Glass, encapsulants, frames, junction boxes, cables, intermediate materials, packaging and manufacturing equipment now occupy a clearer place in the PADIS architecture. Law 14,968/2024 rewrote the program to expressly include inputs in the photovoltaic chain. The broader scope also requires every supplier to identify the route through which it participates.
A module supply chain brings together companies in very different positions. Some sell to a qualified manufacturer. Some operate plants dedicated to one input and seek their own qualification. Integrated manufacturers produce the module and internalize earlier stages. The same statute creates different consequences for each configuration.
The law added “and their inputs”
Article 2(I)(f) of Law 11,484/2007 now covers production of photovoltaic cells, modules or panels, together with their inputs, intermediate materials and packaging, parts, machinery and equipment intended for manufacturing.
Decree 13,065/2026 reproduced this architecture in the regulation. The current text no longer relies on the former closed list of input codes and organizes the analysis around the industrial activity and destination for photovoltaic manufacturing.
Earlier official documents had already described this policy direction. In a technology-needs assessment, MCTI presented PADIS as an instrument to attract investment in cells, modules, panels and strategic production-chain inputs. Law 14,968 converted that direction into express statutory language.
Three routes concentrate supply-chain decisions
Sells an input destined for an incentivized activity. The transaction depends on the purchaser's qualification, demonstrable destination and tax requirements for the sale.
Seeks its own qualification based on the production described in item (f). It must support product, exclusivity, PPB, R&D and the benefit perimeter.
Produces cells, modules or panels and incorporates earlier stages or inputs within the qualified operation. Integration changes purchasing, fixed assets, accounting and the R&D portfolio.
In the first route, a reduced rate may apply to a transaction destined for the qualified company under the conditions of article 3. The supplier needs to know the purchaser, the incentivized use and which information accompanies the invoice.
In the second route, the input plant seeks recognition as a qualifying activity. The statutory basis became stronger in 2024 and 2026, while specific products may still require administrative confirmation. In the third, the core manufacturer must decide whether vertical integration improves cost, supply security and documentary control.
The end of the closed list requires better engineering
Before the 2024 reform, a list of NCM codes dominated the reading of photovoltaic inputs. That structure was revoked. The current criterion follows activity and destination, which is more adaptable to technological evolution. It also requires stronger technical evidence.
A material with broad uses does not become a photovoltaic input solely because it can enter a module. Specification, function, contractual destination, lot traceability, manufacturing process and served market form the evidence set. The more generic the product, the more clearly the incentivized application should be delimited.
For photovoltaic glass, low iron content, transmittance, tempering, anti-reflective coating and supply contracts help distinguish the application from ordinary glass. A similar approach may apply to polymers, junction boxes, conductors and metal parts, always based on the technical reality of the product.
Four questions should remain attached to the case
The broader wording did not resolve every issue. Meridian maintains a structured technical inquiry for a dedicated photovoltaic-glass plant. The questions show where direct reading ends and formal MCTI confirmation begins.
- Can the input qualify on its own?
Item (f) supports this reading, while acceptance for a specific product belongs in the application process.
- How does exclusivity operate?
The statute mentions photovoltaic components, while the decree treats the requirement differently, creating a point for formal interpretation.
- Which R&D qualifies?
An input plant must confirm that research on its material and process sits within an accepted technology field.
- What is the corporate income tax scope?
The text reaches item I activities, while the use of “devices” calls for care when analyzing input revenue.
PPB adds another question. The application must demonstrate compliance with the production process established for the product. Where no specific act clearly applies to an input, the demonstration route should be clarified before treating qualification as a closed assumption.
The benefit follows the supply architecture
For module manufacturers, the amended statute expands the ways to organize purchases, imports, productive assets and local development. For suppliers, it creates an agenda that combines market, product specification, contracts and potential own qualification.
The most important decisions occur before operations:
- Define each company's role
Supplier, dedicated qualified company and integrated manufacturer have different rights, obligations and risks.
- Map the demonstrable destination
Contract, order, specification, lot and invoice must support use in the incentivized chain.
- Choose where qualification sits
The corporate structure affects exclusivity, accounting, R&D and program operations.
- Sequence the plant and application
The qualification date interacts with equipment purchases, imports, production start and invoicing.
- Separate the open case from confirmed benefits
The financial model should show scenarios and validity conditions for each incentive.
The chain entered the statute and value depends on the route
The PADIS reform created a concrete opportunity to deepen photovoltaic manufacturing in Brazil. Suppliers may participate in incentivized transactions. Dedicated companies gained a stronger qualification case. Integrated manufacturers can redesign purchasing and production.
The decision starts with each company's position in the chain and the evidence it can sustain.
Legal and institutional sources
- Law 11,484/2007, consolidated textItem (f), benefits and qualification rules.
- Law 14,968/2024Expressly includes inputs and reorganizes PADIS.
- Decree 10,615/2021, updated textConsolidated program regulation.
- Decree 13,065/2026Updates qualification and photovoltaic-chain activities.
- MCTI technology-needs assessmentConnects PADIS, photovoltaic production and strategic inputs.
- MDIC reference note on invertersAnalyzes progressive industrial deepening, PPB and CFI validation.
- PADIS legislation at MCTIOfficial index of program rules.
Informational content with a regulatory baseline of August 25, 2026. Each input requires validation of product, activity, destination, exclusivity, PPB, R&D and qualification act.