Consulting Services Presentation

June 12, 2025

Dear Sir / Madam,

We are grateful for the opportunity to present JCS Consultoria e Serviços, its work in projects,
studies, analysis and government procedures related to the PV solar and renewable energies
segment and our consulting portfolio for registering objects with Inmetro.

1. About JCS Consulting and Services

JCS – Janousek Consultoria e Serviços specializes in consulting and services for the electronics
and renewable energy segments, providing solutions for the management and improvement of
industrial, commercial and service operations and processes.

With knowledge of the technical specifications of the products and other elements that will be
the subject of the processes, JCS provides a set of differentiated solutions for companies
seeking to adapt their equipment to the regulatory requirements demanded in the import and
commercialization of solar modules, inverters, batteries and storage systems, charge and
discharge controllers and other components of photovoltaic systems.

jcs.janousek.com.br 1 +55 (11) 99776-0168

 2. Areas of activity

Operations Management
Consultancy in the management of industrial, commercial and service operations.
Improvement of manufacturing, supply chain, tax, fiscal and logistics areas.

Ex-Tariffs
Consulting on tax improvement and trade defense strategies.
Preparation of requests for granting, altering, contesting and revoking former tariffs.

Market Analysis
Market analysis and competitiveness studies.
Solar Photovoltaic market report, with detailed import information by manufacturers, models,
volumes and prices charged.

Supplier development
Support in the development of suppliers in Brazil and abroad.
Advice on industrialization processes and product development under OEM regime.

PPB, Finame and Inmetro

Accreditation of suppliers and products at BNDES-Finame.
Accreditation, registration of equipment and objects at Inmetro.
Adaptation of products to PPB and incentive policies (Lei do Bem and others).

Project Due Diligence

Due diligence processes for the solar segment, with assessment of the technical risks of a
renewable energy project.
Independent assessments to support the final analysis processes of projects by developers,
owners and investors.

Government Relations
Monitoring of public policies related to the photovoltaic solar energy segment and potential
impacts on the contractor's strategies.
Monitoring changes in government regulations that may impact companies' business
strategies.
Support and advice in defending clients’ interests before government agencies and trade
associations.

jcs.janousek.com.br 2 +55 (11) 99776-0168

3. About registering objects with Inmetro

Product registration by INMETRO (National Institute of Metrology, Quality and Technology) is an

act that authorizes the importation and commercialization of a product or service in the
national market, allowing the use of the conformity identification seal. The granting of a
registration is subject to the presentation of a valid Certificate of Conformity (Conformity
Assessment Mechanism - Certification), a Test Report issued by an accredited laboratory
(Supplier Declaration - Product) or technical inspection visit (Supplier Declaration - Service) as
provided for in Inmetro Ordinance No. 258, of August 6, 2020.

According to current legislation, the Terms of Reference of the Brazilian Conformity

Assessment System, approved by Conmetro Resolution No. 04, of December 2, 2002, grants
Inmetro the authority to establish guidelines and criteria for the activity of assessing the
conformity of products, systems and services.

Inmetro Ordinance No. 140, of March 21, 2022, updated the minimum performance and safety
regulations for photovoltaic energy systems and equipment, through the Technical Quality
Regulation and the Conformity Assessment Requirements for Equipment for Generation,
Conditioning and Storage of Electric Energy in Photovoltaic Systems, determining rules and
procedures for the manufacture, import and commercialization of components of photovoltaic
solar systems, including:

▪ Photovoltaic modules with power greater than 5Wp;

▪ PWM and MPPT battery charge and discharge controllers;

▪ Inverters for stand-alone or grid-connected systems, with nominal power up to 75 kW, with
or without energy storage;

▪ Batteries for use in photovoltaic systems with lead-acid, nickel-cadmium, nickel-metal

hydride, lithium-ion, sodium nickel chloride, flux or other electrochemical technologies;
which may or may not require an integrated management system (BMS);

The registration of objects must be requested by legal representatives or partners of

manufacturing, importing or marketing companies. Individuals acting as authorized
representatives of companies can also perform registration tasks in the system.

Supplier is a legal entity, public or private, legally established in the country, which carries out
manufacturing or import activities, as the real purchaser, of the product or input in the country,
or provides the service that is part of the regulatory scope of Inmetro.

The Registration is for the exclusive use of the requesting supplier and may be extended to third
parties, provided they are authorized by the registration holder in the list of CNPJs authorized
to use the registration, in an existing process for registration requests and changes in the
Inmetro system.

jcs.janousek.com.br 3 +55 (11) 99776-0168

For components of photovoltaic solar systems, the applicant for registration must issue a
Supplier's Declaration of Conformity by model or product family, accompanied by the
documentation specified in the RGDF Products - General Requirements for Supplier's
Declaration of Conformity of Products, in accordance with the provisions of the Specific
Annexes of the regulation (RAC):

- Technical Specifications Sheet (PET) referring to the model or family of products

submitted to the tests;

- Test report(s) relating to the model or family of products; and

- Test report or certificate of conformity of parts or components relating to the model or

family of products, when applicable.

Each record must correspond simultaneously to:

I - a model or family;
II - a supplier (CNPJ);
III - a manufacturing unit or installation site.

Registrations can be requested by product family and assume similarity between the items that
comprise it, complying with the criteria established in each specific regulation.

Any modification to the design or original characteristics of a registered product or input implies
the need to request a new registration.

For batteries , the family concept applies only to lead-acid, nickel-cadmium and nickel-metal
hydride batteries.

For the registration of lithium batteries and other electrochemicals, the concept of models
applies, which can be grouped according to the following definitions:

Grouping of battery models that have:

(i) same manufacturing unit;

(ii) same manufacturing process;
(iii) same electrochemical composition;
(iv) same topology as the power circuit;
(v) same operating voltage;
(vi) same maximum current;
(vii) same cell shape (cylindrical, prismatic, pouch; when applicable);
(viii) same capacity as the cells in the block/pack composition (when applicable).

Variations regarding the existence of a display (with/without), connection terminal, plug-in pole,
box shape, dimensions and aesthetic elements are considered versions of the same model.

jcs.janousek.com.br 4 +55 (11) 99776-0168

For the registration of energy storage systems or equipment that include batteries in packs or
racks, the tests and all documentation must reference the individual battery module, with
a voltage equal to or greater than 12V.

Therefore, equipment consisting of battery arrangements mounted on racks is excluded from

complying with the obligations of the conformity assessment requirements set out by Inmetro,
with only the batteries that are part of the solution being subject to the regulation, on an
individual basis.

In accordance with current regulations and with the requirements set forth in Ordinances No.
140, of March 21, 2022 - Equipment for Generation, Conditioning and Storage of Electric Energy
in Photovoltaic Systems; Ordinance No. 357, of August 1, 2014 - Adequacy of Assessment
Requirements, however, for Systems and Equipment for Photovoltaic Energy; and by Ordinance
No. 258, of August 6, 2020 - Improvement of procedures for granting Registrations by Inmetro,
the registrations granted will not have an expiration date, but must be updated by the
registration holder in order to ensure that they are always in accordance with the information
provided when they were granted.

Likewise, the provisions for cancellation or suspension of registrations have been revoked and
will apply in the event of non-compliance with the terms of the regulation by the registration
holder.

The deadlines for granting object registrations may vary according to the complexity of the tests,
generally occurring within 7 working days after submission of documents and payment of
associated registration fees.

4. Technical requirements for battery testing

Testing by Foreign Laboratories

The tests must be carried out in a third-party laboratory, national or foreign, accredited by
Inmetro/CGCRE or by an accreditation body that is a signatory to a mutual recognition
agreement with IAAC or ILAC, or in a laboratory designated by Inmetro.

Inmetro Ordinance No. 357/2014 established the possibility of performing product marking
tests in foreign laboratories, provided that they are accredited by Inmetro or by a body that has
signed a mutual recognition agreement of which Inmetro is also a member, such as the
Interamerican Accreditation Cooperation (IAAC) or the International Laboratory Accreditation
Cooperation (ILAC).

In ILAC, Brazil’s CGCRE and China’s CNAS are signatories of the MRA-Mutual Recognition
Arrangement, so foreign laboratories listed in CNAS can carry out tests and essays that are
accepted by Inmetro.

jcs.janousek.com.br 5 +55 (11) 99776-0168

Inmetro Ordinance 140/2022 - Standards and Regulations for Batteries

Technical Quality Regulation for Generation Equipment. Conditioning and

RTQ Storage of Electrical Energy in Photovoltaic Systems.
SPECIFIC ANNEX C - BATTERIES
Secondary cells and batteries for renewable energy storage
IEC 61427-2:2015
General requirements and methods of test - Part 2: On-grid applications.
Secondary cells and batteries for renewable energy storage
IEC 61427-1:2013 General requirements and methods of test - Part 1: Photovoltaic off-grid
application.
Secondary cells and batteries containing alkaline or other non-acid
IEC 62619:2017 electrolytes - safety requirements for secondary lithium cells and batteries,
for use in industrial applications.
Secondary cells and batteries containing alkaline or other non-acid
IEC 62620:2014 electrolytes - secondary lithium cells and batteries for use In industrial
applications.
Stationary cells and batteries for application in photovoltaic systems not
ABNT NBR 16767:2019 connected to the power grid (off-grid) - General requirements and test
methods.
Secondary lithium cells and batteries for stationary applications
ABNT NBR 16975:2021
Electrical specifications and test methods.
Secondary lithium cells and batteries for stationary applications
ABNT NBR 16976:2021
Specification of safety requirements.

The full description of the tests and other requirements for battery accreditation is defined in
Inmetro Ordinance 140/2022, in its Specific Annex C.

Battery Test Methodology

The complete description of the tests and other requirements for battery accreditation is
defined in Inmetro Ordinance 140/2022, in its Specific Annex C.

The Battery Test Methodology consists of the following tests:

▪ Real Capacity at Nominal Regime

▪ Recharge And Discharge Cycles for Photovoltaic Applications
▪ Charge Retention Test (Self-Discharge)
▪ Capacity Regeneration Test
▪ Overcharge Voltage Control Test
▪ Current Overcharge Control Test
▪ Overheating Control Test

jcs.janousek.com.br 6 +55 (11) 99776-0168

 Table 1 — Test definitions
Procedure
RTQ Item Tests/Procedures Ite
Normative Basis
m
5.3.1 1. Actual capacity at nominal regime 4
5.3.2 2. Recharge and discharge cycles for photovoltaic applications 5
5.3.3 3. Charge retention (self-discharge) 6
5.3.4 4. Capacity regeneration 7
5.3.5 Specific Annex C
5. Overload voltage control 8
5.3.6 (Annex B)
5.3.5
6. Overcurrent control 9
5.3.7
5.3.5
7. Overheating control 10
5.3.8

The full description of test procedures and expected results are detailed in Inmetro Ordinance
140/2022

5. JCS Consulting Scope of Services

JCS Consultoria provides a complete set of solutions and support services to companies that
wish to certify or register their products in compliance with Inmetro regulations:

▪ Support in the development of testing laboratories abroad.

▪ Validation of test reports based on Inmetro regulations
▪ Consolidation of information and documents required for the object registration process.
▪ Preparation of the forms and annexes required for the components provided for in the
Photovoltaic Energy Systems and Equipment regulations.
▪ Submission of the Product Registration Request in Inmetro system.
▪ Monitoring procedural steps until the registrations are effectively approved.

The information related to the documents and processes for requesting, analyzing, adjusting,
canceling and granting registrations of objects and related deadlines is based on the legal
provisions established by Ordinances No. 140, of March 21, 2022 - Equipment for Generating,
Conditioning and Storing Electric Energy in Photovoltaic Systems; and by Ordinance No. 258,
of August 6, 2020 - Improvement of procedures for granting Registrations by Inmetro.

Wladimir Janousek – Managing Director

Janousek Consulting and Services Ltd.

jcs.janousek.com.br 7 +55 (11) 99776-0168