Why shipments get held at Indian ports: the compliance reasons behind stuck electronics consignments

A shipment can be held for many reasons: valuation, classification, documentation, or a random examination. This article covers only one group of them, the product compliance reasons: rules set by BIS, the Legal Metrology department, CPCB and the Department of Telecommunications that say what can be imported at all.

We outline where in the clearance process a compliance problem surfaces, but we do not quote demurrage or storage charges. Those depend on the port, the terminal and your contracts, and we have no official source for them. What we can tell you, with citations, is which rules goods can fail, and how to check before the goods leave the factory.

The foundation is section 17 of the BIS Act. It prohibits manufacturing, importing, distributing, selling or storing for sale goods notified under section 16 without a Standard Mark under a valid licence^[1]. The Act's definition of "person" includes importers^[1], so the duty is yours, not only the factory's.

Usually at assessment or examination, after the Bill of Entry is filed and before out of charge. Most sea imports must have the Bill of Entry filed by the end of the day before arrival, and it can be filed up to 30 days ahead^[14]; airports and land stations allow filing up to the end of the day of arrival^[15]. Filing late costs Rs 5,000 a day for the first three days and Rs 10,000 a day after that, capped at the duty payable or Rs 50,000 where no duty is payable^[8].

The Bill of Entry counts as self-assessed once the customs system gives it a number; after assessment, and examination if required, the officer orders clearance under section 47^[16]. For CRS electronics, a CBIC instruction reportedly tells officers to check BIS registration in the system for every consignment, with the risk management system picking some for lab sampling and out of charge only on a pass^[17]. For toys, every consignment is sampled for NABL lab testing, and the goods may be cleared only on condition they are not sold until the sample passes^[18].

Documents are uploaded through eSanchit on ICEGATE^[19], usually by your customs broker. Our customs clearance documents checklist and documents required for import in India list what goes in.

This gap comes from assuming a licence covers more than it does. A CRS licence is narrow in three ways.

It belongs to one factory. Under CRS the applicant is the manufacturer, and the licence is granted per manufacturing unit, not to an importer or trader^[2]. If your supplier is a trading company, or moves production to a sister factory, the licence you were shown may not cover the goods you received.

It covers named brands. A separate CRS application must be made for each brand name unless the brand owner is the same^[3]. A factory's licence for its own brand does not cover your private label.

It covers named models. New models are added by inclusion: a new test request, a lab report and an online application^[9]. A "new version" with a different model number is not covered until it is included.

One more trap: a separate licence is needed for each product name, and BIS has issued guidance on where newer products like audio glasses and smart glasses belong^[20]. A product filed in the wrong category is not covered either.

What to do: before you pay the balance, ask for the licence and check the factory address, brand and every model number against your invoice and packing list. Our CRS documents guide lists what the licence holder should have.

A valid licence is not enough if the goods are not marked. The CRS Standard Mark must carry the licence (R-) number and the Indian Standard reference^[10]. The product, its package, or both must be marked in an easily visible way, legibly, indelibly and non-removably^[10], with text not smaller than Arial size 6^[10]. The BIS website, www.bis.gov.in, must also appear on the product or package^[21].

Common failures:

• Mark only on the screen. Devices with a display may show the mark electronically, but a physical label is still required on the packaging at import, storage and sale^[22].
• Mark on neither product nor box for small items. If size prevents marking the product, as with earphones, the mark goes on the packaging^[23]. It cannot be skipped.
• Wrong IS number. Categories under IS 13252 (Part 1) and IS 616 moved to IS/IEC 62368-1:2023, with old standards allowed concurrently until 1 November 2028^[24][25]. The IS number on the label should match the licence.
• Missing product details, such as model number, batch, date of manufacture and manufacturer address^[10].

See our CRS labelling guide for the full marking rules.

Licences can lapse, and the factory may not tell you.

After the validity date of a CRS licence that has not been renewed, the licensee is not authorised to mark or dispatch products with the Standard Mark, including stock in hand^[4]. If renewal and fees are not received, the licence expires 90 days after validity, and a licence under suspension expires if the suspension is not revoked within 180 days^[4].

The 2026 rules add a new trigger. CRS licences now run for up to five years with fees paid annually in advance^[26]. If the yearly fee and production statement are not received by the due date, the licence is suspended for 90 days from that date, with no notice. Paying within the 90 days with a Rs 5,000 late fee lifts the suspension; otherwise the licence is cancelled^[27].

What to do: check the licence status shortly before each shipment, not just before the first one. See CRS renewal.

Not everything electrical sits under CRS. Many products fall under Quality Control Orders that need an ISI mark under BIS Scheme-I instead. If you import a mixed container, one line item under a QCO can hold the shipment.

• Plugs and sockets. From 1 June 2022, plugs and socket-outlets must conform to IS 1293 and carry the ISI mark^[11]. The BIS product manual allows portable and multiple socket-outlets in licence scope^[28], so the plug and socket parts of extension boards are likely to come under this QCO^[11].
• Electrical appliances. A Safety of Household, Commercial and Similar Electrical Appliances QCO was issued in April 2026, with implementation on 1 October 2026^[29].
• Toys, including electric toys. Electric toys must meet IS 15644 and carry the ISI mark under the Toys QCO^[30].
• Upcoming orders. BIS lists 30 product entries due for enforcement between 6 November 2026 and 1 May 2027^[31]. Our QCO tracker follows them.

Transition relief. For 26 already-implemented QCOs, including electrical accessories and appliances, DPIIT exempts imports shipped (per the Bill of Lading) before implementation with a Bill of Entry within 180 days of implementation, with documents sent to BIS within 7 days of clearance^[7]. A parallel exemption covers purchase orders placed before implementation^[32]. If you rely on one, keep the dated documents.

CRS dates move. Television sets requiring IS 18112 were deferred to 26 January 2027^[33]. Standalone hard disk drives were brought in from 5 November 2026 and then deferred to 1 May 2027^[34][35]. Smartphone screen protectors join on 1 April 2027^[36].

Goods ordered before a deadline but arriving after it are a classic cause of trouble. Check the date against when your goods will actually arrive and be cleared, and watch our 2026 rules ledger for changes. The compliance calendar lists every upcoming date in one place.

Retail packages must carry the Legal Metrology declarations: the name and address of the manufacturer, packer or importer, country of origin, common name, net quantity, month and year of manufacture, MRP, unit sale price and consumer care details^[12]. Consumer care means a name, address, phone number and e-mail for complaints; the 2011 rule text requires the e-mail only 'if available'^[38]. The 2011 rule text bars stickers that change mandatory declarations, except a reduced MRP that does not cover the original^[38].

The importer must also be registered. Anyone importing commodities in pre-packed form for sale must register under rule 27^[38], within 90 days of starting^[38].

There is one useful relief. Importers can make the mandatory declarations in the bonded warehouses of AEO Tier-2 and Tier-3 certified operators, as long as the retail packages carry all declarations before leaving^[39].

The penalties were rewritten in 2026. A first offence draws an improvement notice, a second a penalty of up to Rs 5 lakh, and later offences Rs 25-50 lakh^[40]. Check your artwork with the label checker and the Legal Metrology label rules.

EPR used to feel like a post-sale obligation. CPCB has now asked Customs to check it at the border.

• Batteries. CPCB wrote to CBIC on 23 December 2022 asking Customs to verify CPCB registration certificates when clearing batteries and equipment containing batteries^[5]. CPCB's FAQ says importers must register before importing^[41]. Earbuds, power banks, smartwatches and laptops all contain batteries^[42].
• Plastic packaging. CPCB wrote to CBIC on 13 June 2025 asking Customs to verify proof of plastic EPR registration when clearing importers' consignments^[6]. Importers of products in plastic packaging are obligated entities^[43].
• E-waste. Producers, including importers offering EEE for sale, must register and may not do business without it^[44][45]. Imports of EEE are allowed only for RoHS-compliant products^[44].

Battery labels matter too. Batteries must carry the producer's EPR registration number^[46]; for imported batteries it can go on the equipment or its packaging^[47]. See battery EPR.

Under a 1953 customs notification, a licence from the Ministry of Communications is required to import any wireless transmitter, receiver or transceiver, subject to exemptions^[13]. For licence-exempt consumer devices, that exemption works through ETA:

• For licence-exempt devices that are 'Free' under DGFT policy, the system-generated import undertaking from the Saral Sanchar portal is enough^[13], and Customs may treat the self-declaration as sufficient evidence^[48].
• For licence-exempt devices that are 'Restricted', WPC guidance says a scrutiny-based ETA and a separate import licence are needed, though how this works since the September 2024 move to self-declaration is unclear^[13].
• Equipment in licensed bands needs its own licences^[13].
• ETA covers RF rules only; DGFT import compliance is separate^[49]. Laptops and tablets under HSN 8471 are reported to need an Import Management System authorisation^[50].

Telecom equipment notified under MTCTE, such as routers and Wi-Fi access points^[51], also needs a TEC certificate before sale^[52]. For the difference between the two telecom approvals, see WPC ETA vs MTCTE.

The HS code and the BIS category should tell the same story. If they do not, expect questions. Two examples from our research:

• CESTAT New Delhi has held a smart watch classifiable under ITC(HS) 85176290^[53], and a tribunal has sent back a case on whether an "activity tracker" is a smart watch, holding that Revenue must prove the classification^[54].
• Power banks are likely classified under 85076000 (lithium-ion accumulators), based on reported advance rulings^[55], and are a CRS category in their own right^[56].

Agree the HS code and the CRS category with your customs broker and the factory before shipping.

Several holds have nothing to do with the product and everything to do with the importer's own registrations. They are the cheapest to prevent.

1. Power banks from China. A power bank is its own CRS category^[56], so the factory needs a licence covering your brand and model^[3], and the units must carry the Standard Mark with the R-number^[10]. Because it contains a battery, CPCB has asked Customs to verify battery EPR registration^[5]. Two separate holds are possible on one line item. See importing from China.

2. A mixed toy shipment. Toys need the ISI mark under the Toys QCO^[30], and on top of that each consignment is sampled. At JNCH the importer gives a No Use Bond equal to the assessable value, a sample of each toy type is drawn for a nominated NABL lab, and the report is due within two months; failing goods come back for destruction at the importer's cost^[60]. See importing toys.

3. Wi-Fi routers for an ISP. The router needs a WPC ETA and MTCTE^[61], and its external power adaptor falls under CRS^[56]. The ETA's Saral Sanchar import undertaking covers the radio side for 'Free' items^[13]; MTCTE is enforced at sale and use^[52]. See Wi-Fi routers.

4. Camera drones. Here the problem is not a missing certificate but import policy itself: DGFT prohibited import of drones in CBU, SKD or CKD form from 9 February 2022^[62], with exceptions for government, recognised R&D and similar entities^[62]. A retail importer cannot fix that with paperwork. See drones.

More than the demurrage. In a February 2026 order, JNCH confiscated seven gas cylinders that had been shipped before valid PESO Form D licences were issued, allowed redemption on a Rs 30,000 fine, and imposed penalties of Rs 5,000 under section 112(a) and Rs 50,000 under section 114AA of the Customs Act^[59]. Customs held that the licence had to be valid on the date of shipment, so licences obtained after the goods sailed did not help^[59]. The importer was held liable even though its broker had submitted the documents, because the broker acts with the importer's consent^[59].

The lesson carries over to BIS, WPC and EPR: the approval has to exist and be valid before shipment, and the importer, not the broker, answers for it. Brokers have their own duty to verify client details^[63], but that does not move the liability.

The BIS Act's consequences are clear. Under section 29(3) as enacted (later amendments not checked), contravening section 17 is punishable with imprisonment up to two years, or a fine of at least Rs 2 lakh for a first contravention and Rs 5 lakh for later ones, extendable to ten times the value of the goods, or both; the offence is cognizable^[1]. Where a company offends, responsible directors and managers are also deemed guilty^[1]. Some first offences may be compounded^[1].

While goods wait, storage and demurrage charges can build up. Those are commercial charges with no figure in our official sources, so we do not estimate them. For what the penalty provisions mean for a seller, see selling without BIS: what happens.

• "The broker will sort out compliance." The broker files; the importer is liable for what is filed^[59].
• "A licence applied for is as good as a licence granted." Customs has held that the licence must be valid on the shipment date^[59].
• "EPR is only checked at year-end returns." CPCB has asked Customs to verify battery and plastic EPR at clearance^[5][6].
• "Labels can't be fixed once the goods are in India." Legal Metrology declarations can be applied in AEO Tier-2 or Tier-3 bonded warehouses before release^[39]. BIS marking is a different matter: it belongs to the licensed factory.
• "Mark it on the screen and skip the box." A physical label is still needed on the packaging even when the device shows the mark electronically^[22].

Do the checks before the goods ship. In order:

1. Confirm the CRS category and IS number for each product.
2. Get the factory's licence and check factory, brand and every model.
3. Check the licence is valid on the dispatch date.
4. Photograph the product and box and check the Standard Mark, R-number and www.bis.gov.in.
5. Check the Legal Metrology declarations and your LMPC registration.
6. Register for battery and plastic EPR before the first import.
7. Get the ETA for each wireless model.
8. Check whether any item in the container falls under a QCO.

Our first electronics import checklist puts all of this in one list, with citations. The approval checker and compliance cost estimator help with steps 1 and 6, and if you want a second pair of eyes, ask for a free compliance check before the goods are booked.