Importing LED luminaires into India: BIS categories, the 2026 IS 10322 revision and other approvals

An LED luminaire is a complete light fitting: a panel, downlight, batten, street light, flood light or similar. India treats each type as a separate BIS category. To import them you need:

1. BIS CRS registration, held by the factory, for each luminaire type you import. Eight luminaire categories are on the CRS list, each under its own section of IS 10322 (Part 5)^[1].
2. Plastic packaging EPR for the packaging^[9].
3. E-waste EPR registration, on our reading under code CEEW18 for lighting equipment^[10].
4. LMPC importer registration and Legal Metrology declarations if you sell retail packs^[8].

The 2026 change. BIS has revised the luminaire standards. The old and new editions of IS 10322 (Part 5) can both be used only until 2 February 2027^[3]. Licences not moved to the 2026 standards by then stop being valid^[2].

Two more depend on the model. Battery EPR applies to emergency and solar luminaires with batteries^[11]. A WPC ETA applies to smart fittings with Wi-Fi, Bluetooth or Zigbee, as for smart bulbs^[12].

Not required: a BEE star label. LED luminaires are not on either BEE list; only LED lamps are^[6].

These are the luminaire categories on the CRS product list, with the standard and implementation date the portal gives. Each category needs its own registration.

Several related products have their own categories. If your shipment mixes them, each needs its own registration.

• LED bulbs and tubes with built-in drivers are self-ballasted LED lamps under IS 16102 (Part 1)^[1]. See LED bulbs.
• LED drivers sold separately are DC or AC supplied electronic controlgear for LED modules, under IS 15885 (Part 2/Sec 13)^[13]. See LED drivers.
• LED modules sold on their own are Independent LED Modules for General Lighting under IS 16103 (Part 1)^[1].
• Dimmers for LED products are a separate category under IS 60669-2-1^[1].
• Portable table and floor lamps have their own standard, IS 10322 (Part 5/Sec 4), revised in 2026^[14], but none of the eight luminaire categories above is for portable lamps. Ask BIS before treating them as exempt.

Fancy lights. BIS's 2026 guidelines list "Fancy Lights" alongside fixed general purpose LED luminaires^[2], so decorative ceiling and wall fittings belong in that category.

The BIS category decides the standard, and batteries, radios and solar panels decide the extra approvals. The matrix covers the borderline fittings importers ask about most. "Likely" marks our reading of the rules, not an official ruling. Check your exact product in the approval checker.

Luminaires are in heading 9405, not in Chapter 85 with LED bulbs. Since the 2022 HS changes, there are lines for fittings designed for use solely with LED sources: 94051100 for ceiling and wall fittings, 94052100 for table, desk and floor lamps, 94054100 for photovoltaic (solar) LED luminaires and 94054200 for other LED fittings such as flood lights and street lights^[15]. These descriptions come from a third-party tariff lookup, not an official ruling, so confirm with your broker.

LED bulbs, by contrast, are under 85395200^[23]. A shipment of fittings declared under the lamp heading, or the reverse, invites questions about which BIS licence applies.

Luminaires sit in heading 9405, split by type, while bulbs and drivers sit in Chapter 85. The 9405 descriptions come from a reported tariff lookup, not an official ruling^[15], so confirm with your broker and test the code in the HS code approval finder.

Tools and help. The approval checker maps your fittings to categories, and the first electronics import checklist covers IEC, broker and documents. Verify a BIS licence before paying a factory. For filing help, see our BIS consultants guide; for a free compliance check of your range, contact us.

On 20 March 2026 BIS issued guidelines moving seven luminaire categories to the 2026 editions of IS 10322 (Part 5). The trigger was the revision of the general standard, IS 10322 (Part 1):2014, as IS 10322 (Part 1):2026^[2]. See IS 10322 (Part 1).

Dates. The original last date of concurrent running was 2 August 2026^[2]. A BIS circular of 31 July 2026 extended it to 2 February 2027^[3].

What existing licensees must do^[2]:

• submit complete test reports from a BIS-recognised lab for every lead model previously tested to the old standard;
• give an undertaking that the series models also meet the revised standard;
• finish by the last date, or the licence stops being operative and BIS may cancel it or delete models.

New applicants can still file on the old standard until the last date, with a declaration that they will switch^[2].

Rope lights (Part 5/Sec 9) are not among the seven categories in the circular^[2].

Emergency luminaires get new requirements for lithium batteries and electric double layer capacitors^[2]. If you import emergency fittings, ask your factory whether its battery design passes the 2026 tests.

Retest every lead model to the 2026 IS 10322 (Part 5) section, give an undertaking for the series models and finish before 2 February 2027, or the licence stops being operative^[2][3]. The steps below put that in order. Changes in the 2026 Part 5 sections that most often catch importers: Sec 2 absorbs recessed-luminaire rules from Part 1 and adds air-handling luminaires and marking, Sec 5 adds a glass-breaking test, and Sec 8 updates battery, EDLC and exit-sign requirements^[2]. Our IS 10322 (Part 1) guide explains the general changes, and new rules for 2026 lists every dated change.

For the 2026 editions, median declared lab charges run from about Rs 55,000 (fixed, road, hand lamps, chains) to about Rs 85,000 (emergency), excluding taxes^[29]. Old-edition testing was cheaper, at a median of about Rs 40,000 for Sec 1:2012^[29], which is one more reason not to start a new application on the old edition.

Intertek India in New Delhi declares Rs 1,15,000 for IS 10322 (Part 5/Sec 1):2026, with its largest lines for endurance and thermal tests (Rs 30,000), construction (Rs 20,000), dust and moisture resistance (Rs 15,000) and heat, fire and tracking (Rs 12,000)^[29]. See our BIS labs directory and CRS test labs guide, and how to read a BIS test report before you upload one.

LED luminaires are under MeitY's Electronics and IT Goods (Requirements for Compulsory Registration) Order, 2021^[31], certified under BIS Scheme-II^[32]. No one may import, sell or store them for sale unless they meet the standard and carry the Standard Mark with a registration number^[33].

• Who applies: the manufacturer, for each factory^[33]. Separate applications are needed for each brand unless the brand owner is the same^[17].
• Foreign factories: nominate an AIR, who can be a branch office, the brand owner in India or another Indian entity^[34].
• Series: wattage and size variants are grouped under MeitY's series guidelines and added with supplementary reports^[17].
• New models later: add them by inclusion^[35], at Rs 30,000 including one test report^[4].
• Components. The LED driver inside a luminaire is a CRS product in its own right when sold separately^[13]; ask your lab whether the driver needs its own registration for the luminaire's critical component list.

E-waste EPR: yes, on our reading. Schedule I lists "Other lighting or equipment for the purpose of spreading or controlling light excluding filament bulbs" under CEEW18^[7]. CEEW15 covers only luminaires for fluorescent lamps, and not household ones^[10]. Mapping LED luminaires to CEEW18 is our inference; confirm on the CPCB portal. Producers buy EPR certificates from registered recyclers to meet their targets^[7], and the targets for 2026-27 are 70% under Schedule III^[7].

Battery EPR: only for fittings with batteries. Emergency luminaires, rechargeable lanterns and solar street lights contain batteries, so their importer is a battery producer^[11] and must register before importing^[26].

Plastic EPR: yes, whenever the luminaires come in plastic packaging^[9].

BIS Standard Mark with the R-number and IS reference^[36], on the product, the package or both, legible and indelible^[36]. Text at least Arial size 6^[36], and www.bis.gov.in on the product or package^[37]. Model, batch, date of manufacture and manufacturer's address go on the product, package or label^[36]. The 2026 editions of IS 10322 change the marking requirements^[2], so update your artwork when you migrate.

Legal Metrology declarations on retail packs: importer name and address, country of origin, generic name, net quantity, month and year of manufacture, MRP and consumer care^[38]. Packs sold only to institutional buyers are exempt from the retail rules^[38].

Battery marking for battery-containing fittings: crossed-out wheeled bin^[39].

Plastic EPR number on plastic packaging, or a QR code^[40].

Tick each line for the fitting and the carton before you sign off. Paste your text into the label checker, and see the product label checklist, CRS labelling rules and Legal Metrology label rules.

The factory holds the BIS licence per category and brand; the importer handles EPR and Legal Metrology; contractors and sellers are liable if they supply unregistered fittings. Section 17 of the BIS Act covers importing, selling, storing and displaying for sale^[42]. See our guides for foreign manufacturers, distributors and Amazon sellers.

An importer bringing in panels (fixed general purpose) and flood lights from one factory, one brand, one test report each. Official fees only. The total is our arithmetic.

One fixed-luminaire model costs about Rs 1.3 lakh in year one; three models cost about Rs 2.8 lakh if they share one category, or about Rs 3.7 lakh if they sit in three categories. Assumptions: one brand, a new importer, each model its own lead model, tested to the 2026 edition at the LIMS median. All totals are our arithmetic. Three categories cost more because each category is a separate licence with its own processing fee. Run your own range in the compliance cost estimator or the BIS CRS fee calculator.

After a valid report, the official BIS clock is a target of 20 working days; the deadlines below are the ones that most often cause a rejection or a lapsed licence. Lab turnaround is not published, so ask for it in writing. See how long BIS registration takes.

1. Lighting brand importing panels and downlights. Surface panels are fixed general purpose luminaires; recessed downlights are a separate category^[1]. Budget for two licences. If the factory already holds licences for its own brand, you still need applications in your brand^[17].

2. Contractor importing street lights for a municipal project. Street lights need the road and street lighting category^[1]. Solar street lights carry batteries, so battery EPR applies^[11]. For deliveries after 2 February 2027, the licence must be on IS 10322 (Part 5/Sec 3):2026^[3].

3. Online seller of decorative string and rope lights. Lighting chains and rope lights are two different categories^[1]. App-controlled versions need a WPC ETA. Marketplaces must reportedly show the Legal Metrology declarations on the listing^[43].

Customs checks BIS registration on arrival, and MeitY's surveillance and BIS raids check goods already on sale.

At the port. A CBIC instruction reportedly asks officers to check BIS registration for every consignment under the electronics CRS order and to sample some for safety tests^[47]. CPCB has asked Customs to verify battery EPR registration for equipment containing batteries^[45] and plastic EPR registration for importers^[46]. Keep the customs clearance checklist documents ready.

In the market. Every R-number must be registered on STPI's surveillance portal^[48], and STPI buys samples from shops or e-commerce sites^[49]. Unpaid surveillance fees after 15 working days send the case to BIS for deferment or cancellation^[50]. See CRS surveillance.

Raids. BIS officers can search premises and seize goods involved in a section 17 breach^[51]. In FY 2024-25, BIS reportedly searched 22 e-commerce warehouses after finding uncertified QCO products online^[52]. Selling without BIS explains what follows.

BIS. Importing or selling a notified product without a valid licence and Standard Mark breaches section 17 of the BIS Act^[42]. Under section 29(3) as enacted, 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^[42]. BIS can order a recall of non-conforming marked goods^[42].

Legal Metrology. Missing retail declarations: improvement notice, then up to Rs 5 lakh, then Rs 25-50 lakh^[53].

EPR. Unregistered producers can be charged environmental compensation^[7]; other e-waste violations cost Rs 20,000 to Rs 80,000^[54].