Selling into India as a foreign manufacturer: BIS registration, FMCS, EPR, MTCTE and WPC explained

India puts product safety on the maker and end-of-life and consumer duties on the business that sells in India. As a foreign manufacturer you hold the BIS licence. Your importer or Indian brand owner holds most of the rest, but often needs documents and labels from you.

The CRS licence is granted to the manufacturer for each factory, not to an importer or trader^[1]. A foreign manufacturer must nominate an Authorised Indian Representative (AIR)^[2].

Indian law puts three things on the foreign maker directly: the BIS licence, the product-safety liability that follows the "manufacturer" label, and, if it sells online to Indian consumers itself, the E-Commerce Rules. Everything else sits with the importer or brand owner in India, as our responsibility table by business type shows.

CRS covers many consumer electronics and IT goods. For electronics it rests on MeitY's Compulsory Registration Order, 2021, S.O. 1248(E)^[21], and works on the manufacturer's self-declaration backed by a lab report^[1]. The steps for a factory outside India:

The last official CRS fee table on crsbis.in is dated 4 June 2018^[26]. GST is added to every amount^[26]. A consultant reports that the February 2026 amendment changed the processing fee to Rs 25,000 a year paid in advance^[27]; until BIS publishes a revised table, treat that as unconfirmed. Use our CRS fee guide for detail.

Since the 25 February 2026 amendment, a CRS licence is granted for five years and renewed for five more, with fees paid annually in advance; a later corrigendum suggests some schemes read 'up to five years'^[4]. Before that, the first grant was two years^[28]. If the annual fee and production details are late, the suspension and cancellation provisions apply^[29]. A consultant reports a 90-day suspension and a Rs 5,000 late fee in that case^[27].

Other points for foreign factories:

• Brands. Each brand needs its own application unless the brand owner is the same^[2]. If you make for several Indian brands, plan one application per brand.
• Standards. MeitY replaced IS 13252 (Part 1) and IS 616 in the CRS schedule with IS/IEC 62368-1:2023^[30], with the older standards allowed alongside it until 1 November 2028^[31].
• Fee concessions. The processing fee concessions under the 2024 amendment are for micro, small and medium enterprises and start-ups^[32].
• Renewal. Apply for renewal three months before expiry^[33]. See CRS renewal.

Your AIR is your legal face in India for BIS. It can be (1) your liaison or branch office in India, (2) the brand owner or registered user of the brand in India, or (3) another Indian entity, if the brand owner declares it has no proprietor or registered user of the brand in India^[34].

The AIR must be an Indian resident who consents to be responsible for compliance with the BIS Act, rules, regulations and licence terms for you^[3]. One AIR can represent only one foreign manufacturer, unless the manufacturers are in the same group or the AIR is a related importer^[3]. So a consultant who already represents another factory may not be able to represent yours.

The role carries real liability. When a company commits an offence under the BIS Act, its authorised representative can be deemed guilty along with the company^[35]. BIS can also direct the licence holder or its representative to stop supply and recall non-conforming goods^[35].

TEC's MTCTE scheme has its own AIR concept: an Indian company or firm importing your equipment, registered on the MTCTE portal with an authorisation letter and a notarised affidavit or MoU with you^[7]. For WPC ETA, an Indian representative applying on your behalf needs your authorisation^[8]. One Indian partner can fill all three roles only if it meets each scheme's rules.

Products under a Quality Control Order that requires the ISI mark (Scheme-I) are licensed for foreign factories through the Foreign Manufacturers Certification Scheme (FMCS). In electronics, plugs and socket-outlets are an example: they must meet IS 1293 and carry the ISI mark from 1 June 2022^[36], which, in our reading, brings extension boards in. Our comparison of CRS, ISI and FMCS explains the difference.

FMCS is slower than CRS^[2] because BIS inspects the factory:

• Process. BIS scrutinises the application, visits the factory to check manufacturing and testing infrastructure and draw samples, and grants after satisfactory inspection and independent testing^[5].
• Time. About six months on average from a complete application^[5].
• Fees. Application fee Rs 1,000^[37]. Fees are the same as for domestic Scheme-I licensees, plus per-diem, tickets, visa and insurance for BIS officers and a Rs 10,000 contingency payment^[37]. Visits cost Rs 7,000 per man-day^[37]. Applicants outside SAARC pay in US dollars^[37].
• Before grant. You pay the licence fee and the advance minimum marking fee^[5].
• After grant. You sign an agreement and indemnity bond and give a USD 10,000 Performance Bank Guarantee from a bank with an RBI-approved branch in India^[5].
• Validity. BIS's FMCS pages state one to two years at first grant and renewal for up to five years^[38]. These pages may not yet reflect the 2026 amendment^[39].
• Surveillance. BIS keeps visiting the factory and buys samples from the market, and you report production and dispatch^[17].

From 1 June 2026, FMCS applications are accepted only online through Manakonline^[6].

Surveillance, reporting and fees, every year. The licence is not a one-off certificate.

• CRS surveillance registration. MeitY's CRS market surveillance runs through STPI, whose portal requires manufacturers, AIRs and brands to register each R-number with model details, sales channel, location and MRP, and to calculate surveillance charges^[40]. The costs of registration, including surveillance, are borne by the registered entity^[41].
• Annual fees. Since the 2026 amendment fees are paid each year in advance^[4]. For ISI licences, unpaid fees lead to suspension after 21 days' notice^[42].
• ISI market sampling. BIS generally buys two market samples a year per Scheme-I licence, rising to three or four based on past compliance^[43], and licensees report month-wise production and consignee details every quarter^[43].
• Model changes. New models go on by inclusion^[44]; see series guidelines.
• Renewal. Apply three months before expiry^[33] and put the date in the licence renewal date tool.

EPR registrations belong to the business in India that places goods on the market, not to you. But your importer cannot comply without your help.

E-waste. A producer includes anyone who sells under its own brand equipment made by others, or offers imported equipment for sale^[11]. Registration needs sales by weight, self-declarations of RoHS compliance and the availability of EN 50581 technical documentation^[45]. New equipment and components must stay within the RoHS limits: 0.1% by weight for lead, mercury, hexavalent chromium, PBB and PBDE, and 0.01% for cadmium^[11]. Send your importer the RoHS file; CPCB can ask for the conformance declaration at any time^[46].

Batteries. Importing equipment containing batteries makes the importer a battery producer^[12], who must register before importing^[47]. What you can do at the factory:

• print the crossed-out wheeled bin on every battery, at least 3% of the largest side within the size limits^[48];
• mark Hg, Cd or Pb where required^[49];
• keep portable batteries within 0.002% cadmium^[12];
• print the importer's EPR registration number on the equipment or its packaging, which is accepted for imported batteries^[50].

Plastic packaging. The importer of goods in plastic packaging is an obligated entity^[13]. Plastic packaging must show the producer's or brand owner's name and registration number, and a clause extends this to importers, though a proviso in the same rule exempts packaging used for imported goods, so the position is unclear^[51]. From 1 July 2025 that can be a QR code or barcode instead^[52].

CPCB has asked Customs to verify battery and plastic EPR registrations at clearance^[53][54], so a missing registration can stop your customer's shipment.

Only if your product is on TEC's notified list. No notified telecom equipment may be sold or used in India without a valid Certificate of Conformity Assessment^[55]. Wi-Fi access points and CPE became mandatory on 1 January 2024^[56] and routers on 1 August 2024^[56]. Mobile handsets, servers, smart watches, smart cameras and point-of-sale devices are exempt from prior MTCTE under S.O. 2372(E)^[57].

What a foreign maker should know:

• Two schemes. Under the Simplified Certification Scheme a certificate is normally issued within fifteen working days; under the General Certification Scheme TEC evaluates the reports, usually in 4 to 8 weeks^[58].
• Fees. Administrative fees run from Rs 10,000 (Group A) to Rs 50,000 (Group D)^[58].
• Labs abroad. A foreign lab can be recognised only if ILAC-accredited and not in a country sharing a land border with India^[55]. As a time-bound relaxation, ILAC reports no older than two years may be accepted except for parameters that must be tested in India^[58].
• BIS evidence counts. For safety parameters TEC accepts a valid BIS certificate or a report from a BIS-recognised lab^[58].
• Validity. A regular certificate normally lasts ten years^[58].
• Samples are exempt. Equipment imported for R&D, demonstration or sample testing needs no certification^[55].

Yes, if your product transmits radio. ETA is needed to import, sell and use devices in de-licensed bands^[8]. Since 9 September 2024 every ETA for licence-exempt wireless devices is granted on self-declaration via the Saral Sanchar portal^[59], except radar, jammers, drones and satellite equipment^[8].

• Who files. The importer or authorised Indian representative signs the undertaking^[10].
• Your test lab. The test report must come from an accredited lab, with its name and country stated; the 2019 format does not require an Indian lab^[10].
• Fee and validity. Rs 10,000 per model^[8], valid for the lifetime of the model unless revoked^[8].
• Pre-launch units. Devices imported for testing, prototypes or pre-launch are exempt, with an undertaking to Customs^[60].

DoT has moved licences and authorisations to the Telecommunications Act, 2023 portal^[61]. Whether that changes the ETA route is not yet clear, so check the portal before you file.

• Legal Metrology. Every retail pack must carry the importer's name and address, country of origin, net quantity, month and year of manufacture, MRP and consumer care details^[62]. Your importer registers under rule 27^[14]. Since 29 May 2026 importers may add declarations at AEO Tier-2 or Tier-3 bonded warehouses in India^[63].
• BIS product details. Model, batch, date or week of manufacture and the full manufacturer address must be on the product, pack or an attached label^[24].
• BEE star label. For mandatory appliances such as self-ballasted LED lamps^[15], each brand registers separately and testing is at BEE-recognised labs^[16]. The BEE portal opens only from Indian IP addresses; users abroad must ask BEE to whitelist theirs^[16].

Start with the product list and your Indian partner, then run lab testing and the BIS application in a tight window, because a CRS report expires for application purposes after 90 days^[2]. FMCS takes longer, about six months on average^[5], so start it first if you need both.

1. A Chinese power bank factory making for three Indian brands. Power banks are a CRS category^[65]. Each brand needs its own application^[2], but one test report can support all three when product and factory are identical^[66]. On the published fee table, each application carries Rs 1,000^[26] and Rs 50,000 processing^[26]: Rs 1,53,000 for three, plus GST. Each Indian brand must also find an AIR, and one AIR cannot serve unrelated factories^[3]. Country guide: China; product: power banks.

2. A Korean refrigerator maker. Household refrigerators need the ISI mark under IS 17550 (Part 1)^[67], so the route is FMCS. Known costs: Rs 1,000 application^[37], Rs 7,000 per man-day of inspection^[37], a Rs 10,000 contingency payment plus officers' travel^[37], and a USD 10,000 bank guarantee after grant^[5]. Refrigerators are also on BEE's mandatory list^[15]. Korea already had 3 FMCS records for household refrigerators^[68]. Country guide: South Korea; product: refrigerators.

3. A Vietnamese toy factory. Toys need the ISI mark to IS 9873 or IS 15644^[69]. Of 60 FMCS toy licence records on 30 October 2026, Vietnam held 28 and China none^[70], which shows the route is open to foreign factories that complete it. Country guide: Vietnam; order: toys QCO.

• BIS. Importing or selling notified goods without the Standard Mark under a valid licence carries up to two years in prison or a fine of at least Rs 2 lakh, extendable to ten times the value of the goods, or both^[35]. Your AIR can be deemed guilty with you^[35].
• Expired licence. After validity without renewal, you may not mark or dispatch goods with the Standard Mark, including stock in hand^[33].
• MTCTE. Uncertified notified equipment gets a seven-day stop notice; certification within 180 days costs ten times the normal fee^[55].
• EPR. Unregistered producers can be charged environmental compensation^[11]. That falls on your importer.

Paperwork, not product failure, causes most delays: AIR declarations, stale test reports and licences that drift into deferred or stop-marking status.

• Unrelated AIR without the brand-owner declaration. BIS's January 2025 advisory requires it^[64]. Rejected applications are not refunded once processed^[71].
• Test report over 90 days old. Plan the application date before you book the lab^[2].
• Licences that stop being operative. Of 256 FMCS records for Chinese factories on 30 October 2026, only 23 were operative; 209 were deferred and 24 under stop marking^[70]. Indian buyers check this status, so keep fees and reports current.
• Labs abroad for MTCTE. A foreign lab must be ILAC-accredited and not in a country sharing a land border with India^[55].
• BEE portal blocked. It opens only from Indian IP addresses unless BEE whitelists yours^[16].

A BIS consultant can act on the ground in India, or ask us for a free compliance check.