Importing samples for BIS testing: what Customs, MeitY and BIS actually allow, and how to ship test units without getting stuck

Yes, for products under the Compulsory Registration Scheme. BIS registration exists to stop uncertified goods being sold, but the licence itself depends on testing a sample in India, so the rules make room for that. MeitY's CRS FAQ says the Compulsory Registration Order is not applicable on goods imported for demonstration, research and development or testing in India, and points to a MeitY circular of 26 April 2022 issued under para 2 of the 2021 Order^[1].

That is the good news. The catch is that the FAQ is a summary, and we could not open the circular itself, so we cannot tell you whether it sets a quantity cap or a fixed undertaking format. Older versions of the FAQ talked about "limited quantities" and a declaration. In practice, ship only what the lab needs, label the consignment clearly as test samples, and give your customs broker evidence of the purpose.

If you are still working out whether your product is a CRS product at all, start with does my product need BIS? or run it through the approval checker. The rest of this article explains how many samples you actually need, how they must be handled, how other regulators treat test units (WPC, TEC and the ISI-mark QCOs all have their own rules), and what can still go wrong at the port.

For finished CRS products, the default position at the port is strict. A CBIC instruction reported as 28/2023-Customs tells officers to check BIS registration in the system in all cases, and lets the risk management system pick consignments for lab sampling^[11]. According to the same instruction, DGFT allows import of notified goods only with BIS registration or a specific MeitY exemption letter, and a MeitY office memorandum authorises Customs to deform non-compliant or unregistered goods^[12].

A box of samples has no R-number, by design. Samples sent for an intended grant are outside the licence scope and must not carry the Standard Mark^[3]. So an officer looking at an unmarked smart watch with no BIS record will ask why it should be allowed in. Your answer is the testing exemption, and your job is to make that answer obvious from the documents. Your customs broker files the Bill of Entry, so brief them before the goods fly, not after the officer asks.

A single product can fall under several regimes, and each has its own testing carve-out. This table summarises what the official sources say.

Only as many as the lab needs, plus a small margin for transit damage. Three rules keep the number down.

Series grouping. You do not test every model. Samples are selected according to MeitY's series guidelines for each phase of the CRS Order, and further models in the series can be added later through supplementary test reports that refer back to the original^[4]. Ask the lab which model is the representative one before shipping; our series guidelines explainer covers the grouping rules by category.

One report for several brands. If one factory makes the same product for several brands, the CRS FAQ says they still need separate registrations, but these can rest on a common test report. Samples of every brand are not needed, as long as all brands and model numbers are listed and each brand's label is placed in the report^[15].

Lab requirements. The sample quantity for each test depends on the Indian Standard and the lab's test plan. Ask the lab in writing and keep the reply with your customs file. It is the simplest evidence that the quantity matches a genuine testing need.

If you are importing components rather than finished products, note that the CRS Order applies to finished goods, not to spare parts or components used to make them unless those are notified separately^[16].

It depends on the standard: from 2 units for some appliances to 40 pieces for screen protectors. For ISI-mark products BIS publishes a product manual with the sampling guidelines and scheme of inspection and testing for each standard^[17]; for CRS products, the series guidelines decide which models are tested. These published quantities are the best evidence you can give Customs that your shipment is a genuine sample, not stock.

A BIS-recognised laboratory in India that is recognised for your product's Indian Standard. CRS accepts reports only from labs established, maintained or recognised by BIS for the product^[4], and recognised labs accept CRS samples only against an online test request generated on the CRS website^[27].

Recognition is not a formality. A lab needs ISO/IEC 17025 accreditation from an ILAC or APAC member body, with every test parameter of the standard inside its accredited scope^[28]. Recognition runs for three years^[28], and the lab's declared testing charges stay fixed for those three years unless the standard is revised^[28]. Foreign labs can in principle be recognised on the same criteria plus an Indian office or representative^[28], but BIS's Group-1 list dated 30 October 2026 has 444 entries and every one is in India^[29]. In practice, that is why samples have to be imported at all.

To find a lab, search the LIMS portal by IS number, for example IS/IEC 62368-1:2023^[30]. Each LIMS entry shows the clause-wise charges, any excluded tests and the recognition validity date^[31]. Check the exclusions before you ship: a lab that excludes a clause your product needs will send you to a second lab, which means a second shipment. City-by-city lists are in our lab guides for Delhi NCR, Bengaluru, Mumbai and Pune, Chennai and Hyderabad, and the rules are in CRS test labs.

Declared charges vary widely. The table below is a snapshot of LIMS on 1 November 2026, excluding taxes.

The order matters, because the CRS portal starts a 60-day clock when you generate the test request^[2].

Everything the lab will print on the report: product category, product name, models and brands. These cannot be changed at application stage; if something is wrong, cancel the test request before testing starts and generate a fresh one^[34]. Because the 60-day sample window runs from the request^[2], a cancelled request also restarts your shipping plan.

Three details catch importers out:

• Marking labels. The labels on the lead and series models sent to the lab must be checked before dispatch^[34]. A sample with the wrong model number on its label produces a report that does not match your application.
• Battery chemistry. One licence covers all lithium-system cells, but each application or inclusion may carry test reports for only one chemistry^[35]. If you plan Li-ion and LiFePO4 battery packs, ship them as separate test plans.
• Adding models later. A supplementary report that adds series models or a brand is dated from its own issue date and must be submitted within 90 days^[36]. Do not ship series-model samples months ahead of the filing.

If a product needs a registered component, such as a battery inside a power bank, you can use parallel testing: the component and end product are tested at the same time, but BIS grants licences in sequence and you carry the risk if the component fails^[37]. For what a finished report should contain, see how to read a BIS test report.

The normal import set, plus evidence of the testing purpose. FTP para 2.06(b) lists the mandatory import documents as the transport document (Bill of Lading, Airway Bill or similar), the commercial invoice cum packing list and the Bill of Entry^[38], and you need an IEC to import at all^[38]. Everything else in the table is what makes the CRS exemption visible to the officer. Our customs clearance documents checklist has the full list.

The rules behind the steps are: the CRS portal is where the manufacturer registers, generates a test request and selects a BIS-recognised lab^[2]; the lab must be established, maintained or recognised by BIS for the product^[4]; the sample and request must reach the lab within 60 days with the QR code on the sample^[2]; no Standard Mark on samples^[3]; and the report must be under 90 days old when BIS receives the application^[4]. For wireless products, the undertaking to Customs is a WPC requirement^[6].

The documents describing the shipment as samples, the lab's written confirmation and the not-for-sale undertaking are our recommendations, not a prescribed format we could verify. They give the officer what the CRS exemption needs: evidence that the goods are genuinely for testing.

There is no fixed figure. The CRS FAQ says testing time depends on the workload of the lab you choose and on the manufacturer submitting the technical details the lab needs^[43]. What is fixed is the frame around it: 60 days to get the sample to the lab^[2], then 90 days from the report's issue to file^[4], then a BIS target of 20 working days if everything is in order^[4].

Shipping delays eat into the first window. If samples sit at the port for weeks, you may have to generate a fresh test request. That is the main reason to prepare customs paperwork before the request is generated. For the whole timeline, see how long BIS registration takes.

1. A private-label power bank from Shenzhen. A brand owner in Pune has a factory in China making a 10,000 mAh power bank in three capacities. Under the series rules for power banks with an external adaptor, a range of capacities can share a series if input voltage, construction class and other listed features match^[25], so the lab may need samples of one representative model, not three. The factory, which is the applicant^[44], nominates the brand owner as AIR^[45], generates the test request, and only then the samples fly, unmarked^[3]. The government side of the bill starts at Rs 1,000 application fee plus a Rs 25,000 processing fee for each year of the licence, paid in advance^[46], plus the lab's own charge for IS 16046 cells. Use the BIS CRS fee calculator for the rest, and the China import guide for the shipping side.

2. A Wi-Fi router for an ISP launch. A Wi-Fi router is not itself a CRS category, though its external adaptor is^[47]. It needs ETA and MTCTE^[48]. Samples travel under the WPC testing undertaking^[6] and the MTCTE sample-testing exemption^[7]; the adaptor samples travel under the CRS testing exemption^[1]. Three regimes, one carton, three pieces of paper.

3. Toy samples for product development. A toy importer wants twenty designs to evaluate before choosing which to certify. The Toys QCO allows R&D imports of up to 300 units a year, no more than five per sample type, not for sale^[8]. Twenty designs at five each is 100 units, inside the cap. For certification samples later, the BIS toys manual asks for 3 to 10 pieces, fully packaged and labelled^[21]. Commercial toy consignments are a different story: under DGFT policy a sample is picked from each consignment for NABL lab testing, and failing goods are sent back or destroyed at the importer's cost^[49]. See importing toys.

ISI-mark products work differently. Under FMCS, BIS officers visit the foreign factory and draw samples for independent testing^[50]. Those samples are tested only in BIS or BIS-recognised labs; the applicant sends them to the lab in India and pays the actual testing charges^[51]. Under the simplified procedure (option 2) for Scheme-I, the applicant instead submits a test report with the application^[52], and that report must generally be under 90 days old^[53].

If you want to import product samples for your own evaluation under a QCO, rather than for BIS testing, check the specific order. Several QCOs have explicit R&D import allowances with annual caps: toys up to 300 units a year with no more than five per sample type^[8], cookware up to 200 units^[13], furniture up to 200 units a financial year^[14] and footwear up to 4,500 pairs^[9]. These allowances are for R&D, not for sale, and records go to the government.

No, if they are genuinely for testing. RF devices in licence-exempt bands imported for testing, prototype or pre-launch purposes are exempt from WPC ETA, but the importer must give Customs an undertaking in the prescribed format^[6]. TEC's 2025 rules exempt equipment imported for R&D, demonstration, testing of samples or a regulatory sandbox from MTCTE conformity assessment^[7].

Remember that one product can need all three. A Wi-Fi router is a BIS, WPC and MTCTE product^[48]. Ship its samples with the BIS test request, the WPC undertaking and a note on the MTCTE testing purpose. See WPC ETA vs MTCTE for which applies to what. For the wireless side of the launch, see how to get WPC approval and the Saral Sanchar portal guide.

Units sent abroad for repair. The CRS FAQ says products sent abroad for maintenance can come back without a BIS registration number if the model and serial number do not change. A faulty unit replaced by a new one with a different serial number is covered by the Order^[54].

Highly specialised equipment. Large or high-power equipment (three-phase, single-phase over 16 A, larger than 1.5 m x 0.8 m, or over 80 kg) made or imported in fewer than 100 units per model a year can be exempted on a specific MeitY exemption, from 15 June 2026^[10]. CBIC told field formations to implement this in Instruction 08/2026-Customs, according to a copy of the instruction we read^[55].

Deadline products. For imports, the date of landing in India decides whether a CRS deadline applies^[5]. Samples landing before a category's start date are outside the Order anyway.

• The Standard Mark is already printed. Samples must not carry it^[3]. A factory that prints retail packaging with an anticipated R-number creates a problem at the port and with BIS.
• The 60-day window runs out in transit. Generate the test request when the samples are ready to fly^[2].
• Too many units. A carton of 200 "samples" looks like stock. Ship what the lab confirms it needs.
• No wireless undertaking. Without it, a Bluetooth sample can be treated as an unapproved wireless device^[6].
• Samples sold afterwards. The exemption covers testing, not sale. Selling unregistered CRS goods breaches section 17 of the BIS Act^[56].

You usually have a route forward, but it can cost a second shipment. A recognised lab must issue the report within 7 days of completing testing and may not withhold it^[28]. If the lab is suspended, BIS will not accept reports issued during the suspension; you may send fresh samples to another recognised lab and continue in the same file, with a scrutiny fee of Rs 10,000 plus taxes per report^[57]. If a sample fails, fix the design and retest; if the delay pushes a report past its age limit, a BIS DDG may accept reports outside the time norms for genuine reasons^[36]. Our guide to CRS rejections covers what BIS sends back most often.

If you would rather hand this to someone, our BIS consultants directory explains what consultants do and charge, or ask us for a free compliance check before you book the freight.

• "Samples under a certain value don't need anything." We found no value threshold in the CRS FAQ. The exemption depends on purpose, testing, not on value^[1].
• "A foreign lab report saves the shipment." Not for CRS today: every lab on BIS's Group-1 list is in India^[29]. MTCTE is different and accepts ILAC reports for some parameters^[58].
• "The lab can fix the model name later." It cannot; test request details are fixed once testing starts^[34].
• "Leftover samples can be sold." Selling unregistered CRS goods is a section 17 offence^[56]. Labs keep sample remnants for at least three months after the report^[28]; agree in writing what happens to the rest.
• "Any consultant or lab staffer can be my AIR." A recognised lab's management, staff and their families may not act as AIR for a foreign manufacturer^[28]. See how to choose a BIS consultant.