produced in the country is not competitive as compared to that of foreign manufacturers, especially Chinese manufacturers.
Major problems observed on the quality issues in modules and batteries are - Non-Conformance to nameplate ratings and tolerances for modules and battery; Visual defects in modules – micro-cracks, discoloration of contacts, snail trails, etc.;
Quality of encapsulation material; A significant performance difference reduction after thermal cycling and damp heat test; And inaccurate deep cycle ratings specified by manufacturer in case of solar batteries. In our opinion, better quality of raw material and quality control of the manufacturing process can take care of more than 80% of the issues faced by consumers. None of the standards guarantee 25 years’ life of solar PV modules. It only qualifies that the modules do not have a design flaw, are safe to use, and are likely to survive in the field. For guaranteeing the 25 years’ life, accelerated stress tests must be incorporated in the test flow, in line with the PV durability test initiative suggested by Fraunhofer, Germany. In case of PV modules, Potential Induced Degradation (PID) failures are commonly observed in the solar plants because of high system voltage, hot climate, and humidity levels. Solar PV manufacturers may improve on the encapsulation quality, i.e., choice of material and thickness of encapsulation material for reducing the PID related field failures. Regarding solar batteries, thermal management, and associated components become critical. Here also the choice of material, proper dimensional specification needs to be controlled by the manufacturer.
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