What is an Authorised Indian Representative (AIR) under BIS?

BIS licences are granted to the factory that makes the product, not to the shop or importer that sells it. Under the Compulsory Registration Scheme, the applicant is the manufacturer, and the licence is granted per manufacturing unit^[10]. When that factory is outside India, BIS needs someone inside India it can hold to account. That person is the Authorised Indian Representative, usually shortened to AIR.

The AIR must be an Indian resident who consents to be responsible for compliance with the BIS Act, Rules, Regulations and licence terms on behalf of the foreign manufacturer^[4]. In short, the AIR is the foreign factory's legal face in India for BIS purposes.

There is no single statutory definition; the AIR role is built from BIS scheme documents and the BIS Act. BIS requires the AIR to be an Indian resident who consents to be responsible for compliance with the BIS Act, Rules, Regulations and licence terms on the foreign maker's behalf^[4].

The BIS Act backs this up. It defines 'person' to include manufacturers, importers, sellers and their representatives^[7]. Section 30 makes the authorised representative guilty along with the company when the company commits an offence^[7]. So the AIR is not just a contact address; it carries legal exposure under the Compulsory Registration Scheme.

Any foreign manufacturer applying for a BIS CRS licence must nominate an AIR using the nomination form, Form IV^[1]. The same idea applies to the Foreign Manufacturers Certification Scheme for ISI-marked goods: FMCS applicants also nominate an AIR using the prescribed nomination form^[11].

Indian importers are affected even though they do not hold the licence. An importer cannot hold a CRS licence for a factory it does not own^[10], but it can often act as the AIR. BIS allows three kinds of AIR for a foreign CRS applicant^[5]:

• the manufacturer's own liaison or branch office in India;
• the brand owner, or the registered user of the brand, in India;
• another Indian entity, in which case the brand owner must declare that it has no proprietor or registered user of the brand in India.

BIS accepts the foreign maker's own branch or liaison office in India, the Indian brand owner or registered user of the brand, or an unrelated Indian entity backed by a brand-owner declaration^[5].

The AIR is named inside the factory's CRS application on crsbis.in. Order matters, because the documents must match each other exactly.

The letter nominating the AIR is uploaded during a foreign factory's CRS application, along with Form I and a notarised affidavit^[9]. The AIR's details then sit on the licence, which is why changing the AIR later is a paid change^[6].

The role is not a formality. Under section 30 of the BIS Act, when a company commits an offence, every responsible officer and the authorised representative, as well as the company, are deemed guilty^[7]. BIS can also direct a licence holder or its representative to stop supply and recall non-conforming goods^[7]. Anyone agreeing to be an AIR should understand that exposure before signing.

The full CRS document list, including the AIR papers, is on BIS CRS documents.

The AIR answers BIS for the licence: it ensures compliance, appears when called, helps BIS draw market samples and avoids contact with labs about BIS samples. The FMCS rules spell this out^[3], and CRS practice follows the same idea.

• Residency: the AIR must be an Indian resident^[4].
• One firm only: an AIR may represent only one foreign manufacturing firm under BIS conformity assessment schemes. The exceptions are manufacturers in the same group of companies, or related importers nominated as AIR^[4].
• Form: the nomination is Form IV in the CRS form set^[2].
• Changing the AIR: BIS charges Rs 5,000 plus GST to change the AIR or contact person on a CRS licence^[6]. This sits in the same Rs 5,000 band as other changes such as name, address or management changes^[15].

We have found no separate government fee for the first nomination in BIS's published fee list. The full fee table is on BIS CRS fees.

Each regulator uses an Indian representative for foreign makers, but the paperwork and conditions differ.

The same as the company. Section 30 of the BIS Act deems the authorised representative guilty along with the company^[7]. Importing or selling notified goods without a valid licence and Standard Mark breaches section 17^[7]. That is punishable with up to two years' jail, or a fine of at least Rs 2 lakh for a first offence and Rs 5 lakh after, up to ten times the value of the goods^[7].

Some first offences can be compounded by an officer authorised by the BIS Director General^[7]. For what happens on the market side, see selling without BIS.

A Delhi company imports power banks under its own brand from one Shenzhen factory, and wants to add earphones from a second, unrelated factory.

1. Power bank factory. Power banks are a CRS category^[18]. The Delhi company owns the brand, so it can be the AIR as brand owner^[5].
2. Earphone factory. The one-firm rule stops the same company being AIR for a second, unrelated foreign maker. The exceptions are factories in the same group or a related importer nominated as AIR^[4]. Unless one applies, the earphone factory needs a different AIR.
3. Later change. If the brand moves distribution, changing the AIR on each licence costs Rs 5,000 plus GST^[6].
4. Cost of the main licence. Since 25 February 2026 the CRS processing fee is Rs 25,000 a year per application, paid in advance^[15], plus GST^[6]. Estimate yours with the BIS CRS fee calculator.

Many importers sourcing from China hit the one-firm rule at their second supplier, so plan AIR structure before signing new factories.

• One importer, many factories. A trading company that buys from several Chinese factories often wants to be the AIR for all of them. The one-firm rule blocks this unless the factories are in the same group or the importer is a related importer^[4].
• Wrong AIR category. If an unrelated Indian company is nominated while an Indian brand owner exists, the brand-owner declaration cannot honestly be given^[5].
• Switching importers. When a brand changes its Indian distributor, the licence still names the old AIR until a change request is filed and paid for^[6].
• Underestimating liability. The AIR can be treated as guilty of the company's offence^[7]. Agree in writing with the factory who handles tests, recalls and correspondence.

Five numbers cover most AIR questions.

• Compulsory Registration Scheme: the BIS scheme most AIRs work under.
• Standard Mark and R-number: what the licence lets the factory print.
• BIS-recognised laboratory: where CRS samples are tested.
• Essential requirements: the TEC standards an MTCTE AIR certifies against.

Foreign brands should also read compliance for foreign manufacturers. For help structuring AIRs across several factories, ask for a free compliance check.