BIS Certification & CRS Registration for Importers and D2C Brands

BIS certification is the umbrella term for the licences and registrations issued by the Bureau of Indian Standards (BIS) before certain goods can be manufactured, imported, sold or stored for sale in India. For an importer or a D2C brand sourcing electronics or appliances from overseas, this is rarely one certificate. It usually means working out whether a product sits under the Compulsory Registration Scheme (CRS) for electronics and IT goods, or under the older ISI mark scheme for household appliances, and then establishing who in the supply chain, the factory, the brand owner or the importer, is actually eligible to hold the licence. Getting this sequencing wrong is the single most common reason import consignments get held at customs.

Is BIS certification mandatory for imported electronics and appliances?

Yes, if the product falls under a notified Compulsory Registration Order or Quality Control Order. Under Section 17 of the BIS Act, 2016, no person may manufacture, import, sell, distribute or store for sale a notified product without the applicable BIS registration or licence and the Standard Mark. This applies equally to a domestic manufacturer, a foreign factory and the Indian importer or brand selling the product.

What is BIS certification and how is it different from CRS registration?

BIS certification is not a single scheme. For an importer of electronics or appliances, two schemes matter, and confusing them is the most expensive mistake in this category.

Scheme I is the ISI mark, the original BIS certification framework in force since the 1950s. It requires a factory audit, ongoing surveillance and an annually renewable licence, and it covers roughly 300 to 600 notified product categories including electrical wiring accessories, pressure cookers, room heaters, gas cylinders and, since 2023, most kitchen electrical appliances. Scheme II is the Compulsory Registration Scheme (CRS), introduced by the Ministry of Electronics and Information Technology (MeitY) through the Electronics and Information Technology Goods (Requirement for Compulsory Registration) Order, 2012. CRS runs on self-declaration of conformity backed by a lab test report, with no factory audit, and it covers a narrower list of roughly 80 electronics and IT categories such as mobile phones, laptops, power banks and LED products.

The distinction matters for a D2C appliance brand because it is easy to assume an entire product line falls under the lighter CRS route simply because it is electrical. A kettle, an air fryer or an induction cooktop is very likely to sit under the ISI mark and the factory audit requirement, while a smart speaker or a power bank from the same catalogue sits under CRS. Treating both the same way in a sourcing timeline is where launches slip.

A related and current point for appliance importers: BIS Scheme X, the proposed Omnibus Technical Regulation for machinery and electrical equipment under HS Chapters 84 and 85, was repeatedly deferred through 2025 and was ultimately withdrawn, with BIS confirming on 14 January 2026 that Scheme X would no longer be required. Products that were being tracked against a Scheme X deadline still fall back to whichever CRS order or Quality Control Order already applies to them, so the underlying ISI or CRS obligation has not gone away even though Scheme X has.

A second update that changes the CRS numbers importers may have seen elsewhere: under the BIS (Conformity Assessment) Amendment Regulations, 2026, notified 25 February 2026, a Scheme II registration is now granted for five years from the outset rather than two, and renewal is granted for a further five years, though the applicable fee for grant, renewal or continuation must still be paid annually in advance along with production details. Missing an annual payment or the production filing can put the registration into abeyance even within an otherwise valid five-year term, so the extended validity period does not reduce the ongoing filing discipline required to keep a registration active.

Which products need BIS certification or CRS registration for importers and D2C brands?

Product scope depends on the specific Compulsory Registration Order or Quality Control Order notified for that category, not on a general sense that “electronics need BIS.” An importer should check the product against the current notified list before sourcing, not after the shipment is booked.

Under the Electronics and Information Technology Goods (Requirement for Compulsory Registration) Order, 2012 and its subsequent phases, CRS today covers close to 80 notified categories across five ministries. For a consumer electronics importer, the categories that come up most often include:

• Mobile phones, tablets, laptops, notebooks and desktops
• Power banks, wireless chargers and adapters
• LED televisions, video monitors and set-top boxes
• Smart watches, wireless keyboards and Bluetooth speakers
• Digital cameras, webcams and CCTV cameras or recorders
• Microwave ovens, induction cooktops and rice cookers (notified under CRS, not ISI, despite being kitchen products)
• Self-ballasted LED lamps and LED luminaires

Separately, under the Electrical Appliances for Kitchen (Quality Control) Order, 2023 and the IS 302 series of standards, ISI licensing applies to categories such as toasters, sandwich grills, roasters, and household electric cooking ranges, ovens and hobs. This is the category where D2C appliance brands most often get the scheme wrong, since it looks like a CRS product but is actually an ISI product with a mandatory factory audit.

A live standards migration also affects a large share of this product list. The Ministry of Electronics and Information Technology notified, on 29 October 2025, the adoption of IS/IEC 62368-1:2023 as the unified safety standard for audio, video, IT and communication technology equipment under the CRS order, replacing IS 13252 (Part 1):2010 and IS 616:2017. This affects laptops, tablets, televisions, monitors, printers, power banks, CCTV cameras and similar products, and BIS has since issued implementation guidelines for the transition. Both the old and new standards run concurrently until 1 November 2028 for most products, and until 1 May 2026 specifically for extended reality devices such as AR and VR headsets, which were added to the CRO at the same time. After the applicable cutoff, no new registration can be granted under the old standards, so a brand testing a laptop or CCTV camera model today should confirm with its lab whether the test report is being issued against IS/IEC 62368-1:2023 rather than the standard it may have used on a previous filing for the same product line.

A brand carrying a mixed catalogue, say wireless earbuds, a smart scale and an electric kettle, is very likely dealing with two different BIS schemes inside a single product launch, each with its own applicant, timeline and cost. Mapping the catalogue against the notified orders before finalising a sourcing calendar is the first real task, not an afterthought once stock is in transit.

CRS itself is notified by five ministries, not one, though only the first two rows matter to a consumer electronics or appliance importer:

An importer sourcing consumer electronics or small appliances rarely needs to look past the MeitY-notified list, but the other four categories explain why some BIS guides quote a much larger CRS product count than the electronics-specific figure used in this article.

Benefits of holding a valid BIS or CRS registration

Registration is a market-access requirement first, but it also does practical work for an importer beyond avoiding a penalty.

• Customs clearance without hold-ups. A shipment carrying a notified product without a valid registration in hand can be detained at the port regardless of its duty and GST status, since the BIS Act prohibition operates independently of customs valuation.
• Marketplace eligibility. Amazon India, Flipkart and most organised retail buyers require a live BIS registration number before onboarding a notified electronics or appliance SKU, so the registration is a precondition for the sales channel, not just the legal right to sell.
• Distributor and B2B credibility. A registration number on the product listing is one of the first things a distributor’s own compliance team checks before agreeing to stock a new import brand.
• A defensible position during BIS surveillance. Since BIS can pull market samples at any time, holding current documentation removes the single most common trigger for an enforcement notice, an unregistered SKU appearing in a routine sweep.

Who can apply for BIS certification, the importer, the brand owner or the manufacturer?

This is the point importers get wrong most often. Under both Scheme I and Scheme II, the BIS licence or registration is granted to the manufacturer, not to a trader, distributor or importer who does not own the factory. An importer bringing in finished goods from an overseas factory cannot apply in its own name unless it also holds a manufacturer authorisation from that factory, or unless the factory itself completes the registration and the importer sells under the factory’s registration number.

In practice, three routes work for a D2C brand or importer:

1. Factory-held registration. The overseas or Indian factory applies for and holds the ISI licence or CRS registration in its own name, and the importer sells the product bearing that registration number. This is the fastest route when the factory already supplies other Indian clients and already holds a current registration for the exact model.
2. Brand-owner registration with manufacturer authorisation. The Indian brand applies as the registration holder, supported by a manufacturer authorisation letter and the factory’s technical file and test cooperation. This is the more common route for a private-label D2C brand that wants the registration number tied to its own brand name rather than the factory’s, and it is the route BIS treats as the “brand owner” applicant.
3. Foreign manufacturer through an Authorised Indian Representative (AIR). Where the factory itself is applying and has no legal presence in India, it must appoint an AIR under Format IIIA, IIIB or Format C of the BIS Conformity Assessment Regulations, 2018, who manages the portal application, hard-copy submission and BIS correspondence on the factory’s behalf.

Whichever route is used, the registration is tied to a specific manufacturer, product, model and, for ISI, a specific factory location. Changing factories for the same SKU, a common D2C move when a supplier relationship ends, means a fresh registration, not a transfer.

An applicant, whichever of the three routes it uses, must be able to show all of the following before BIS will process the file:

• A test report from a BIS-recognised laboratory confirming conformity with the applicable Indian Standard
• Constitutional documents establishing the applicant’s legal identity, PAN and GST registration
• A manufacturer authorisation letter, where the applicant is the brand owner rather than the factory itself
• For a foreign factory, a validly appointed Authorised Indian Representative before the portal application is filed
• For ISI applications, evidence of in-house quality control capability sufficient to pass the factory audit

How much does BIS certification cost for an importer?

Cost depends on the scheme and the number of models. A CRS registration typically runs to roughly ₹50,000 to ₹65,000 in BIS application, processing and test report fees per model, verified against the live fee schedule, plus lab testing charges that vary by product complexity. ISI licensing carries a lower base application fee but adds a ₹7,000-per-man-day factory audit fee and a product-specific marking fee, which runs materially higher for an overseas factory once auditor travel, accommodation and visa costs are added.

BIS certification process for CRS registration, step by step

CRS registration runs entirely online through the BIS CRS portal and follows a fixed sequence for both domestic and foreign applicants.

Before filing, the applicant should have the following ready, since incomplete documentation is the most common cause of a stalled application:

• PAN and GST registration of the applicant entity
• Company constitutional documents (incorporation certificate, MoA and AoA, or partnership deed)
• Product technical specification sheet and label or marking artwork
• Third-party test report from a BIS-recognised laboratory
• Form I application, Form II undertaking and Form III affidavit under the BIS Conformity Assessment Regulations, 2018
• Brand authorisation letter from the manufacturer, where the brand owner rather than the factory is the applicant
• For foreign manufacturers, the AIR nomination on Format IIIA, IIIB or Format C, and the AIR’s identity and legal status documents

1. Confirm applicability and the Indian Standard. Check the product against the notified CRS categories and identify the specific Indian Standard (IS) number that applies to that model.
2. Register on the CRS portal and appoint an AIR if needed. Foreign manufacturers must nominate an Authorised Indian Representative before the application can proceed.
3. Generate a test request and select a BIS-recognised laboratory. The portal issues a QR code for the sample, which must be affixed before the sample is sent to the lab.
4. Complete lab testing. Test reports against the relevant IS standard are typically issued within 10 to 15 working days of the lab receiving the sample, and the report must not be older than 90 days at the time of submission.
5. Assemble supporting documents. This includes Form I (the application under the BIS Conformity Assessment Regulations, 2018), the undertaking in Form II, the affidavit in Form III, brand authorisation where applicable, and company constitutional documents.
6. Submit the application online, with hard copies of signed documents couriered to the relevant BIS office within 15 days of online submission, a step foreign applicants routinely miss.
7. Respond to BIS queries. BIS reviews the application and test report and raises queries on the portal for any gaps, which must be answered within the stated window or the file lapses.
8. Receive the registration certificate, which carries the registration number (R-number), the scope of the licence, brand name, model number and the applicable IS standard.
9. Mark the product. The Standard Mark, R-number and IS number must appear on the product or its packaging, in a minimum font size and in a permanent, legible format, with e-labelling permitted for products with built-in screens.

ISI licensing process for BIS-notified appliances, and why it takes longer

ISI licensing under Scheme I follows a broadly similar application and testing sequence, with one structural difference that changes the whole timeline: a factory audit is mandatory, not optional. For an Indian factory, BIS officers inspect manufacturing processes, in-house quality control and testing capability before granting the licence. For an overseas factory supplying a D2C brand or importer, the equivalent route is the Foreign Manufacturers Certification Scheme (FMCS), under which BIS auditors travel to the factory, which adds cost and typically extends the timeline by several weeks against a comparable CRS filing.

A licence granted under Scheme I is valid for one year and must be renewed annually, against CRS’s five-year validity under the 25 February 2026 amendment described above. The safer practice is still to file any renewal well before expiry rather than rely on any grace period, since under the BIS (Conformity Assessment) Regulations, 2018, a licence with lapsed fees or missing production filings can be held in abeyance and, on continued non-compliance, cancelled outright, at which point the applicant is back to filing a fresh application rather than a renewal. BIS also conducts surveillance visits and can pull samples from the market at any point during the licence period, and a factory found non-conforming can have the licence suspended for that specific model, not the whole factory.

For a D2C appliance brand sourcing kitchen electricals, this means the ISI route needs to be built into the sourcing calendar months before the intended launch date, not weeks, because the factory audit alone can take longer than the entire CRS cycle for a comparable electronics product.

BIS certification cost for importers and D2C brands

Costs sit in four buckets regardless of scheme: the government application and processing fee, the lab testing fee, the factory audit fee where applicable, and the recurring annual or renewal fee.

MSME-registered applicants receive a 20 percent discount on the processing fee under current BIS norms. Fee notifications for CRS processing and additional test reports vary across BIS circulars and product categories, so the ranges above should be treated as a budgeting guide, not a quote, and confirmed against the live fee schedule for the specific IS standard before an application is filed. A separate point worth budgeting for even though it is not a one-time cost: under the BIS (Conformity Assessment) Amendment Regulations, 2026, a CRS registration granted or renewed for a five-year term still requires the licence fee and production details to be filed and paid annually, so the longer validity period reduces paperwork frequency but not the annual cash outflow. Where a brand is filing for several SKUs across both schemes at once, the practical approach is to cost each model separately rather than assume a blended average, since a single kitchen appliance model under ISI with an overseas factory audit can cost several times what a single CRS electronics model costs.

How long does BIS certification take before a product can be sold in India?

For CRS registration, a realistic end-to-end timeline runs 20 to 40 working days from sample submission to certificate, assuming the test report is clean and BIS raises no queries. For ISI licensing, add the factory audit cycle, which for a domestic factory typically adds two to four weeks and for an overseas factory under FMCS can add six to ten weeks once auditor scheduling and travel are accounted for.

The practical implication for a D2C brand is that the registration timeline, not the shipping timeline, should set the launch date. A shipment can clear customs in days once the goods have a valid registration in hand, but a registration started after the goods are already at port is the scenario that produces demurrage charges and unsellable inventory.

Registration is not the end of the compliance obligation. The Standard Mark, registration number and IS number must stay legible and permanent on the product or packaging for as long as it is sold, with e-labelling permitted only for products carrying a built-in screen. BIS can pull samples from the market at any point during the validity period, and any consumer complaint about a registered product must be investigated and closed within 90 days, excluding lab testing time. A factory should treat these as ongoing, not one-time, obligations when it prices the registration into a product’s landed cost.

Common mistakes that cost importers and D2C brands time and money

Assuming the importer can apply directly. BIS registration is manufacturer-linked. An importer with no factory ownership and no manufacturer authorisation letter cannot file in its own name, and discovering this after the goods have shipped means either a rushed authorisation letter from the factory or filing under the factory’s own registration at short notice.

Classifying a kitchen appliance as a CRS product. Several appliance categories that read as electronics, kettles, toasters, cooking ranges, sit under the ISI mark and the Electrical Appliances for Kitchen (Quality Control) Order, 2023, not CRS. Filing the wrong application wastes the testing fee and the lead time.

Not budgeting for the factory audit on an overseas ISI application. Auditor travel, accommodation and visa costs for an FMCS audit are a real, non-trivial line item that a CRS-only cost estimate does not capture. Selling non-compliant products without the mandatory Standard Mark attracts a fine of not less than ₹2 lakh for the first contravention, and not less than ₹5 lakh for a subsequent one, extendable up to ten times the value of the goods, along with imprisonment of up to two years, under Sections 17 and 29 of the BIS Act, 2016. BIS’s own enforcement record includes warehouse seizures at major e-commerce fulfilment centres covering exactly this category of product, smart watches, food mixers, pressure cookers and wireless earbuds, so this is an active enforcement risk, not a theoretical one.

Treating registration as a one-time event per brand rather than per model and per factory. A change of factory for the same SKU, or the addition of a new model variant, both require a fresh registration or an inclusion application, not a simple update to the existing certificate.

Missing the hard-copy submission window. For CRS, signed hard copies of the application must reach the BIS office within 15 days of online submission. Foreign applicants filing through an AIR miss this window more often than domestic applicants, and a lapsed hard-copy deadline restarts parts of the review.

Case study

Situation: A Bengaluru-based D2C brand importing small kitchen appliances and personal electronics from a Guangdong-based factory, preparing a festive-season catalogue launch.

Challenge: The brand had assumed all 14 SKUs in the catalogue fell under CRS, had already booked shipping, and discovered late that four kitchen appliance models required ISI licensing with a factory audit rather than CRS registration.

What Treelife did: Mapped every SKU against the correct notified order, split the filing into a CRS batch and an ISI batch, arranged the manufacturer authorisation letter and AIR nomination for both, and coordinated the FMCS factory audit schedule directly with the factory’s compliance team to run in parallel with the CRS lab testing.

Outcome: The 10 CRS SKUs launched on the original date. The four ISI SKUs launched five weeks later than planned instead of missing the season entirely, and the brand avoided a repeat of the misclassification on its next sourcing cycle by building a standing BIS map into its vendor onboarding checklist.

If your product catalogue mixes CRS and ISI categories, Treelife’s regulatory team can map your SKUs against the current notified orders before your next purchase order goes out. See our tax and regulatory advisory services for how we structure this alongside customs and GST compliance.

FAQ’s on BIS Certification & CRS Registration for Importers and D2C Brands

Q: Can an importer apply for BIS certification directly, without involving the manufacturer?
A: No. BIS registration under both Scheme I and Scheme II is granted to the manufacturer or to a brand owner holding a manufacturer authorisation letter. A pure importer with no ownership stake in the factory and no authorisation cannot file in its own name.

Q: What is the cost difference between CRS registration and ISI licensing?
A: CRS typically costs in the range of ₹50,000 to ₹65,000 in BIS application, processing and test report fees per model, verified against the live fee schedule. ISI licensing starts from a lower base application fee but adds a ₹7,000-per-man-day factory audit fee plus a product-specific marking fee, which is materially higher for an overseas factory under the FMCS route once travel and logistics are included.

Q: How long is a BIS registration or licence valid?
A: Following the BIS (Conformity Assessment) Amendment Regulations, 2026, effective 25 February 2026, a CRS registration is now granted for five years from the outset and can be renewed for a further five years, though the applicable fee and production details must still be filed annually. This replaces the earlier two-year CRS validity that older guides may still quote. ISI licensing remains valid for one year and must be renewed annually.

Q: What documents does a foreign manufacturer need to appoint an Authorised Indian Representative?
A: The nomination is filed on Format IIIA, IIIB or Format C under the BIS Conformity Assessment Regulations, 2018, along with the AIR’s identity and legal status documents and an acknowledgement of the online application.

Q: Does BIS Scheme X still apply to appliances and machinery?
A: No. BIS confirmed on 14 January 2026 that Scheme X, the proposed Omnibus Technical Regulation for machinery and electrical equipment under HS Chapters 84 and 85, would no longer be required after repeated deferrals through 2025. Products still need to be checked against whichever existing CRS order or Quality Control Order already applies to them.

Q: What happens if a product is sold in India without the required BIS certification?
A: Under Sections 17 and 29 of the BIS Act, 2016, the offence carries a fine of not less than ₹2 lakh for a first contravention and not less than ₹5 lakh for a subsequent one, extendable up to ten times the value of the goods, along with imprisonment of up to two years, in addition to product seizure and removal from e-commerce listings.

Q: Are kitchen appliances like kettles and toasters covered under CRS or ISI?
A: Most household kitchen electrical appliances, including toasters, grills and cooking ranges, fall under the ISI mark and the Electrical Appliances for Kitchen (Quality Control) Order, 2023, which requires a factory audit. This is distinct from microwave ovens, induction cooktops and rice cookers, which are notified under CRS.

Q: Can the same BIS registration be used if the brand changes its manufacturing factory?
A: No. ISI licensing and CRS registration are both tied to a specific factory location for a given model. A change of factory requires a fresh application, not a transfer of the existing registration.

Q: What is the difference between BIS CRS and BIS FMCS?
A: CRS is the Scheme II self-declaration route for electronics and IT goods, with no factory audit. FMCS is the route foreign manufacturers use to obtain an ISI licence under Scheme I, which does require a factory audit conducted by BIS at the overseas facility.

Q: How does BIS certification interact with GST and customs clearance for imported goods?
A: A notified product without valid BIS registration can be held at the port of entry regardless of its GST or customs duty status, since the BIS Act prohibition applies at the point of import itself. Customs clearance and BIS compliance should be tracked as parallel workstreams, not sequential ones, so the registration is in hand before the shipment departs the origin port.

Q: Do e-commerce marketplaces independently check for BIS registration before listing a product?
A: Major marketplaces such as Amazon and Flipkart require a valid BIS registration number before listing notified electronics and appliance categories, and BIS has separately conducted direct enforcement action at marketplace fulfilment warehouses for non-compliant stock.

Q: What happens if a product fails BIS lab testing?
A: The applicant can review the test failure, make the necessary product or component changes, and resubmit a fresh sample for testing. This restarts the lab testing timeline but does not require a new application filing if done within the same application window.

Q: Is a factory audit required for every ISI-licensed product, or only for first-time applicants?
A: A factory audit is required at the point of initial licensing and periodically thereafter through BIS surveillance, not only for a first-time applicant. A factory already holding an ISI licence for one product still faces surveillance visits across its licensed product range.

Q: Do laptops, TVs and CCTV cameras need to move to a new BIS safety standard?
A: Yes. MeitY notified IS/IEC 62368-1:2023 on 29 October 2025 as the replacement safety standard for IS 13252 (Part 1):2010 and IS 616:2017 under the CRS order, covering audio, video, IT and communication technology equipment. Old and new standards run concurrently until 1 November 2028 for most products and until 1 May 2026 for extended reality devices, after which no registration can be granted under the withdrawn standards.

Regulatory references

• Bureau of Indian Standards Act, 2016, Sections 17 and 29
• BIS (Conformity Assessment) Regulations, 2018, Scheme I and Scheme II
• BIS (Conformity Assessment) Amendment Regulations, 2026, notified 25 February 2026, revising Scheme II licence validity to five years
• BIS (Conformity Assessment) Amendment Regulations, 2020, Annexure I of Scheme I, product-specific marking fees
• Electronics and Information Technology Goods (Requirement for Compulsory Registration) Order, 2012, and subsequent phases notified by the Ministry of Electronics and Information Technology
• MeitY notification dated 29 October 2025 adopting IS/IEC 62368-1:2023 in place of IS 13252 (Part 1):2010 and IS 616:2017 under the CRS order
• Electrical Appliances for Kitchen (Quality Control) Order, 2023
• IS 302 series of Indian Standards for household electrical appliances

External sources

• Bureau of Indian Standards
• Ministry of Electronics and Information Technology

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Treelife

Treelife Team | support@treelife.in

We are a legal and finance firm with a deep focus on the startup ecosystem. We offer a wide range of services, including Virtual CFO, Legal Support, Tax & Regulatory, and Global Expansion assistance.

Our goal at Treelife is to provide you with peace of mind and ease in business.