BIS CRS surveillance: how market samples are picked, what you pay and what happens if one fails

CRS surveillance is the government buying your registered product after grant and testing it again against the Indian Standard it was registered to. It is run by MeitY, with STPI buying the samples, sending them to labs and collecting the charges^[1].

The Compulsory Registration Scheme is built on self-declaration: you test a sample at a BIS-recognised laboratory, upload the report and get an R-number. Nobody from BIS visits your factory before grant. Surveillance is the check that the units actually on sale still match that report.

Two bodies are involved, and it helps to keep them apart. STPI's surveillance SOP says BIS handles search and seizure, while MeitY conducts surveillance of registered manufacturers^[11]. So a failed surveillance sample starts with MeitY and STPI and ends with BIS deciding what happens to the licence.

This page covers the post-grant cycle only. For getting registered in the first place see BIS CRS documents and CRS fees; for keeping the licence alive see CRS renewal.

MeitY carries out routine CRS surveillance, with STPI as its agent; BIS acts on the results. MeitY's circular of 5 July 2024 entrusted STPI with supporting surveillance under the Electronics and IT Goods CRO 2021^[1].

It was not always this way. In April 2022 a BIS Registration Department circular, a copy of which is hosted by a test lab, announced BIS-run market surveillance of CRS products, asking licensees for consignee lists within 10 days and a surveillance deposit within 15 days^[12]. A compliance consultancy reported in June 2022 that BIS then put this in abeyance because MeitY said it would continue routine surveillance itself^[13].

That history explains why older consultant articles talk about 'BIS demand drafts' and 'BIS market surveillance cells'. For electronics under the CRS order today, the portal you deal with is STPI's, not BIS's.

BIS still runs its own market surveillance for ISI-marked goods under Scheme-I. That system is different: generally two market samples a year per licence^[14]. If you also hold an ISI mark licence, see ISI renewal for how that side works.

R-numbers are picked by an algorithm on MeitY's surveillance portal, not by complaint alone. MeitY then selects a designated test lab from empanelled BIS-recognised labs, using STQC labs where possible and, where possible, a lab different from the one that did your original testing^[3].

The July 2024 circular describes the selection as random^[1]. MeitY does not publish how many R-numbers it picks each year, so there is no way to calculate your odds. Plan as if every R-number you hold will be picked at some point during its validity, which since 2026 can run five years^[17].

Two practical points follow. First, because the lab is meant to differ from your original lab, a borderline pass at a friendly lab gives no protection. Second, a lab that is in the same group as your original lab counts as the same entity for this purpose^[3]. Our page on CRS test labs lists how the lab network works.

Yes. STPI buys the sample from the open market or an e-commerce platform, and the SOP names Amazon and Flipkart as examples. It seals the unit and uploads the model number, serial number, pickup date, time and location to the portal^[2].

The pickup location is supposed to change from one surveillance to the next^[2]. That matters for brands that sell one batch offline and another online: whichever listing STPI buys from is the one that gets tested.

If STPI cannot find the product in the market, it contacts you for authorised channels and may pick the sample from an e-commerce site or your premises or warehouse. Failing to give the information or the sample in time is treated as a violation of the Order leading to suspension of the licence^[8].

For marketplace sellers this links surveillance to your listings. If you sell on Amazon or Flipkart, make sure every listing shows the same model number as the R-number registration and the CRS label. A listing with a mislabelled or grey-market unit can end up being the surveillance sample for your licence.

Separately, BIS has bought QCO products from e-commerce sites on its own: a Lok Sabha reply reported that in FY 2024-25 BIS bought 344 samples of QCO products from e-commerce platforms and 142 had no valid BIS certification^[18]. That is enforcement against unregistered goods, not routine surveillance of licensees, but it comes from the same channels.

A CRS surveillance case runs through about eight stages, all tracked on the STPI surveillance portal, with e-mail alerts at each step^[3].

You pay the full cost: the MRP of the samples needed, packaging, logistics and courier at actual cost, and the lab's test charge. The test charge is the STQC or government-approved rate or the lab's declared BIS rate, whichever is lower^[19]. The legal basis is paragraph 5(8) of Scheme-II, which puts sample and testing costs on the licensee, and MeitY's circular repeats that the cost of surveillance is borne by the manufacturer^[1].

STPI publishes an Annexure-A of maximum surveillance test charges per category. The rates are caps until the next revision; the lab's own declared rate applies if lower^[6]. Compare them with the initial testing costs on LIMS: for IS 13252 (Part 1) labs declare between Rs 25,000 and Rs 2,00,000^[20].

A surveillance bill is the test charge plus the price of the unit plus courier, so the test charge dominates for cheap products. Two worked examples using the published caps:

Example 1: a power bank brand with one R-number. STPI buys one power bank listed at, say, Rs 1,499 MRP. The cap on the test charge is Rs 45,500^[6]. Add packaging and courier at actual cost^[19]. The bill is roughly Rs 47,000 plus courier, payable within 15 working days^[5]. If the selected lab's declared BIS rate for IS 16046 testing is lower, you pay the lower figure^[6].

Example 2: a cell maker with a lithium cell R-number. The cap for a sealed secondary cell is Rs 1,63,100^[6]. The number of cells bought is 'as required for testing as per notified IS standards'^[19], so the sample cost is several cells, not one. Budget well over Rs 1.6 lakh per surveillance for each R-number.

The MRP figure in Example 1 is illustrative; the rates are from STPI's annexure. Use the compliance cost estimator to fold a surveillance reserve into your yearly budget, and compare with the cost of a CRS registration.

Yes. Manufacturers, AIRs and brands sign up on crsbis.stpi.in and add every R-number with model details: model and market name, type, availability channel, location and MRP, or a CSV upload. They also upload made-to-order and end-of-life declarations, calculate the surveillance charges per brand and category on the payment page, and pay online or offline with the UTR receipt^[16].

This is a separate login from the BIS CRS portal where you got registered. Many foreign brands miss it because their Authorised Indian Representative only handled the BIS side. If your contact details on the STPI portal are stale, surveillance notices go nowhere, and the circular warns that slow responses can lead to penal action under the BIS Act^[21].

The 'availability channel' and 'location' fields are what STPI uses when your product cannot be found in the market^[8]. Fill them with real channels (named marketplaces, distributors, warehouse address) rather than 'pan-India'.

The lab asks for whatever it needs to test your model to the standard, and you have 10 working days to send it^[4]. In practice that means the same technical file you used at registration: the critical components list, circuit diagrams, user manual, rating label artwork, and component certificates.

If you do not send them, the lab tests what it can with what it has and uploads the report. You are still charged the full surveillance cost and the R-number is forwarded to BIS. If you also do not pay, the case is treated as both non-cooperation and non-payment^[22]. MeitY can also recommend that BIS not renew the registration^[4].

Keep a 'surveillance pack' per R-number ready to send the same day: the original test report, the components list with each component's BIS registration or test report, and the label used today. If you changed a critical component since registration without filing an inclusion or update, the surveillance lab will find it. Our guide on how to read a BIS test report shows what the lab compares.

Every stage of CRS surveillance has a fixed clock in the SOP, and the ones that fall on you are short. The table lists each one with who it binds.

If the sample passes, MeitY closes the case, you are asked to collect the tested unit from the lab within 30 days, and BIS may start the renewal process for that R-number^[23]. If you do not collect it, the lab disposes of it under its own policy.

The link to renewal is worth noting. The CRS FAQ says samples are picked during surveillance rather than retested before renewal^[24]. A clean surveillance history is part of what keeps CRS renewal routine.

A pass does not change your duties. You still pay the annual fee and file production details each year under the 2026 rules^[25], and you still renew before the validity date. Set reminders with the licence renewal date tool.

If the lab reports non-compliance, MeitY sends you a call-for-explanation letter through the portal, and you have 14 days to reply with documentary evidence. If MeitY is still convinced the product does not conform, the case goes to BIS for action under the BIS Act 2016 and the Conformity Assessment Regulations 2018^[7].

The SOP does not list BIS's penalties. They come from the BIS Act and the regulations. BIS can direct a licence holder to stop supply and recall non-conforming Standard-Marked goods^[26]. A licence holder who sells marked goods that do not conform can be ordered to pay compensation to the consumer^[27]. Courts take cognizance only on a complaint by or under BIS's authority or the other officers named in section 32^[28].

The lab holds the failed sample until MeitY or BIS closes the case, then releases it^[23]. Keep it after collection; it is evidence for any appeal.

For Scheme-I (ISI) licences BIS publishes a detailed escalation ladder: corrective action for a first non-conformity, then suspension for a consecutive second critical failure or a third failure^[29]. No equivalent public ladder exists for CRS, which is why a single failed CRS sample should be answered fast and fully.

Surveillance can end badly without any test failure. The SOP lists non-payment of charges, not providing technical documents or support, missing the deadline for a custom-built sample, and exceeding the overall timelines as reasons for 'not completed successfully', and these cases also go to BIS^[23].

Unpaid invoices escalate quickly. STPI sends at most two reminders at 7-day intervals; if nothing is paid after 15 working days, the case is forwarded to BIS for deferment or cancellation of the registration for non-cooperation^[5]. Product unavailability handled badly is treated as a violation leading to suspension^[8].

In other words, a perfectly compliant product can still lose its licence through paperwork. Most of the risk on this page is administrative, and it is the easiest part to control.

Custom-built and end-of-life models each have their own declaration, and filing the right one saves a surveillance case from going wrong.

Custom-built (made to order). If all registered models in a category are custom-built, you give a declaration and arrange the sample yourself; STPI charges actual costs without the cost of the sample^[8]. The made-to-order sample must be delivered within 30 working days, or it is treated as a violation leading to suspension^[8].

End of life. If a model is discontinued, apply to BIS to exclude the model (or cancel the R-number), then give STPI the BIS receipt, an end-of-life undertaking and later the BIS approval letter to get the model exempted from surveillance^[30]. The Annexure-E declaration states the model is not available in shops, online or with the manufacturer and that you will not make or sell it^[31]. Model withdrawal on the BIS side is done online with a fee^[32].

Do not declare end of life for a model that is still on a marketplace somewhere. The declaration is a signed statement, and STPI buys from e-commerce sites^[2].

Yes, if all registrations for a product lapse or are cancelled. When every R-number for a product of a given manufacturer has expired, been cancelled, withdrawn or lapsed, you can claim a refund of the outstanding interest-free deposit, and STPI refunds it within 30 days after verification^[30].

Before raising a new demand, STPI checks whether you deposited an advance against that R-number in an earlier surveillance and adjusts it^[5]. Keep your own ledger of deposits per R-number so you can match STPI's invoices.

If you held a CRS licence in 2022 and paid a BIS surveillance demand draft that was never used, consultants reported that BIS said such drafts would be returned^[13]. Raise it with BIS if you never received yours.

Importers and resellers are not the licensee, but they are often where the sample is bought. The CRS FAQ says registered goods must show the Standard Mark during surveillance, and a trader can back this up with a copy of the registration certificate and source-of-procurement documents^[33].

The BIS Act's definition of 'person' covers importers, distributors, retailers and sellers^[26], and section 17 bars selling or storing for sale notified goods without a valid licence and mark^[26]. Contravening section 17 can mean imprisonment up to two years or a fine of not less than Rs 2 lakh for a first contravention^[26].

So if you import a foreign brand's registered product, ask the brand or its AIR for: the R-number certificate, the model list on the licence, and confirmation that the R-number is registered on the STPI portal. Our guide to verifying a BIS licence shows how to check the R-number yourself, and selling without BIS covers the enforcement side.

Preparation is mostly keeping data current and money ready. The circular asks manufacturers to keep contact details updated, give information and documents on time and pay demands, to avoid penal action^[21].

Surveillance tests whatever model STPI buys under the R-number, which can be any model on the licence, not only the lead model you tested at registration. STPI uploads the model number of the unit it actually bought^[2].

This is where series guidelines come back to matter. At registration a single lead model can cover a series, for example up to ten models for most electronics categories^[34]. Every series model must genuinely share the safety-critical design with the lead model, because any one of them can be the surveillance sample.

For the IS/IEC 62368-1 migration in 2026, BIS's FAQ said one representative sample per licence is not enough and lead models must be retested^[35]. If you have migrated, make sure the models on sale are built to the migrated design.

Foreign manufacturers go through the same STPI process, with their AIR or local representative as the contact. The SOP addresses notices, document requests and invoices to the 'manufacturer/LR' (local representative)^[15].

That puts real duties on the AIR: watching the portal, collecting technical files from the factory within 10 working days, and arranging payment within 15 working days^[5]. If your AIR is an unrelated Indian company, agree in writing who pays surveillance bills and how fast the factory must send documents. Changing AIR on the BIS side costs Rs 5,000 plus GST^[36], but the STPI portal must be updated too.

Our foreign manufacturers guide covers the AIR relationship, and BIS consultants can act as the day-to-day contact if you do not have an Indian office.

Write to the Project Management Unit-CRS at STPI: [email protected], phone +91-11-24628081 or +91-11-24346678, quoting your reference number in the subject^[10]. The office is at STPI HQ, East Kidwai Nagar, New Delhi^[10].

For anything about the licence itself (inclusions, withdrawals, renewal) the counterpart is BIS on the CRS portal. For whether a product is covered at all, BIS advises asking the regulator, MeitY^[37].

If a surveillance notice has arrived and you are unsure what it asks, send it to us through our free compliance check. We can tell you which deadline is running.