Importing LED bulbs from China to India: the factory's IS 16102 registration, BEE star label, EPR and costs for 2026

Before LED bulbs leave China you need the factory's BIS CRS registration covering your brand and model, a BEE star label permission for each model, and your own EPR and Legal Metrology registrations in India.

Self-ballasted LED lamps have been a CRS product since 13 September 2015, under IS 16102 (Part 1)^[1]. The registration goes to the manufacturer for each factory^[10], so your Chinese supplier applies. LED lamps are also on the Bureau of Energy Efficiency's mandatory list^[4], and no BEE label may go on a mandatory appliance without BEE's prior written permission^[4].

LED bulbs are unusual among Chinese electronics because the two product approvals sit with different parties. The Chinese factory holds the BIS registration. For BEE, any company that makes, sells or imports a mandatory appliance must register^[4], so you as importer can hold the BEE permission. That split shapes everything below.

For general LED bulb rules, read our LED bulb import guide. For general advice on Chinese suppliers, see importing from China.

The Chinese factory holds BIS CRS; you usually hold BEE, EPR, LMPC and the IEC. Smart and rechargeable bulbs add WPC or battery EPR.

China supplies most of them by value: US$ 13.17 million of the US$ 18.58 million of LED lamps India imported in 2025-26^[7].

Imports of LED lamps from China rose from US$ 8.52 million in 2024-25^[7]. LED modules from China fell, from US$ 11.96 million to US$ 8.94 million^[20]. These are modest sums next to China's US$ 131,620.29 million of total exports to India in 2025-26^[21], which suggests much of India's LED lamp demand is met by local assembly. Indian makers who import parts benefit from a customs exemption entry for all parts used to make LED lights, fixtures and lamps, which the 2026-27 Budget extended to 31 March 2028^[22]; check the rate with your broker.

The tariff line for finished LED lamps is ITC(HS) 85395200^[6]. Luminaires, battens and panels are different products with different CRS categories; see LED luminaires and HS codes.

Look up the R-number on crsbis.in's List of Registered Manufacturers and confirm the factory address in China, your brand, every model, the IS 16102 edition and the validity date.

The crsbis.in search finds registrations by R-number, product, model or brand, and shows the manufacturer, its address and country, the IS number, grant date, status, validity and scope by brand^[23]. The BIS Care app can verify an R-number too^[24]. Step-by-step help is in how to verify a BIS licence.

Yes. Every Chinese factory with an LED lamp registration must move its lead models to IS 16102 (Part 1):2026, and the last date was extended to 2 February 2027^[3].

The 2026 edition supersedes the 2012 one^[28]. BIS's guidelines of 24 February 2026 first set 2 August 2026 as the end of concurrent running, with existing licensees submitting complete test reports for lead models plus an undertaking for series models^[29]. BIS later extended the last date of implementation to 2 February 2027^[3].

The new edition changes what is tested: it covers lamps up to 60 W, adds photobiological safety tests and marking, covers lamps with non-removable rechargeable batteries, and adds abnormal-operation and ingress-protection tests, new marking for lamps not suitable for water contact, and an axial strength test for Edison caps^[29]. Artwork may need to change, so ask the factory for its migration plan before you approve packaging for 2027 stock.

It applies on crsbis.in with an English business licence, has samples tested at a BIS-recognised lab, and files Form I within 90 days of the report, naming an Authorised Indian Representative.

The factory registers on www.crsbis.in, generates a test request, picks a lab and files Form I^[30]. Its business licence must be in English or carry a certified translation, showing the factory's name, address and manufacturing scope^[30]. Samples with the portal QR code go to the lab within 60 days^[30], and the report must be no more than 90 days old when BIS gets the application^[25].

LED lamps are in MeitY's Phase II series guidelines with other lighting and power products^[31]. BIS's Annexure-2 allows up to 20 models in one series for several LED lighting categories^[32], so a factory making 5 W to 15 W bulbs on one platform may cover a range with one lead test and supplementary reports^[25]. Supplementary reports must be filed within 90 days of their own issue date^[33]. See series guidelines.

The factory then uploads the AIR nomination and a notarised affidavit^[34]; the original affidavit must reach BIS within 30 days^[34]. BIS aims to decide in 20 working days if all is in order^[25]. Use the CRS application checklist and the CRS portal guide.

The Indian brand owner is the natural AIR for a private-label bulb; for a Chinese brand, it is the factory's Indian office or an Indian entity that accepts responsibility.

A foreign CRS applicant may nominate its Indian branch or liaison office, the Indian brand owner or registered user, or another Indian entity where the brand owner declares it has no proprietor or registered user in India^[35]. The AIR must be an Indian resident who consents to answer for BIS compliance^[36], and may represent only one unrelated foreign factory^[36]. Under section 30 of the BIS Act, an authorised representative can be deemed guilty with the company for an offence^[37].

If you buy bulbs from one Chinese factory and battens from another, you cannot be AIR for both unless they are in the same group. Read the AIR glossary entry and our guide for foreign manufacturers.

Register your company with BEE, pay the security deposit, register each bulb model with a test report from a BEE-recognised lab, then print the label with a QR code and pay label fees every quarter.

The BEE (Appliance Labeling and Compliance) Regulations, 2026 came into force on 1 January 2026^[4]. A company that makes, sells or imports a mandatory appliance registers once for Rs 5,000^[4]. Each appliance category needs a label security deposit of Rs 3 lakh, or Rs 50,000 for small-scale industry, refundable on permanently stopping^[4]. Each model costs Rs 5,000 to register^[4], and appliances must be tested in BEE-recognised labs^[38].

There is a China-specific snag: the BEE Star Label portal works from Indian IP addresses, and users outside India must formally ask BEE to whitelist their IPs^[38]. That is one more reason the Indian importer usually holds the BEE registration.

BEE has upgraded the star rating table for LED lamps from 1 January 2027^[5], so a bulb rated at one star level in 2026 may rate lower under the new table.

For importers buying from China, this means two things. First, plan orders so that stock labelled under the old table is sold or relabelled in time; check the advisory for transition terms before you print. Second, ask the factory whether its efficacy improvements will keep your current star level, because the star level is printed on the label alongside the country of origin^[4]. Our BEE products list and star rating entry explain the scheme.

E-waste EPR and plastic EPR for ordinary bulbs; battery EPR as well for rechargeable or emergency bulbs. All three registrations are yours, not the Chinese factory's.

E-waste. LED lamps are reported to fall under Schedule I code CEEW18^[39], which covers other lighting equipment excluding filament bulbs^[9]. A producer includes anyone offering imported EEE for sale, through any channel^[9]. The registration fee is Rs 10,000 if your sales have just started^[12], with a Rs 5,000 annual maintenance charge^[12]. Registration lasts five years^[12]. You may only import RoHS-compliant products^[9], and registration needs RoHS self-declarations and EN 50581 technical documentation^[12], so get the factory's RoHS file before shipping. Targets: e-waste EPR targets.

Plastic. Bulbs in plastic clamshells make you an importer under the plastic rules^[13]. If you use paper cartons only, check whether any inner plastic remains.

Battery. Standard bulbs have no battery, but rechargeable and emergency bulbs do^[18]; CPCB requires importers of equipment containing batteries to register before importing^[40]. Read EPR for small importers and the EPR registration checklist.

The BIS Standard Mark with IS number and R-number, www.bis.gov.in, the BEE label with QR code, your EPR details and the Legal Metrology declarations. The factory prints the BIS details; you supply the rest.

Customs checks that the model is BIS-registered and may draw samples under its risk system; your EPR registrations may also be asked for.

CBIC Instruction 28/2023-Customs is reported to require officers to check BIS registration for every consignment of CRS goods, with random sampling, limited non-destructive safety tests at BIS-recognised labs, and out of charge only after a pass^[45]. DGFT is reported to make BIS registration a condition of import for CRS goods^[46]. CPCB asked Customs in June 2025 to verify plastic EPR registration for importers^[47].

File the Bill of Entry by the end of the day before the vessel arrives^[48]; late charges are Rs 5,000 a day for the first three days^[49]. The basic documents are the bill of lading, the commercial invoice cum packing list and the Bill of Entry^[50]. If you ship by sea, note that Nhava Sheva handles around 50% of containerised cargo at India's major ports^[51]. See the customs clearance checklist, out of charge and demurrage.

For one bulb series from a Chinese factory, the official fees are about Rs 27,000 on the factory's side in year one and Rs 26,000 in each later year, and on your side about Rs 3.3 lakh in the first year, of which Rs 3 lakh is a refundable BEE deposit.

The example: an Indian brand with turnover under Rs 5 crore imports one 9 W LED bulb model (one series) in plastic clamshells, sells 50,000 units in year one, and is not a small-scale industry for BEE. GST is extra on BIS fees^[52].

It leaves out BIS and BEE lab charges, e-waste EPR certificate purchases, consultant fees, customs duty, freight and the cost of moving to the 2026 edition of IS 16102.

Lab charges vary by lab, so get quotes from BIS-recognised labs and BEE-recognised labs. E-waste certificates are bought from registered recyclers^[9]; CEEW environmental compensation is Rs 74 per kg with a floor certificate price of Rs 22^[54], which gives a sense of the market band. A small-scale BEE registrant pays a Rs 50,000 deposit instead of Rs 3 lakh^[4]. We have not verified the basic customs duty on 85395200 in the official tariff, so ask your broker.

Try your own numbers in the compliance cost estimator or the BIS CRS fee calculator, and see EPR registration costs.

The usual failures are a registration that does not cover your wattage or brand, a report still on the 2012 standard, and BEE ratings that do not match the factory's claims.

We found no anti-dumping duty on LED lamps from China in our search of CBIC and DGTR notifications up to 1 November 2026; confirm with your broker before pricing.

Anti-dumping duty in India is imposed product by product, by a Finance Ministry notification after DGTR findings, and normally lasts five years^[57]. India has no FTA with China^[58], so no preferential duty is available on Chinese bulbs. If you compare suppliers in other countries, our Vietnam and Thailand guides cover how ASEAN origin claims work.

1. Indian private label made in China. The factory applies for CRS in your brand^[25] with you as AIR^[35]. You register with BEE, pay the deposit and register the model^[4], then add e-waste, plastic EPR and LMPC. This is the most common set-up for D2C brands.

2. Distributor of a Chinese brand. The factory's existing registration may already cover the brand. BEE requires each brand to be registered separately^[38], so agree who holds the BEE permission: if the Chinese brand holds it, it must ask BEE to whitelist its IP^[38]. See distributors.

3. Smart Wi-Fi bulbs for marketplaces. Add a WPC ETA per model^[16], which is a self-declaration with an RF test report, a manufacturer authorisation and technical literature^[17]. Marketplaces will want all of it; see before listing on Amazon and smart plugs for a similar product.

Customs can hold, return or destroy them; BIS can prosecute; BEE can forfeit your deposit; and Legal Metrology and CPCB can penalise you separately.

• BIS. Up to two years in prison or a fine of at least Rs 2 lakh for a first offence, extendable to ten times the value of the goods^[37].
• BEE. If a label non-compliance is not explained within 30 days of a show-cause notice, BEE forfeits the security deposit and suspends the model registration for a year^[4].
• E-waste. Environmental compensation can be levied even on unregistered producers^[9], and non-target violations start at Rs 20,000 for a first default^[54].
• Legal Metrology. Improvement notice, then up to Rs 5 lakh, then Rs 25 lakh to Rs 50 lakh^[59].

Read selling without BIS, run the approval checker or ask us for a free compliance check.