Why BIS rejects CRS applications, and how to fix each query before it costs you a retest

A CRS application is rarely rejected on day one. The usual path is a query first, then a decision.

BIS expects to finish a clean application in 20 working days^[1]. If the officer finds deficiencies, BIS issues a rejection notice that gives you not less than 30 days to resolve the query^[1]. If you fix the problem in time, processing continues.

BIS's grant guidelines list the grounds on which an application can then be rejected: unpaid dues to BIS, tampered documents, unethical practices, major deviations or false declarations, a non-conforming test report, or failure to give a satisfactory reply within the time allowed. Before rejecting, BIS must give you a chance to be heard, in person or through a representative if you ask, and must pass a reasoned (speaking) order^[6].

The money matters. BIS does not refund fees when an application is rejected after processing because the replies were unsatisfactory^[5]. A rejection usually means a new application, a new processing fee and often a new test report.

This table combines BIS's 2016 list of frequently observed deficiencies, its January 2025 advisory and its circulars on test reports. Each row is something BIS itself has flagged.

Document queries are the cheapest to avoid and the most common. The checks that matter:

• One identity for the factory. CRS licences are granted to the manufacturing unit, not to an importer^[11]. The factory name and address on your login document, Form I, test report and affidavit must be identical^[8].
• Login documents. BIS wants an English business licence, or a certified translation, showing manufacturing activity^[12]. Do not alter it^[10].
• Form I. Sealed and signed by the manufacturer's authorised representative and, for foreign factories, by the AIR. Product name must match the test report^[9].
• Affidavit. Form III on Rs 100 non-judicial stamp paper, notarised, matching Form I^[3]. The original must reach BIS within 30 days of online submission or the application or licence can be cancelled^[2].
• MSME concession. Indian MSMEs claiming the fee rebate must upload the MSME certificate for the current classification year^[9].

The full list of forms is on BIS CRS documents, and a tick-list is on the BIS CRS application checklist.

Brand is part of what BIS registers. Each brand needs its own application unless the same company owns both brands^[1], and one R-number is granted per manufacturer for a product with a particular brand^[4].

BIS checks three things against each other: the brand name and status in Form I, the trade mark registration document, and the brand logo on the label in the test report. They must agree exactly, including a mark that is only "applied for"^[9]. BIS also wants an authorisation from the brand owner named on the trade mark certificate to the factory^[8].

Foreign makers have one more check. In Form I point 7, if your AIR is an unrelated Indian company (option 7(c)), the brand owner must declare that the brand has no proprietor, registered user, subsidiary, branch or liaison office in India. If the AIR is the brand's own Indian entity (7(b)), the brand owner authorises that AIR firm^[9]. The AIR options are explained on Authorised Indian Representative and in BIS's rules^[13].

Never file a second application for the same product and brand to "speed things up". BIS says it will reject all such pending applications and cancel the R-numbers already granted for that product and brand^[4].

A non-conforming test report is a listed ground for rejection^[6]. Many other report problems start as queries but end the same way if not fixed.

• Model numbers and names. Must match the test request and the portal category exactly^[9]. Test request details cannot be changed at application stage; cancel and redo the request before testing if they are wrong^[14].
• Labels. The report must show the marking labels of all models applied for, and the electrical ratings on the labels must match the product description^[9].
• Series rules. The report must follow MeitY's series guidelines^[9]. See BIS CRS series guidelines.
• Age. No more than 90 days from issue to BIS receipt^[1]. BIS can relax time norms only for genuine reasons, at DDG level^[6].
• Lab status. Reports issued while the lab was suspended are not accepted^[15].
• Routine amendments. BIS has complained about applicants sending amended reports without good reason and asks you to check the report thoroughly before applying^[16].
• Standard Mark on samples. Samples sent to the lab must not carry the BIS mark^[17].

Lab selection and timing are on BIS CRS test labs.

Two classic errors are choosing the wrong product category and filing a new licence when an inclusion was needed (or the reverse).

Category. BIS asks applicants to identify the product category carefully, using the scope of the Indian Standards and the coverage in the QCOs issued by MeitY, MNRE and other regulators^[9]. For whether a product is covered at all, or for an exemption, BIS sends you to the regulator, not to BIS^[9]. BIS's August 2026 guidance on wearables is an example of category clarification^[18].

Licence vs inclusion. BIS's refund guidelines allow the processing and licence fees to be refunded if you applied for a new licence when you needed an inclusion (or the reverse), once you file the correct request^[5]. If you spot any other error, withdrawing within 24 hours of submission, or before processing starts, gets a refund minus the application fee and taxes^[5].

Ask the regulator before you file, not BIS. BIS sends questions on whether a product falls under a QCO, and requests for exemption, to the ministry concerned, such as MeitY^[9]. An application filed in the wrong category is a common query, and fees on a rejected file are not refunded^[5].

Two exemption routes exist for electronics. Highly Specialized Equipment, such as three-phase or very large or heavy kit made or imported in fewer than 100 units per model a year, can be exempted on a specific MeitY exemption^[19]. For imports generally, DGFT's condition reportedly accepts either BIS registration or a specific MeitY exemption letter^[20]. Check coverage by HS code with the HS code approval finder and read the scope on the electronics CRS order page.

Most product-specific queries come from series grouping: models put on one report that MeitY's guidelines say must be tested separately. The criteria differ by product, and BIS checks the report against them^[9].

Because their files have more moving parts: a translated business licence, an Indian AIR and a brand that often belongs to someone else. Each is a separate place for a mismatch.

• Translation. BIS frequently sees missing or conflicting English translations, and business licences altered to change the name, address or scope^[10].
• AIR route. Under point 7(c) of Form I an unrelated Indian AIR needs the brand owner's declaration that the brand has no proprietor, registered user, subsidiary, branch or liaison office in India; under 7(b) the brand owner authorises the AIR firm^[9]. Picking the wrong point is a common query.
• AIR already taken. An AIR may represent only one foreign manufacturer, apart from group companies or a related importer^[26].
• Lab ties. A recognised lab's management, staff and their families may not act as AIR under CRS^[27].
• Affidavit by courier. The original must reach BIS within 30 days of online submission^[2].

The foreign manufacturers guide and the China import guide cover the AIR set-up in detail; the documents page lists every form.

Yes. BIS does not accept reports issued by a lab during its suspension; the applicant can send fresh samples to another recognised lab and continue in the same file, paying a scrutiny fee of Rs 10,000 plus taxes per test report^[15]. Reports are also only valid from labs BIS recognises for that exact standard^[1].

Two lab rules help you. A recognised lab must issue the report within 7 days of completing testing and may not withhold it^[27], and it must keep sample remnants for at least 3 months^[27], which matters if a result is disputed. Check the lab's recognition and status on BIS LIMS before booking^[28]; our test labs guide shows how, and the regional lists under BIS-recognised labs help you compare options.

Usually the full government fee again, and often new lab tests. BIS does not refund fees after a rejection for unsatisfactory replies^[5], and a fresh application needs a report under 90 days old^[1].

Worked example. A brand files one application covering three test reports for an IS 13252 product. Under the 2026 schedule the BIS fees for year one are Rs 67,000 before GST: Rs 1,000 application, Rs 25,000 processing, 2 × Rs 20,000 for the extra reports and Rs 1,000 licence fee^[29]. It misses the query deadline and is rejected. Refiling costs another Rs 67,000. If the reports have aged past 90 days, three new tests at around the Rs 63,750 median lab price add roughly Rs 1.9 lakh^[30]. Against a clean grant expected in 20 working days^[1], the delay is the query window of at least 30 days^[1], plus new testing and a fresh review.

Price your own case with the CRS fee calculator; the fees page explains each line, and how long BIS registration takes covers realistic timelines.

Treat the query notice as your last chance on this application.

You have three options.

1. Reapply. Fix the problems and file a fresh application. Fees for the rejected file are not refunded^[5], and the test report must still be within 90 days^[1].
2. Appeal. An appeal against a BIS order goes to the BIS Director General within 90 days, with a Rs 2,000 fee^[7]. It makes sense only if you believe BIS got the facts wrong.
3. Rebuild after a failed model. If a licence was cancelled because one model failed, a fresh application within three months can reuse older accepted reports for the other models; the failed model and its series need new tests^[6].

While you have no licence, you cannot import or sell the product. The CRS order bars import and sale of covered goods without the Standard Mark and a valid registration number^[11]. Shipments that arrive meanwhile are a customs problem; see why shipments get held.

Yes, and some causes look like application errors.

• Affidavit not received. If the original affidavit does not reach BIS within 30 days of online submission, the licence granted is liable to cancellation^[2].
• Duplicate R-numbers. Multiple registrations for the same product and brand are cancelled^[4].
• Wrong factory. Making licensed products at premises other than the licensed one is misuse and can lead to cancellation^[31].
• Missed annual fee. Under the 2026 rules, if the annual fee and production details are not received in time, suspension and cancellation provisions apply^[32].

Renewal and annual-fee rules are on BIS CRS renewal.

Four changes add checks that did not exist in 2024.

1. IS/IEC 62368-1. It replaced IS 13252 (Part 1) and IS 616 in the CRO schedule, with the old standards running only until 1 November 2028^[33][34]. One representative sample per licence is not enough for the migration^[28]. See IS/IEC 62368-1.
2. Lithium cell capacity. After 30 April 2027 no new IS 16046 (Part 2) licence is granted without a rated-capacity report^[35].
3. Annual fee and production details. Missing them now triggers suspension and cancellation provisions during the licence^[32].
4. Exemption route for specialised kit. Highly Specialized Equipment made or imported in fewer than 100 units per model a year can be exempted, but only on a specific MeitY exemption^[19]; filing a CRS application instead, or assuming the exemption, are both mistakes.

All dated changes are on new rules for 2026. After grant, BIS's checks move to the market; see CRS surveillance.