Importing air conditioners into India in 2026: the DGFT prohibition, BIS ISI mark, BEE star label and EPR

Air conditioners are one of the most tightly controlled appliances in India. Work through these in order:

1. Import policy first. India's notification to the WTO lists the import of air conditioners with refrigerants under ex84151010 and ex84151090 as prohibited, a change made by DGFT Notification 41/2015-2020 of 15 October 2020^[1]. We could not open the DGFT text itself, so treat this as reported, but plan as if a pre-charged split or window AC cannot be imported as a finished product.
2. BIS ISI licence. Room ACs must carry the BIS Standard Mark under Scheme-I: IS 1391 (Part 1) for window (unitary) units and IS 1391 (Part 2) for split units^[3]. The QCO has applied since 1 October 2023^[4].
3. BEE star label. Room ACs are on BEE's mandatory list^[5]. You need company registration, a label security deposit and model registration before you print a label^[5].
4. E-waste EPR. ACs (other than central plants) are Schedule I item CEEW4^[8], and an importer who sells them is a producer^[9].
5. Plastic packaging EPR^[10] and LMPC importer registration^[11].

Two items depend on the model: a WPC ETA if the AC has Wi-Fi or Bluetooth control, and the BIS position on any compressor or heat exchanger you import separately as spares.

The table below is for a split or window room AC sold to consumers. Fees are government fees only; testing and consultant fees are extra.

Split and window ACs are declared under 84151010, "window or wall types, self-contained or split system", and other room ACs under 84151090^[2]. These are the same two lines that the October 2020 import prohibition targets for units with refrigerant^[1]. Confirm the 8-digit line with your customs broker before you file a Bill of Entry.

The BIS order splits the product family differently from the tariff:

The approvals are the same for every room AC, but the Indian Standard, the BEE star table and the label fee change with the type. Fixed-speed and variable-speed (inverter) room ACs pay the same Rs 30 BEE label fee, and so do cassette, floor-standing, ceiling and corner units^[6]. Window and split units sit under different parts of IS 1391^[3], and BIS needs a separate application for each product standard and each factory^[12], so a range that mixes window and split models needs two licences.

Two borderline cases trip up importers. Light commercial ACs are a separate BEE category at Rs 95 a unit, and chillers are charged per kW^[6]. A Wi-Fi or app-controlled AC adds a WPC ETA for the radio module^[18]. The IS 302 safety standard for heat pumps, air conditioners and dehumidifiers is also changing: BIS moved the end of concurrent running of the old and new editions to 23 February 2027^[22]. Check the BEE products list for any type not in the table.

This is the first question to settle, because it can make every other approval irrelevant.

• DGFT Notification 41/2015-2020, dated 15 October 2020, moved air conditioners with refrigerants under ITC(HS) 84151010 and 84151090 from "Free" to "Prohibited". India's quantitative-restrictions notification to the WTO lists the measure as in force, citing the Foreign Trade Policy 2023 as its legal basis^[1].
• We could not open the DGFT notification PDF, so this page treats the prohibition as reported, not verified. Check the current ITC(HS) Schedule I on the DGFT portal for your exact line before you place an order.
• The wording targets ACs "with refrigerants". We have not seen an official ruling on whether an AC shipped without refrigerant, or in knocked-down form, falls outside it. Do not rely on that route without a written opinion from DGFT or your customs broker.

In practice, brands that sell ACs in India manufacture or assemble them here and import parts. The QCO relaxations on compressors and heat exchangers below are written for exactly those manufacturers.

This order assumes the import policy question is settled and the product will be sold under your brand.

Plan on six to eight months for a first foreign-factory licence, because the BIS FMCS step decides the date and everything else runs alongside it. Do not book a commercial shipment until the licence is granted: goods that arrive first cannot be cleared for sale. Use the QCO deadline checker to see which dates apply to your enterprise size.

ACs are under Scheme-I (the ISI mark), not CRS. The Air Conditioner and its related Parts, Hermetic Compressor and Temperature Sensing Controls (Quality Control) Order, 2019 was notified as S.O. 4354(E) on 5 December 2019^[3]. Its start date was pushed four times, to 1 January 2021, 1 January 2022, 1 January 2023 and finally 1 October 2023^[4]. DPIIT's Transition Facilitation Order also records 1 October 2023 as the implementation date^[28].

What it means for an importer. Section 17 of the BIS Act bars importing, selling or storing notified goods without the Standard Mark under a valid licence^[29], and "person" includes importers^[29]. The licence is held by the manufacturer for each factory and each Indian Standard^[12].

For a foreign factory (FMCS): BIS records the application, inspects the factory and tests samples independently^[13]. BIS gives about six months as the average grant time^[13]. FMCS fees match domestic Scheme-I fees, plus BIS officers' travel, Rs 7,000 per man-day for visits and a Rs 10,000 contingency payment^[30].

Compressors and heat exchangers. These parts are in the same order. Two 2026 amendments matter to AC makers:

• Up to 31 March 2027, AC and refrigeration makers may import hermetic compressors for their own production outside the QCO, capped at a share of their FY 2024-25 imports. The cap is 30% for rotary compressors under 2 TR used in ACs and 100% for rotary compressors of 2 TR and above for VRF systems^[21].
• S.O. 5438(E), published on 5 October 2026, exempts up to 6,000 compressors and heat exchangers a year for three years when imported or made for maintenance and sales by a certified (or applicant) manufacturer. It also allowed declared old stock to be sold until 30 September 2026^[20].

Transition route for Indian companies. The Transition Facilitation Order lets DPIIT permit an Indian company, after a risk assessment, to source goods under the AC QCO through BIS Scheme-II licences^[28]. Applications are accepted for 24 months^[28]. It is a permission for specific companies, not a general exemption.

The minimum marking fee for IS 1391 is Rs 6,01,000 a year for a large enterprise, the biggest single fee in an AC licence^[31]. It is far above the application fee of Rs 1,000 and the Rs 1,000 annual licence fee^[12].

The unit rate is Rs 1 per kW of cooling capacity^[31]. A 1.5 ton AC is about 5.28 kW, using BEE's conversion of 3,517 watts per ton^[6], so it carries roughly Rs 5 of unit-rate fee. A BIS grant letter reportedly says the higher of the actual fee (unit rate times production) and the minimum is payable^[32]. At Rs 5 a unit, you would need to mark more than 1,10,000 ACs of that size before the unit rate overtakes the minimum, so most importers simply pay the minimum.

Indian MSMEs get concessions on the minimum until 31 May 2029: 80% for micro and 50% for small enterprises^[33]. These follow the MSMED Act definitions^[34], so a foreign factory should budget at the large rate. The full fee rules are on BIS ISI mark fees and the ISI licence cost guide.

Room ACs (fixed speed, variable speed and cassette, floor-standing, ceiling and corner types) are mandatory under Schedule A of the BEE (Appliance Labeling and Compliance) Regulations, 2026^[5], which took effect on 1 January 2026^[5]. No BEE label may be applied without BEE's written permission^[5].

Current star tables. BEE revised the AC energy standards through S.O. 2794(E) (16 July 2024) and S.O. 3984(E) (28 August 2025)^[35]. Every label under the old standard expired on 31 December 2025. The new tables run from 1 January 2026 to 31 December 2027 for split ACs and to 31 December 2029 for window (unitary) ACs^[7]. Existing models could be moved to the new table, usually at a lower star level, by applying before 28 December 2025^[36].

Fees.

• Company registration: Rs 5,000 one-time^[5].
• Label security deposit: Rs 3 lakh per appliance category (Rs 50,000 for small-scale industry), refundable^[5].
• Model registration: Rs 5,000 per model^[5].
• Label fee: Rs 30 per room AC; light commercial ACs are Rs 95^[6]. Pay it quarterly with a production statement^[5].

The label. It must show the brand, model, energy performance figure, label series, rated capacity, star level and country of origin^[5]. A QR code is required, and the label must appear at online and offline points of sale^[5]. On AC labels, cooling capacity in tons uses 1 TR = 3517 W, rounded to two decimals^[6]. The revised label design applies from 1 July 2026^[37].

Validity. Permission is granted for three years per model and is renewed free when the star plan is revised^[5]. Watch the table end date: a split AC approved in 2026 still needs a new label when the table changes after 31 December 2027.

Yes. Schedule I of the E-Waste (Management) Rules, 2022 lists "Air-Conditioners excluding centralised air conditioning plants" as CEEW4^[8]. An importer who offers imported EEE for sale is a producer^[8] and must register on the CPCB portal before trading^[8].

• Registration fee depends on your annual recycling target; it is Rs 10,000 for a producer whose sales have just started^[15]. The annual maintenance charge is Rs 5,000^[15].
• New entrants with a short sales history get Schedule IV targets based on earlier-year sales^[8].
• You meet targets only by buying EPR certificates from registered recyclers^[8].
• A shortfall costs environmental compensation; for CEEW items the rate is Rs 74 per kg^[38]. ACs are heavy, so this adds up quickly.

Refrigerant rules. The 2023 Second Amendment added safe refrigerant management duties for manufacturers and refurbishers of refrigeration and AC equipment^[39]. New EEE must also meet the RoHS limits^[8].

Plastic EPR. An importer of goods in plastic packaging is an obligated "importer" under the plastic EPR guidelines^[10]. AC packing (film, foam, bags) falls into the guideline categories^[25]. CPCB has asked Customs to check plastic EPR registration at clearance^[40].

LMPC. Anyone who imports pre-packaged goods for sale must register under rule 27^[11], for a Rs 500 fee^[11]. The box must carry the importer's name and address, country of origin, net quantity, month and year of manufacture, MRP and consumer-care details^[41][11].

Only when it has a radio. A Wi-Fi or Bluetooth module puts the AC in WPC's scope as a device operating in a de-licensed band^[18]. Low-power 2.4 GHz equipment is reported to be licence-exempt under the 2005 rules^[42]. ETA is by self-declaration on Saral Sanchar^[19] for Rs 10,000 per model^[18], backed by an RF test report^[18]. If the Wi-Fi module was already ETA-approved as a separate product, check with WPC whether the finished AC needs its own ETA. A plain remote-control AC (infrared remote) does not, on our reading.

Three sets of markings go on an AC sold in India:

• BIS Standard Mark with the licence number, applied only to goods made under the licence^[29].
• BEE star label on the front of each unit, with QR code, also allowed on the box^[6][5].
• LMPC declarations on the retail package^[41]. A reduced-price sticker may not cover the original MRP^[11].

Plastic packaging must also show the name and registration number of the producer or brand owner^[43].

Check the unit and the carton against this list before the factory prints them, because relabelling at an Indian port or warehouse costs more than reprinting at source. The detail behind each line is on LMPC label rules, the product label checklist and BEE star label. Paste your draft into the label checker for a quick first pass.

Example: a brand importing one split AC model, made in a foreign factory, with no Wi-Fi. Government fees only, where published. BIS marking fees for IS 1391 are set in BIS's marking fee notification and change often^[45], so they are not totalled here.

Three split models from one factory cost about Rs 1.3 lakh more in government fees than one, because the BIS minimum marking fee is charged per licence, not per model. The example assumes a large foreign factory, 1.0, 1.5 and 2.0 ton split inverter models under one IS 1391 (Part 2) licence, 2,000 units per model, one two-day factory visit by one officer, and all models in the first application. Testing, consultants, officers' travel and GST are extra.

Add a window model and the picture changes: it needs its own IS 1391 (Part 1) application^[12] and so a second minimum marking fee of Rs 6,01,000^[31]. Models added after grant cost Rs 5,000 per variety^[30]. Run your own numbers in the compliance cost estimator or compare fees on the BEE fees page and FMCS fees page.

1. A trader wants to import finished split ACs from a factory abroad. The first problem is the reported prohibition on ACs with refrigerant^[1]. Even if that were cleared, the factory would need a BIS licence^[3] and the trader would need BEE registration^[5]. Most traders stop at step one.

2. An Indian AC maker imports compressors. Compressors are under the same QCO^[3]. Until 31 March 2027 the maker can import part of its compressor needs outside the QCO for its own production, capped at a share of FY 2024-25 imports, and must keep monthly records and file an indigenisation plan^[21]. Spares for after-sales service have a separate 6,000-unit yearly allowance^[20].

3. A foreign brand sells Indian-made ACs under its own name. The Indian factory holds the BIS licence. The brand registers with BEE (each brand is registered separately)^[24], pays the label fee^[6] and registers for e-waste EPR as a producer selling under its own brand^[8].

Each approval sits with a different party, and the importer of record carries more than most people expect. For ACs the split matters more than usual, because the finished unit, the compressor and the heat exchanger can each fall under a different licence holder. Use the table to split the work before the first order, and write it into your supply contract. If one company plays several roles, it carries every row it plays. For the documents each party signs, see BIS ISI documents and the customs clearance checklist.

Most AC delays come from a mismatch between the model shipped and the model approved, not from the regulators. The table lists the failures we see most often in published rules, with the fix for each. Check BIS ISI renewal for licence lapses and the BEE star label portal guide for label issues.

• BIS: contravening section 17 can mean up to two years' imprisonment or a fine of at least Rs 2 lakh (Rs 5 lakh for repeat offences), up to ten times the value of the goods^[29].
• BEE: an unexplained label breach leads to forfeiture of the Rs 3 lakh deposit, a one-year suspension of model registration and penalty proceedings^[5]. Under the Energy Conservation Act the penalty can reach Rs 10 lakh plus Rs 2,000 to Rs 5,000 per non-compliant appliance^[51]. Online listings can be taken down^[5].
• E-waste: missing targets costs environmental compensation per kg^[38].
• LMPC: non-conforming packages bring an improvement notice, then penalties up to Rs 5 lakh^[48].

Enforcement now runs through warehouse searches, online test purchases and public lists of failed licences, not only port checks. For ACs, BEE check testing is the risk most brands meet first, because the star table is tight and samples can be bought from any shop or website. We found no published case that names air conditioners specifically other than those in the table; most reported actions are about appliances in general. For what a search or seizure means for a seller, read what happens if you sell without BIS, and use how to verify a BIS licence before you buy stock from a distributor.

The AC rules changed four times in 2026, mostly to ease parts imports, and two deadlines fall in 2027. The big umbrella order for household appliances that came into force on 1 October 2026^[57] does not change anything for room ACs, because it excludes goods already under another QCO^[57]; ACs stay under the AC QCO. Follow later changes on the QCO tracker, the new rules 2026 ledger and the electrical appliances QCO page.

Start with the free tools, then bring in a consultant or lab only for the steps you cannot run yourself.

• Approval checker: confirms which of BIS, BEE, EPR, LMPC and WPC apply to your exact air conditioner.
• Compliance cost estimator: rebuilds the worked example above with your model count and volumes.
• QCO deadline checker: shows the date that applies to your enterprise size.
• Label checker: checks the carton text against LMPC and BIS marking rules.
• Licence renewal date tool: works out when to renew each licence.
• BIS consultants and BIS-recognised labs: directories by city.
• Importing from China: factory-side issues for the most common source country.
• Importing from Thailand and from South Korea: two large AC source countries with FMCS licence holders already on BIS records.

If you want a second opinion on your file, ask for a free compliance check. We do not promise approval or speed; we tell you what is missing.