EN 
PT_BR 
INMETRO (National Institute of Metrology, Quality and Technology) changed two ordinances for the certification of photovoltaic modules in August this year: Ordinance No. 258, with the adoption of the risk classification for products, which modifies the rules for maintenance, renewal, suspension and cancellation of registration.
The other was the Ordinance No. 282, in which objects regulated under the Dconf (Conformity Assessment Board) that present a slight, irrelevant or non-existent risk will be exempt from the public act of release.
William Bonjardim, supervisor of the commercial and marketing area at Yes Certificação, analyzed the main changes imposed by INMETRO and highlighted four changes that were impactful.
“The first is that INMETRO retreats from a decision it had made in 2019, which would be for each importer to have its own registration. In other words, everyone should register in the system and grant registration, regardless of whether they are bringing a product that has already been documented”, Bonjardim pointed out.
“Today, with this amendment to Ordinance No. 258, it is once again authorized for companies holding the registration to authorize their customers to make imports on an orderly basis. This is a very important change because several representatives, previously, only presented an authorization to their customers and they had no problem granting the LI (Import License)”, he highlighted.
“As of this update, in addition to declaring which CNPJs would be authorized, it is only necessary to grant the authorization letter again. In theory, companies will be able to grant LI easily”, pointed out the expert.
2nd change
The second change is the issue of registration statuses, which have undergone small changes, and the process of evaluating each status. Previously, there were four: the active; active with restriction; canceled and; suspended. With the publication of the ordinance, a new status was created: inactive.
“If the company wants to stop the import of that product, it requests the inactivation of its registration, presents documents justifying the need to inactivate and, all the products that it brought before this inactivation petition, would be regular on the market and can be sold smoothly . Previously, this was a requested step with restricted assets, but it was difficult to obtain registration”, explained the executive.
According to Bonjardim, the suspension resulted in a change in behavior. Previously, if the maintenance deadline was missed, which was every 12 months, importers would have their registrations suspended.
“If you had a shipment in transit with this registration suspended, it would not be possible to grant the LI and the goods would be blocked at the port. Therefore, the suspension of registration will only be applied if INMETRO identifies any irregularity. However, a simple missed maintenance deadline will no longer suspend registration and harm companies”, highlighted Bonjardim.
3rd change
The third change that the expert emphasized is valid based on the modifications to Ordinance 282. All products regulated by INMETRO that require registration were classified into three risk levels. In the case of photovoltaic equipment, they were classified as risk level two.
“This level grants registration without prior analysis. What does that mean? Generally, in the previous process, you launched the request to grant registration, paid the RU invoice, waited for this payment to be written off and INMETRO analyzed all the documentation. If everything was regularized, registration would be achieved in approximately 15 to 30 days. Today, products classified at risk level 2 will have their registrations granted within 48 hours”, explained Bonjardim.
However, he emphasized that this analysis, even though it is not carried out at the time of the request, takes up to 100 days to be carried out. During this period, if any irregularity is identified, the registration will be suspended.
4th change
The fourth change impacts maintenance. Today the Orchestra system There is no longer a maintenance task nor a scope change task, which was replaced by a registry change.
“In this new procedure, you will fill in the registration field and go through the process of including or excluding your products. Previously, this task was blocked for attaching documents and reports if the products that were registered did not change,” said Bonjardim.
“Currently, the 'request change of registration' task is also used for you to attach documents relevant to maintaining your registration. So, in the case of solar panels, the test report, term of commitment and other documents can be attached even without any change to the products registered in the system”, he concluded.
Photovoltaic inverter certification process
A question that integrators and distributors have in relation to INMETRO is the certification process for photovoltaic inverters, which has a period of four years.
For William Bonjardim, this is a very pertinent issue, as, according to him, there is a flaw in the typing of ordinances. “There is a theoretical and practical expiration date”.
