India has been rapidly expanding the scope of mandatory quality standards for imported products through Quality Control Orders (QCOs). As of 2026, over 650 products across more than 200 QCOs require BIS certification before import clearance. The pace of issuance has accelerated — more QCOs were notified between 2020 and 2025 than in the entire preceding history of the BIS Act.
For importers, the consequence of non-compliance is immediate: goods arriving at the port without valid BIS certification face detention, seizure, re-export, or destruction. There is no grace period and no provisional clearance mechanism for QCO-covered goods.
Understanding Quality Control Orders
A QCO is a notification issued under Section 16 of the Bureau of Indian Standards Act, 2016. It mandates that specified products — whether manufactured domestically or imported — must conform to the relevant Indian Standard and bear the Standard Mark (BIS certification) before they can be sold or distributed in India.
QCOs typically specify:
- ▸The Indian Standard (IS number) that the product must conform to
- ▸The product category and HS codes covered
- ▸The effective date and any transition period
- ▸The applicable BIS scheme (ISI Product Certification, CRS, or FMCS)
BIS Certification Schemes for Importers
ISI Mark (Product Certification Scheme)
Applicable to products covered under the Product Certification Scheme. Requires factory audit by BIS, sample testing at BIS-recognised labs, and ongoing surveillance. Foreign manufacturers must apply under the Foreign Manufacturers Certification Scheme (FMCS) with an Authorised Indian Representative (AIR).
CRS (Compulsory Registration Scheme)
Primarily for electronics and IT products. The manufacturer submits test reports from BIS-recognised labs and registers the product. No factory audit is required, making CRS faster and simpler than ISI certification. Registration is valid for two years and must be renewed.
FMCS (Foreign Manufacturers Certification Scheme)
Foreign manufacturers who cannot apply directly under the domestic schemes must use FMCS. Requires appointment of an AIR who is responsible for compliance in India, a factory inspection by BIS officials, and sample testing. The AIR bears liability for non-compliance.
Port-Level Enforcement
Customs officers at the port of import verify BIS certification as part of the clearance process. The verification includes checking:
- ▸Whether the product falls under any QCO based on HS code classification
- ▸Whether valid BIS licence/registration exists for the specific product and manufacturer
- ▸Whether the BIS Standard Mark is physically present on the product and packaging
- ▸Whether the certificate number matches the BIS database
Failure at any of these checkpoints results in detention of goods and potential seizure proceedings under the Customs Act. The importer\'s options at this stage are limited: re-export at own cost, obtain BIS certification retrospectively (if possible within the free period), or face confiscation proceedings.
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Frequently Asked Questions
What is a Quality Control Order?
A Quality Control Order (QCO) is a notification issued by the Central Government under Section 16 of the Bureau of Indian Standards Act, 2016, mandating that specified products conform to Indian Standards (IS) and bear the BIS mark (ISI or CRS) before they can be manufactured, imported, distributed, or sold in India.
What happens if goods arrive at the port without BIS certification?
Goods covered by a QCO that arrive without valid BIS certification are liable to be detained, seized, or refused clearance by Customs. The importer faces re-export at their own cost, destruction of goods, or confiscation proceedings. Port storage and demurrage charges continue to accrue during the hold.
What is the difference between ISI mark and CRS registration?
ISI mark (Compulsory Registration Scheme for specific products under Product Certification) applies to products where BIS conducts factory audits and sample testing. CRS (Compulsory Registration Scheme) is a simplified registration for electronics and IT goods where the manufacturer registers the product based on test reports from BIS-recognised labs. Both require valid BIS licence/registration for import clearance.
How long does BIS registration take for foreign manufacturers?
Timelines vary by scheme. ISI mark for foreign manufacturers involves factory inspection by BIS officials (typically 2-4 months for scheduling and visit) plus sample testing. CRS registration can take 4-8 weeks if test reports from recognised labs are available. The FMCS (Foreign Manufacturers Certification Scheme) adds complexity due to the requirement of an Authorised Indian Representative (AIR).
Can a QCO be challenged legally?
QCOs have been challenged in High Courts on grounds of insufficient transition period, retrospective application, and absence of testing infrastructure. Some challenges have succeeded in obtaining interim stays, particularly where the government imposed QCOs without adequate notice periods or where accredited testing labs for the specified standards did not exist in India.
Importing to India?
We advise on QCO applicability, manage the BIS registration process for foreign manufacturers, and handle port-level disputes when goods are detained for non-compliance.
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