Importing LED bulbs into India: BIS, BEE star label and EPR requirements for 2026

LED bulbs need both a BIS safety registration and a BEE energy label. For a standard self-ballasted LED bulb you need:

1. BIS CRS registration, held by the factory. Self-ballasted LED lamps are a CRS category under IS 16102 (Part 1); the portal lists both the 2012 and the 2026 editions^[1].
2. A BEE star label. Self-ballasted LED lamps are on BEE's mandatory Star Labelling list^[4].
3. E-waste EPR. LED lamps fall under the Schedule I lighting entry, code CEEW18, on our reading of the rules^[9].
4. Plastic packaging EPR^[10].
5. LMPC importer registration^[11] and, on our reading, package declarations^[12].

Two depend on the product. On our reading, smart bulbs with Wi-Fi or Bluetooth need a WPC ETA and ordinary bulbs do not^[13], and rechargeable or emergency bulbs contain a battery and bring battery EPR^[14].

Not required, on our reading: MTCTE^[15].

Official government fees only; lab, AIR and consultant charges are not government fees.

LED bulbs are usually classified under ITC(HS) 85395200, "Light-emitting diode (LED) light sources: LED lamps"^[3]. The line itself is official; whether your product is a "lamp" or something else is for you and your broker to settle. Confirm the code with your customs broker before filing.

The bigger trap is the BIS category. Only self-ballasted lamps (a bulb with its driver built in) fall under IS 16102. Other LED lighting has its own CRS entries:

The LED lamp line is 85395200; the lines next to it carry different BIS categories, so a wrong code points Customs at the wrong approval. Use the table to check that the code on your Bill of Entry and the CRS category on your licence describe the same product, then test it in the HS code approval finder.

A plain mains LED bulb needs BIS CRS, the BEE label, e-waste EPR, plastic EPR and LMPC; radios, batteries and higher wattages add or shift approvals. The matrix below shows what each common variant adds. Where a cell says "likely", it is our reading of the rules, not an official ruling.

Two changes in the 2026 edition of IS 16102 (Part 1) matter here: it covers lamps up to 60 W rated input and lamps with non-removable rechargeable batteries, and it adds tests for abnormal operation and ingress protection^[30]. A high-wattage or rechargeable bulb that sat awkwardly in the 2012 edition now has a clear test route. Check your exact variant in the approval checker.

In this order. If one lab is recognised by both BIS and BEE, ask whether it can plan both tests together.

Tools and help. The approval checker lists the approvals for your exact variant, and the label checker tests your artwork. Before your first container, work through the first electronics import checklist, and see how to verify a BIS licence before you pay a supplier. If you want help with BIS filing or the AIR role, our BIS consultants guide explains what consultants charge and how to choose one, and the BIS labs directory lists recognised labs by city. For a free compliance check of your bulb range, contact us.

Standard and dates. Self-ballasted LED lamps for general lighting have been on the CRS list since 13 September 2015 under IS 16102 (Part 1):2012^[27]. A revised IS 16102 (Part 1):2026 has been introduced, and the portal lists both editions^[1]. BIS has extended the last date for implementing the revised standard to 2 February 2027^[2]. If you are testing now, ask your lab whether it can test to the 2026 edition, so you are not retesting a few months after grant.

LED bulbs are not part of the move to IS/IEC 62368-1:2023, which replaced IS 13252 (Part 1) and IS 616 for IT and audio-video products^[36]. LED lighting has its own standards.

Who applies. The manufacturer, per factory; not the importer^[16]. A foreign factory nominates an AIR^[17].

Brands and wattages. A separate application is needed per brand unless the brand owner is the same^[17]. Which wattages share a test report is decided under MeitY's series guidelines^[17]. Each extra report costs Rs 20,000^[8].

Timeline and validity. BIS targets 20 working days from a complete application^[17]. Licences now run five years and renew for five, with fees paid each year in advance^[18]. See BIS CRS and CRS renewal.

The revised IS 16102 (Part 1):2026 replaces the 2012 edition, and BIS has extended the last date for implementing it to 2 February 2027^[2]. After that date, plan on every licensed bulb model being covered by a 2026 test report.

What the standard is. IS 16102 (Part 1):2026 is the first revision of the safety standard for self-ballasted LED lamps, supersedes the 2012 edition and is kept by BIS committee ETD 23^[37]. The companion performance standard, IS 16102 (Part 2):2026, supersedes the 2017 edition^[38]. Read our IS 16102 (Part 1) guide for the clause-level detail.

What is new in testing. Lamps up to 60 W, photobiological safety tests and marking, lamps with non-removable rechargeable batteries, abnormal-operation and ingress-protection tests, marking for lamps not suitable for water contact, an axial strength test for Edison caps and modified fault-condition tests^[30].

How the deadline moved. BIS's guidelines of 24 February 2026 first set 2 August 2026 as the last date of concurrent running, with existing licensees asked to submit complete test reports for lead models plus an undertaking for series models^[30]. That date was then extended to 2 February 2027^[2]. The same 2 February 2027 date applies to seven LED luminaire categories moving to the 2026 IS 10322 (Part 5) sections^[39], so a lighting brand with both bulbs and battens faces one deadline for both. All dated changes are tracked on new rules for 2026.

What it means for a new application today. Lab capacity is the bottleneck. On 1 November 2026 BIS LIMS listed only 25 labs for the 2026 edition against 52 entries still for 2012^[31]. Test new models to the 2026 edition now, so you do not pay for a 2012 report that has to be redone within months.

Series. BIS's revised series table allows up to 20 models in one series for several LED lighting categories^[40], so a family of wattages can often share a lead-model report. Your lab applies the series guidelines to decide which wattage is tested.

Declared lab charges for IS 16102 (Part 1):2026 run from Rs 17,000 to Rs 1,25,000, with a median of about Rs 51,000, excluding taxes^[31]. These are the figures labs publish on BIS LIMS, which BIS's own FAQ names as the place to find recognised labs by IS number^[41].

A single lab's breakup shows what you pay for. Intertek India in New Delhi declares Rs 40,000 for the 2026 edition, with lines for marking, cap interchangeability, bending moment, accidental contact with live parts, insulation and electric strength, torsion, axial strength of Edison caps, cap temperature rise, heat and flame, fault conditions, creepage, abnormal operation, dimmable lamps, ingress protection and broken lamps^[31].

The BEE energy-performance test is a separate job at a BEE-recognised lab^[34]. We found no published BEE test charge, so get it quoted. Our BIS labs directory and CRS test labs guide explain how to pick a lab, and how to read a BIS test report shows what to check before you upload it.

It is mandatory. BEE's Star Label portal lists LED lamps as a mandatory appliance^[42], and self-ballasted LED lamps are in Schedule A of the BEE (Appliance Labeling and Compliance) Regulations, 2026, which came into force on 1 January 2026^[5]. No BEE label may be put on the product without BEE's prior written permission^[5].

Registration and fees:

• Company. Every company that manufactures, sells or imports a mandatory appliance must register with BEE, with a one-time fee of Rs 5,000^[5].
• Appliance category and deposit. Each appliance category is registered separately with a refundable, interest-free label security deposit of Rs 3 lakh, or Rs 50,000 for small-scale industry^[5].
• Models. Each model is registered separately for Rs 5,000 per application^[5]. Each brand is registered separately, and testing must be at BEE-recognised labs^[34].
• Label fee. Rs 10 per 100 LED lamps^[5], paid quarterly within 30 days of the quarter end with a production statement, plus a CA-certified annual reconciliation; prepaid label fees at QR code requisition are due to apply from 1 April 2027 if BEE's portal supports them^[5].

Timeline and validity. BEE must finish scrutiny within 30 working days; you get up to 60 days to fix discrepancies^[5]. Permission to label a model lasts three years^[5].

The 2027 star table. BEE has issued an advisory upgrading the LED lamp star rating table from 1 January 2027^[6]. We have seen only the title, not the new thresholds. A model rated today may drop a star or need retesting, so check before you print labels for stock that will sell after January 2027. The reference standard for the LED lamp label is IS 16102 (Parts 1 and 2)^[4].

Ongoing duties. Give BEE an updated list of authorised sellers by 30 April each year^[5]. BEE check-tests models, and on a final failure can order stock withdrawn^[5].

Foreign manufacturers registering directly should note that the BEE portal is reachable from Indian IP addresses only, unless BEE whitelists yours on request^[34].

Yes. Schedule I lists "Other lighting or equipment for spreading or controlling light, excluding filament bulbs" under EEE code CEEW18^[7], and LED lamps fall under that entry on our reading^[9]. One caveat: LED "filament" style bulbs might be argued to fall under the filament-bulb exclusion. That argument has not been tested in any source we found, so do not rely on it.

Who registers. Anyone who offers to sell imported EEE is a producer^[7], and no producer may do business without registering on the CPCB portal^[7], the E-Waste Management System at eprewaste.cpcb.gov.in^[43].

What you file. Sales placed on the market by year and weight, a RoHS self-declaration and an awareness plan^[21].

Fees. Rs 10,000 for producers whose sales have just started; otherwise by target, from Rs 2,500 under 50 tonnes^[21]. Annual maintenance is Rs 5,000^[21]. Registration lasts five years^[21].

Targets. Producers with a full sales history face Schedule III targets of 70% for 2026-27, rising to 80% from 2027-28^[7]. New producers start on Schedule IV: 20% of sales from two years earlier^[7]. You meet targets only by buying EPR certificates from registered recyclers^[7].

What a shortfall costs. For the CEEW category, environmental compensation is Rs 74 per kg, and the floor certificate price is Rs 22 per kg^[44].

Returns are due quarterly and annually, by the end of the month after the period^[7]. See e-waste EPR and EPR returns.

Smart bulbs likely need a WPC ETA. On our reading of the ETA rules, ordinary LED bulbs have no radio and need no ETA, while smart bulbs with Wi-Fi or Bluetooth do^[13]. The ETA is a self-declaration on Saral Sanchar^[20], at Rs 10,000 per model^[19]. DoT is moving authorisations to the Telecommunications Act, 2023 portal^[45], and whether the ETA self-declaration route will change is not yet confirmed^[46].

Rechargeable and emergency bulbs likely need battery EPR. A standard bulb has no battery; a rechargeable or emergency LED bulb does, which on our reading brings it under the battery rules^[14], and importing equipment that contains batteries makes you a producer under the battery rules^[23]. Register with CPCB before importing^[32]; the fee is Rs 10,000 for turnover under Rs 5 crore^[22]. The battery must carry the crossed-out wheeled bin symbol^[47] and your EPR number^[48]. See battery EPR.

MTCTE does not appear to apply to bulbs of either kind: they are not in TEC's notified list of 1 July 2024, the latest full list we checked^[15].

Yes. An importer of LED bulbs sold in plastic packaging counts as an importer under the Guidelines on EPR for Plastic Packaging and needs plastic EPR registration^[10]. The micro and small enterprise carve-out in the list of obligated entities applies to producers and brand owners, not to importers^[35].

• Registration. On CPCB's centralised EPR portal^[35]; your State Pollution Control Board handles it if you operate in one or two states, CPCB if more^[24].
• Fee. Rs 10,000 if you generate under 1,000 tonnes of plastic waste a year^[25], plus 25% of that each year when you file the annual return^[25].
• Validity. One year for a fresh registration and three for a renewal, under CPCB's March 2022 SOP^[25].
• Obligation. Your eligible quantity is based on the average plastic packaging you imported and sold over the last two years, by category^[24], and the target has been 100% of it since 2023-24^[24]. The annual return, with certificate details, is due by 30 June^[35].

See plastic EPR for categories and the portal process.

Yes, if you import LED bulbs packed for retail sale. Rule 27 of the Legal Metrology (Packaged Commodities) Rules, 2011 requires every person who pre-packs or imports any commodity for sale, distribution or delivery to register its name and address^[11]. Our reading that this covers LED bulbs in retail packs rests on the Delhi Legal Metrology importer form; we could not open the full rules text^[12]. Packages for industrial or institutional consumers are exempt from the retail-package provisions^[49].

• Where and how much. Apply to the State Controller or the Director of Legal Metrology^[11] with a Rs 500 fee^[11], within 90 days of starting to import^[11].
• What you state. Name, complete address of the premises and the commodities imported^[11]; since 29 May 2026 a company must also name the director responsible for violations^[26].
• Validity. The certificate stays valid until cancelled^[26], but details must be updated every year on the online portal^[26].

LMPC registration does not approve the product. It records you as the importer named on the pack and makes you answerable for the declarations printed there.

BIS Standard Mark. Mark the product, the package or both, legibly and indelibly^[50], with the R-number and IS number^[50] in letters at least Arial size 6^[50], and www.bis.gov.in^[51]. Model, batch, manufacture date and manufacturer's address go on the product, pack or a label^[50]. See CRS labelling.

BEE star label. The label shows the appliance name, brand, model, energy performance, label series, rated capacity, star level, country of origin and the BEE logo^[5]. It must carry a QR code with the label particulars and appear on every registered unit, at both online and offline points of sale^[5].

Plastic EPR marking. Rule 11 asks for your registration number on plastic packaging, though a proviso in the same clause exempts imported goods' packaging, so the text conflicts^[52]. A QR code is allowed^[53]. Print it to be safe.

Legal Metrology declarations. Every retail pack must declare the name and address of the manufacturer, packer or importer, country of origin, generic name, net quantity, month and year of manufacture, MRP, unit sale price and consumer care details^[49]. Declare the month and year of manufacture, not of import^[11]. For electronics, the date of manufacture can reportedly appear anywhere on the retail package if it is legible^[54]. Stickers may not alter the declarations, except a reduced-MRP sticker that leaves the original visible^[11]. If the factory cannot print Indian declarations, they may be applied in an AEO Tier-2 or Tier-3 bonded warehouse before the goods leave it^[26].

Tick every line below before you sign off the bulb and carton artwork; most LED bulb holds trace back to one of them. Paste your draft text into the label checker, and see the full product label checklist and Legal Metrology label rules.

The factory holds the BIS licence, the brand owner or importer holds BEE and EPR, and anyone who sells is liable if the goods are not compliant. Each party can be a different company, which is where gaps open. BIS registration is issued to the manufacturer, not the importer^[16], while BEE registration expressly covers companies that import a mandatory appliance^[5]. Section 17 of the BIS Act bars importing, selling, storing or displaying uncertified notified goods^[55], so a seller cannot point at the factory. See our guides for Amazon sellers and foreign manufacturers.

One standard LED bulb model, one brand, a new importer selling 10,000 bulbs in the first year, not a small-scale unit, under 1,000 tonnes of plastic a year. Official fees only. The totals and the label-fee line are our arithmetic, not official figures.

• Lab testing for IS 16102 and BEE energy performance, and any AIR or consultant fees, are not government fees.
• Smart or rechargeable models add Rs 10,000 per model for the ETA^[19] or Rs 10,000 for battery EPR registration^[22].
• E-waste certificates. Your target is met by buying certificates, which for the CEEW category cannot trade below Rs 22 per kg under CPCB's guidelines, though a court challenge to the floor is reported^[44]; the actual price is set by the market.
• The 2026 BIS fee change. A consultant reports the CRS processing fee is now Rs 25,000 a year^[58]; BIS's published table is still the 2018 one.
• The deposit is refundable only on permanently ceasing manufacture^[5].

See CRS cost and EPR cost.

Three bulb models that each need their own BIS test report cost about Rs 2.9 lakh in fees and median lab charges, against about Rs 1.4 lakh for one model, before the refundable BEE deposit. The assumptions: one brand, a new importer, each wattage tested as its own lead model to the 2026 edition at the LIMS median, no smart or battery features. All totals and per-model lab figures are our arithmetic. If the three wattages fall in one series, you pay one test report and one BIS processing fee, which narrows the gap a lot. Run your own numbers in the compliance cost estimator or the BIS CRS fee calculator.

The official clocks add up to a few weeks once your test report is ready; lab time and your own paperwork decide the rest. The table lists every official limit. Lab turnaround is set by the lab and is not published, so ask for it in writing. Our how long BIS registration takes explains where the time usually goes.

1. First-time importer, private label. The factory needs a CRS application in your brand^[17], and you need your own BEE company, category and model registrations, with each brand registered separately^[34]. Budget for the Rs 3 lakh BEE deposit^[5]. Register for e-waste EPR before selling, since unregistered producers can face environmental compensation^[7].

2. Marketplace seller. The BEE label must appear at online points of sale too^[5], and where BEE finds non-compliance online it directs the platform to de-register the model^[5]. Check that your supplier's model holds a current BEE permission and a CRS R-number before listing. Marketplaces must reportedly show the Legal Metrology declarations^[57].

3. Foreign brand. Appoint an AIR for BIS who is an Indian resident^[60]. For BEE, the regulations expressly cover importers of mandatory appliances^[5], so your Indian importer can register; if you register directly from abroad, ask BEE to whitelist your IP addresses^[34].

Most holds come from a label or registration that does not match the model.

Three checks run after you start selling: MeitY's market surveillance of CRS licences, Customs checks at the port and BEE's check testing of star ratings. Each can cost you money even when the paperwork is right.

MeitY market surveillance. STPI runs CRS surveillance for MeitY through the portal crsbis.stpi.in, where manufacturers, AIRs and brands must register every R-number with model details^[63]. STPI buys samples from the open market or from e-commerce sites such as Amazon and Flipkart^[64]. The listed maximum surveillance test charge for self-ballasted LED lamps is Rs 45,500^[65], or the lab's declared charge if lower^[65]. You must pay within 15 working days of the demand, or the case goes to BIS for deferment or cancellation^[66]. Our CRS surveillance guide covers the full process.

Customs. A CBIC instruction reportedly directs officers to check BIS registration for every consignment under the electronics CRS order, with random sampling for non-destructive safety tests^[67]. CPCB has also asked Customs to verify plastic EPR registration for importers^[62]. Keep the documents in our customs clearance checklist ready.

BEE check testing. If a first check test fails, BEE retests twice the quantity in two labs at your cost, and can order stock withdrawal on a final failure^[5].

Raids on warehouses. In FY 2024-25, BIS reportedly bought 344 samples of QCO products from e-commerce platforms, found 142 without valid certification and searched 22 e-commerce warehouses^[68]. The BIS Act lets officers search premises and seize goods^[69]. What follows a failed check is set out in selling without BIS.

The approvals are the same, but most of the volume comes from China, so factory checks matter more. India imported LED lamps worth US$ 13.17 million from China in 2025-26, out of US$ 18.58 million from all countries^[70]. Before you pay a deposit, search the factory's R-number, brand and IS number on the CRS register, which shows the date of grant, status, validity and brands^[71], or check it in the BIS Care app^[72].

Indian assembly is getting cheaper: the Union Budget 2026-27 extended the concessional duty on parts for LED lights and inputs for LED drivers to 31 March 2028^[73]. Our LED bulbs from China page has the China-specific budget and factory checks, and importing from China covers the wider process.

BIS. Importing or selling a notified product without a valid licence and Standard Mark breaches section 17 of the BIS Act^[55]. The penalty is up to two years in prison, or a fine of at least Rs 2 lakh (Rs 5 lakh for repeat offences) extendable to ten times the value of the goods, or both^[55]. Importers and sellers are "persons" under the Act^[55], and BIS can order a recall^[55].

Legal Metrology. Since the 2026 Jan Vishwas amendment, a pre-packaged commodity without the required declarations draws an improvement notice first, then a penalty of up to Rs 5 lakh, then a fine of Rs 25–50 lakh; online marketplaces are covered too^[74].

EPR. Plastic EPR shortfalls attract environmental compensation of Rs 2,900 to Rs 7,900 a tonne, multiplied for repeat defaults^[75]. The e-waste rules set the same Rs 20,000 / 40,000 / 80,000 scale for a producer's violations other than a shortfall^[44].

BEE. If a missing or counterfeit label is not explained within thirty days of a show-cause notice, BEE forfeits the security deposit and suspends the model registration for a year^[5].