Importing electronics from China into India: what the factory must hold and what falls on you

India splits the work in two. BIS safety approvals belong to the factory that makes the goods. Environmental and consumer approvals belong to whoever imports and sells them in India: you.

The CRS licence is granted to the manufacturer for each factory, not to an importer or trader^[1]. But you are not off the hook: the BIS Act counts importers, distributors and sellers as "persons" bound by the ban on goods without the Standard Mark^[11]. So the factory's licence must cover your model before you ship.

China is India's largest single source of goods: imports were US$ 131,620.29 million in 2025-26, up from US$ 113,447.34 million the year before, out of total imports of US$ 775,713.17 million^[18]. Much of that is electronics and their inputs.

The lines below are the ones small importers ask about most. Each has its own approvals, and three have a dedicated China guide. Note how large the lithium-ion line is: almost all of India's imports under that tariff item came from China^[19], and every battery or battery-powered product brings battery EPR on top of BIS.

Mostly, no. The BIS, EPR, Legal Metrology and WPC rules in our research apply to every foreign factory in the same way, wherever it is. A CRS application from a Chinese factory goes through the same portal, forms and test report rules as any other.

The official rules in our research that do turn on where the factory or lab is located are these:

• Telecom testing labs. Under the 2025 telecom conformity rules, a lab abroad can be recognised as a Conformity Assessment Body only if it is ILAC-accredited and is not in a country that shares a land border with India^[9]. China shares a land border with India, so for MTCTE products such as Wi-Fi routers, plan on testing at a lab in India or in a country that does not border India. An earlier TEC relaxation for ILAC test reports was also limited to non-border-sharing countries^[26].
• FMCS fees in dollars. For the ISI-mark route, applicants outside SAARC must pay in equivalent US dollars, by RTGS, NEFT or SWIFT, net of bank charges^[5]. A factory in China pays in dollars.
• Country of origin on the pack. Every pre-packaged commodity must declare its country of origin^[27]. Rules on e-commerce country-of-origin filters are covered in our guide for marketplace sellers.

By contrast, a WPC ETA self-declaration only asks that the RF test report come from an accredited lab, with its name and country stated; the 2019 format names no accreditation body and does not require an Indian lab^[16].

Duty is a separate matter. China is not on India's list of FTA partners^[28], so no preferential rate applies, and several anti-dumping duties name Chinese producers. Both are covered further down, together with the investment rule for land-border countries.

Many electronics from China are CRS products: earphones, power banks, chargers, smart watches, LED lighting, laptops, phones and more. The factory applies online on crsbis.in^[3]. Here is the route from the factory's side.

• One licence per factory. The licence is tied to a manufacturing unit^[1]. If your supplier is a trading company that moves orders between factories, each factory that makes your goods needs its own licence.
• One application per brand. A separate application is needed for each brand name unless the brand owner is the same^[2]. A factory's licence for its own brand does not cover your private label.
• The standard is changing. MeitY replaced IS 13252 (Part 1) and IS 616 with IS/IEC 62368-1:2023 in the CRS schedule^[31]. The old standards may run alongside it until 1 November 2028^[32]. Ask which standard the report will be issued to before testing.
• Expired licences. After a licence's validity date, if it has not been renewed, the factory may not mark or dispatch goods with the Standard Mark, including stock in hand^[33].

Every foreign CRS applicant must nominate an Authorised Indian Representative (AIR) on Form IV^[2]. The AIR can be:

1. the factory's own liaison or branch office in India;
2. the brand owner, or the registered user of the brand, in India; or
3. another Indian entity, in which case the brand owner must declare it has no proprietor or registered user of the brand in India^[12].

The AIR must be an Indian resident who agrees to be responsible for compliance with the BIS Act, rules, regulations and licence terms for the factory^[34]. An AIR can represent only one foreign manufacturer, except for factories in the same group or related importers nominated as AIR^[34].

Think before you agree to be the AIR. Where a company commits an offence under the BIS Act, its authorised representative can be deemed guilty along with the company^[11]. Changing the AIR later costs Rs 5,000 plus GST^[35].

See the AIR glossary entry for more.

It depends on the scheme.

CRS: no factory visit in the official steps. The official CRS steps are lab testing and an online application, with no BIS factory visit listed^[3]. CRS rests on the manufacturer's self-declaration of conformity^[1].

ISI mark through FMCS: yes. Products under a Quality Control Order that require the ISI mark are certified for foreign factories under the Foreign Manufacturers Certification Scheme (FMCS). One example among the products we track is extension boards, which in our reading fall under this rule: plugs and socket-outlets must meet IS 1293 and carry the ISI mark from 1 June 2022^[36]. The FMCS process is: application scrutiny, a BIS visit to the factory to check its manufacturing and testing set-up and draw samples, independent testing, and grant^[4].

What that means for a Chinese factory:

• Online only. From 1 June 2026 BIS accepts FMCS applications only through the Manakonline portal^[37].
• The factory pays for the visit. Fees are the same as for Indian Scheme-I licensees, plus per-diem, tickets, visa and insurance for the BIS officers, and a Rs 10,000 contingency payment^[5]. Visit charges are Rs 7,000 per man-day^[5].
• Bank guarantee. After grant, the factory signs an agreement and indemnity bond and gives a Performance Bank Guarantee of USD 10,000 from a bank with an RBI-approved branch in India^[4].
• About six months. BIS says FMCS licences take on average around six months from a complete application^[4].
• Ongoing surveillance. BIS keeps visiting licensed factories and buys samples from the market^[38].

One more order to watch: the Safety of Household, Commercial and Similar Electrical Appliances (Quality Control) Order, 2026 was issued on 6 April 2026 with implementation on 1 October 2026^[39]. If you import appliances from China, check whether your product is in its schedule. Our CRS, ISI and FMCS comparison explains the three routes side by side.

Because most of them are deferred. On BIS's FMCS list of 30 October 2026, China had 256 licence records, but only 23 were operative; 209 were deferred and 24 were under stop marking^[10]. Compare South Korea, with 291 of 321 operative^[40]. A deferred or stopped licence does not let the factory use the ISI mark, so the headline count of 256 overstates how many Chinese factories can supply ISI goods today.

We counted the list by Indian Standard on 1 November 2026. The big groups are cables, plugs, tyres and compressors, and very few of them are live^[40]. Household appliances under IS 302 show 10 Chinese records, covering irons, hand mixers and room heaters, and none is operative^[40]. There is no Chinese record at all under the toy standards^[40], which is why our toys from China guide starts with the factory's licence status.

The operative 23 include three plug and socket licences, one motorcycle helmet licence under IS 4151 and one for residual current circuit-breakers^[40]. Even "operative" needs a second look: across the whole list, 428 operative records showed a validity date before 1 November 2026, five of them Chinese^[40]. Check both the status and the validity date, which the list shows for every CML number^[10].

These approvals cannot be held by the Chinese factory. They sit with the business in India that imports and sells.

EPR for e-waste. A "producer" under the E-Waste (Management) Rules, 2022 includes anyone who offers imported electrical and electronic equipment for sale, whatever the sales channel^[13]. Producers must register on the CPCB portal and may not do business without it^[13]. Imports and sales are allowed only for products that meet the RoHS limits on hazardous substances^[13], so ask the factory for its RoHS data.

EPR for batteries. Importing batteries, or equipment containing batteries, makes you a producer under the Battery Waste Management Rules^[14]. CPCB says importers must register before importing^[6]. Earbuds, power banks, phones, laptops and smart watches all contain batteries^[14][41].

EPR for plastic packaging. An importer of any commodity with plastic packaging is covered^[15].

Legal Metrology (LMPC). Every person who imports a commodity for sale must register its name and address^[7]. The fee is Rs 500^[7] and you must apply within 90 days of starting^[7].

WPC ETA for wireless products. Bluetooth, Wi-Fi and other licence-exempt radio devices need an ETA^[8]. The Indian importer or authorised representative files the self-declaration on Saral Sanchar^[42], at Rs 10,000 per model^[8]. The documents are the RF test report, an authorisation from the manufacturer if you apply as its Indian representative, and technical literature^[8]. Ask the Chinese factory for the authorisation letter up front.

BEE star label for LED bulbs. Self-ballasted LED lamps are on BEE's mandatory list^[43]. Any company that makes, sells or imports a mandatory appliance must register with BEE, for a one-time Rs 5,000 fee^[43].

TEC MTCTE for telecom gear. A foreign maker's equipment is certified through an AIR that is an Indian company importing it^[17]. Wi-Fi access points and CPE have needed MTCTE since 1 January 2024^[44].

Labels are cheapest to get right at the factory. If a product is too small for the BIS mark, such as earphones, it can go on the packaging only^[45]. Since 29 May 2026, importers may also add the Legal Metrology declarations at AEO Tier-2 or Tier-3 bonded warehouses before goods leave them^[46].

These are official fees only. They exclude lab testing, consultants and travel. The CRS figures are from the fee table published on crsbis.in, applicable from 4 June 2018^[35]. A consultant reports that the 25 February 2026 amendment changed the CRS processing fee to Rs 25,000 a year, paid annually in advance^[52], but the official fee table on crsbis.in had not been updated when we checked.

About Rs 1.37 lakh in official fees and lab charges at the low end, before GST and consultants, split between the factory and you. Here is how a first-time importer of one power bank model, made in a Shenzhen factory with no Indian registration, would add it up.

Power banks are a CRS category under IS/IEC 62368-1:2023^[21], so the factory needs an R-number. The power bank has no radio, so no ETA is needed, but the battery and the plastic packaging make you a producer under two EPR regimes^[41][56]. Lab charges vary a lot: four Delhi labs on BIS's lab system declare Rs 65,000 to Rs 1,92,000 for IS/IEC 62368-1^[57].

The arithmetic: factory side Rs 1,000 + Rs 50,000 + Rs 1,000 + Rs 65,000 = Rs 1,17,000; importer side Rs 10,000 + Rs 10,000 + Rs 500 = Rs 20,500; together Rs 1,37,500 at the lowest lab price and the smallest EPR bands. A consultant is extra: one firm lists a professional fee of Rs 14,999 for CRS, as reported on its website^[58]. Run your own numbers in the compliance cost estimator or the BIS CRS fee calculator.

Goods from China pay the normal tariff rate, because China is not on India's FTA partner list^[28], and some products also carry anti-dumping duty that names Chinese producers. There is no certificate of origin that lowers the rate.

Tariff rates are set product by product. Toys and toy parts under heading 9503 carry basic customs duty of 70%^[59], while cellular mobile phones and their chargers were cut to 15%^[60]. Check your exact tariff line before pricing.

Anti-dumping duty is imposed by a Finance Ministry notification under section 9A of the Customs Tariff Act after DGTR findings, usually for five years^[61]. It is charged on top of basic duty, whatever approvals the product holds. The table is a selection relevant to electronics and appliance supply chains, not a complete list. The steel safeguard duty also applies to China: China is one of the developing countries left out of the exemption for certain categories^[62].

Not for buying goods. Press Note 3 is an investment rule: since April 2020, investment by an entity of a country sharing a land border with India, or where the beneficial owner is there, needs government approval^[68]. It says nothing about importing finished goods on an invoice.

It matters when the Chinese side wants equity. If a Chinese factory plans to set up an Indian subsidiary to act as its Authorised Indian Representative or to assemble locally, the investment takes the government route. A later transfer that brings beneficial ownership within the rule also needs approval^[69]. DPIIT revised the text in March 2026, keeping the government route and adding a reporting duty for some land-border-linked investments^[70]. Many Chinese brands therefore use an unrelated Indian company as AIR, which needs a brand-owner declaration under BIS's 2025 advisory^[71].

The commercial set (invoice, packing list, bill of lading) plus proof of every registration the goods need, uploaded before the Bill of Entry is filed. The 2025 JNCH and Bengaluru notices ask importers to complete any required registration first and upload the certificate in eSanchit^[73].

For CRS goods, a CBIC instruction reported from December 2023 tells officers to check BIS registration for every consignment and lets the risk system pick samples for testing at BIS-recognised labs^[74]. File the Bill of Entry before the day of arrival ends^[75], or pay late charges of Rs 5,000 a day for the first three days^[76]. The full list is on our customs clearance documents checklist, and filing happens on ICEGATE.

Most problems are paperwork mismatches between the factory's BIS record and what actually ships. BIS's own lists of frequent deficiencies are dominated by inconsistent names, addresses, models and brands^[80]. Our CRS rejections guide covers the full list.

Start with the free tools, then use a lab and, if you need one, a consultant. No BIS-recognised lab sits in China: BIS's Group-1 list of 30 October 2026 has 444 labs, every one in India^[85]. So the factory's samples travel to India. Lab directories by city: Delhi NCR, Bengaluru, Mumbai and Pune, Chennai and Hyderabad; our test labs guide explains how to choose one.

If the factory has never dealt with BIS, a consultant can act as the go-between. Compare BIS consultants, including those in Delhi and Noida, and read how to choose a BIS consultant. Consultant prices advertised online start from Rs 7,899, according to one listing that does not say what is included^[86].

Free tools: the approval checker, the HS code approval finder, the QCO deadline checker and the label checker. Or ask us for a free compliance check on your Chinese supplier.

• BIS. Under section 29(3) of the BIS Act as enacted (later amendments not checked), importing or selling notified goods without the Standard Mark under a valid licence is punishable with up to two years in prison or a fine of at least Rs 2 lakh for a first offence, rising to ten times the value of the goods, or both^[11]. BIS can also order the licence holder to stop supply and recall non-conforming goods^[11].
• Legal Metrology. Importing or selling a pre-packaged commodity without the required declarations brings an improvement notice for a first offence, a penalty of up to Rs 5 lakh for a second, and a fine of Rs 25 lakh to Rs 50 lakh after that^[87].
• EPR. Environmental compensation can be levied on unregistered producers as well as registered ones^[13]. For battery-rule breaches other than a target shortfall, it starts at Rs 20,000 for a first default^[88].
• MTCTE. Notified telecom equipment found without a certificate gets a notice to stop sale within seven days; certification within 180 days costs ten times the normal fee^[9].