Importing lithium-ion battery packs into India: BIS CRS, battery EPR and labelling in 2026

Lithium cells and batteries for portable applications are a BIS CRS category, tested to IS 16046 (Part 2):2018, which is identical to IEC 62133-2:2017^[1]. On BIS's list the category is "Sealed Secondary Cells/Batteries containing Alkaline or other non-acid Electrolytes for use in portable applications"^[11], and BIS records the IS 16046 requirement as implemented on 1 June 2016^[2].

The second big obligation sits with you, the importer. Under the Battery Waste Management Rules 2022, anyone who imports batteries is a producer^[12], and CPCB says importers must register before they import^[6]. Plastic packaging EPR and Legal Metrology registration complete the list.

This page is about portable packs. Traction packs for e-bikes and EVs, and energy-storage packs, are not 'portable applications' in the ordinary sense and fall in different battery-rule categories^[8]; check their CRS position separately (see the borderline section below).

Lithium-ion battery packs are entered under ITC(HS) 8507 60 00, "Electric accumulators: Lithium-ion"^[3]. That is the tariff line for the battery itself. Confirm the line with your customs broker for your exact product before filing.

Borderline products, and why they matter:

• Power banks are a separate CRS category, "Power banks for use in portable applications"^[24]. If what you are buying is really a power bank, register it under that category instead. See our power banks guide.
• E-bike and EV traction packs are not portable batteries under the battery rules: there, a traction battery for an electric road vehicle is an "EV battery"^[8]. BEE has a voluntary star label for high-energy lithium-ion traction packs, charged at Rs 10 per kWh if used^[25].
• Solar storage batteries sit under MNRE's CRS category "Storage battery", tested to IS 16270:2023^[24].
• Packs of 5 kg or more are not portable batteries under the battery rules; anything that is not portable, automotive or EV, including energy storage batteries, is industrial^[8]. Industrial batteries have different EPR targets^[8].

The weight and use test decides your battery-rule category; the portable-application test decides your CRS category. Check both before you sign a purchase order.

Chemistry, weight and end use change the approvals: a different lithium chemistry needs its own inclusion, a pack of 5 kg or more stops being a portable battery, and a traction pack follows the EV battery rules.

Variants inside one licence. Sealed cells and batteries can share a series across ratings if they have the same nominal voltage, cell construction, electrodes and electrolyte^[26], and lithium cells and batteries allow up to 20 models in one series^[27]. All lithium-system cells sit on one licence, but each application or inclusion may carry reports for one chemistry only^[28]. See series guidelines, check your line in the HS code approval finder, and compare e-bike chargers and UPS and inverters.

The CRS registration is held by the factory and depends on lab testing, so start it first. Battery EPR must be in place before the first import, not after. This order is our suggestion; it does not guarantee approval or timing.

CRS runs under Scheme-II of the BIS Conformity Assessment Regulations 2018 and rests on the manufacturer's self-declaration backed by a lab report^[32]. Our BIS CRS guide covers the whole scheme; this section covers what matters for battery packs.

Who applies. The manufacturer of the pack, per factory. An importer or trader cannot hold the registration^[32]. A foreign factory must nominate an Authorised Indian Representative using Form IV^[14]. The AIR can be its Indian branch, the Indian brand owner, or another Indian entity if there is no Indian brand owner^[33].

The standard. IS 16046 (Part 2):2018 covers portable sealed secondary lithium cells and batteries made from them^[2]. It replaced the single IS 16046:2015, which was split into Part 1 for nickel systems and Part 2 for lithium systems^[34]. BIS lists one amendment to Part 2^[2]. Read more on our IS 16046 page.

Series and models. BIS samples by MeitY's series guidelines, and further models can be added through supplementary test reports that refer to an accepted original report^[14]. New models on an existing registration go through inclusion^[35], which costs Rs 30,000 per inclusion application^[4].

Cells inside the pack. We have not found an official BIS circular stating whether the cells inside a registered pack need their own CRS registration. Ask your lab how it handles the cells in the pack file.

Fees and time. Since 25 February 2026 CRS costs a Rs 1,000 application fee and a Rs 25,000 processing fee every year, paid in advance, plus Rs 1,000 a year licence fee, before GST^[4][36]. That Gazette schedule^[4] replaced the 2018 table's one-time Rs 50,000 processing fee^[36]. BIS aims to grant within 20 working days if everything is right first time^[14].

Validity. Since the 25 February 2026 amendment, a CRS licence is granted for five years and renewed for five more, with fees paid each year in advance^[5]. If the annual fee and production statement are missed, the licence is suspended for 90 days; paying with a Rs 5,000 late fee lifts it, otherwise it is cancelled^[4].

The Battery Waste Management Rules 2022 apply to every battery, whatever its chemistry, size or use, except batteries in military, security or space equipment^[8]. A producer includes anyone who imports batteries or equipment containing batteries^[18]. CPCB's FAQ says such importers must register before importing and that registrations under the old 2001 rules are no longer valid^[6].

Registration. You apply online in Form 1(A); since the 2023 amendment the certificate is valid until cancelled^[18]. CPCB must decide within two weeks of a complete application, after which registration is deemed^[18]. The fee is Rs 10,000 for turnover under Rs 5 crore, Rs 20,000 for Rs 5 to 50 crore and Rs 40,000 above that^[7].

Do you have an obligation? According to CPCB's FAQ, an importer has EPR obligations when it sells under its own brand, supplies others who sell under its brand, supplies bulk consumers directly, or sells under the imported brand; it does not when buyers resell under their own brand^[6].

Targets. For rechargeable portable batteries in consumer electronics, the collection target from 2024-25 onwards is 70% of the quantity placed on the market five years earlier^[8]. Other portable batteries have targets of 60% of 2023-24 placement for 2026-27, rising to 70% from 2027-28^[8]. Targets run separately for each chemistry, so Li-ion is counted on its own^[8]. You meet them by buying EPR certificates from registered recyclers or refurbishers; certificates are valid for seven years^[8].

Returns. Form 1(C), with quantities imported in the last financial year, is due by 30 June^[18]. The annual return in Form 3 is also due by 30 June of the next year^[8]. For FY 2025-26 the deadline was extended to 30 November 2026^[37].

Recycled content. From 2027-28, portable batteries must contain at least 5% domestically recycled material by dry weight, rising to 20% from 2030-31^[38].

Full details are on our battery EPR guide.

• WPC ETA: no, on our reading. A battery pack has no radio transmitter^[15]. WPC also says batteries as accessories need no WPC import licence or NOC^[39].
• TEC MTCTE: no, per our research. Battery packs are not in TEC's July 2024 list of notified products^[16].
• BEE: no for portable packs, on our reading. BEE's voluntary "High Energy Li-Battery" schedule covers lithium-ion traction batteries and systems, not portable packs^[17].
• E-waste EPR: no. The E-Waste Rules 2022 do not apply to waste batteries covered by the battery rules^[9]. A device with a built-in battery is different: the device can be e-waste and the battery inside it a separate battery obligation^[40].

Plastic EPR. Yes, if the packs come in plastic packaging, which retail packs nearly always do^[19]. The application fee is Rs 10,000 below 1,000 tonnes a year of plastic waste, Rs 20,000 up to 10,000 tonnes and Rs 50,000 above^[21], plus 25% of that fee each year with the return^[21]. A fresh registration is valid for one year, a renewed one for three^[21]. Read more in our plastic EPR guide.

Legal Metrology. Importers of commodities for sale must register under rule 27^[10]. For packs imported as retail units, we understand this means importer registration and full declarations, though we have confirmed only the registration form, not the full rules text^[22]. The fee is Rs 500^[10], and companies must now name the director responsible for violations^[23]. Packs supplied to industrial or institutional buyers are exempt from the retail provisions^[41].

BIS Standard Mark. The mark must carry the R-number and the Indian Standard reference^[42], be legible and indelible on the product, the package or both^[42], and the text must be at least Arial size 6^[42]. Add www.bis.gov.in on the product or package^[43], plus product details such as model, batch and the manufacturer's full address^[42].

Battery rules. Every battery or pack must carry the crossed-out wheeled bin symbol, covering at least 3% of the largest side, up to 5 cm x 5 cm^[8]. Packs must also show your EPR registration number^[18]; for imported batteries, MoEFCC has said marking it on the equipment or its packaging is enough^[44]. Since 2025 you may use a barcode or QR code instead, after telling CPCB^[45]. Portable batteries may contain no more than 0.002% cadmium by weight^[18].

Legal Metrology. Each retail pack declares the importer's name and address, country of origin, generic name, net quantity, month and year of manufacture, MRP, unit sale price and consumer care details^[41]. For electronic products and accessories, the month and year of manufacture can reportedly go anywhere on the pack^[46].

Plastic EPR. Rule 11 asks for the name and registration number of the producer or brand owner on plastic packaging, and extends this to importers, though a proviso in the same clause exempts packaging of imported goods^[47]. A QR code or barcode is allowed since 1 July 2025^[48].

Check every item below on the product, the retail box and the listing before the factory prints, because a reprint after the goods land costs more than all the fees on this page. Run the artwork through the label checker, and see the product label checklist, CRS labelling and LMPC label rules.

This worked example assumes a factory with no CRS registration yet, one test report, and an importer with turnover under Rs 5 crore and less than 1,000 tonnes a year of plastic waste. It uses the official fee tables only; the totals are our arithmetic.

Our arithmetic: CRS Rs 1,000 + Rs 25,000 + Rs 1,000 = Rs 27,000 before GST in year one, then Rs 26,000 a year. Importer: Rs 10,000 + Rs 10,000 + Rs 2,500 + Rs 500 = Rs 23,000. Total official fees in year one: Rs 50,000, plus GST on the BIS fees. If the factory already holds a registration covering your model and brand, your own fees are the Rs 23,000.

The CRS figures come from the 2026 Gazette schedule^[4]; over a five-year licence the CRS part comes to Rs 1,31,000 on our arithmetic. Indian micro enterprises and start-ups get 80% off the processing fee, small enterprises 50% and medium 20%, until 31 May 2029^[4], but foreign manufacturers are generally not MSMEs. Lab testing, AIR charges, consultants, battery EPR certificates and plastic EPR certificates are not government fees (labs, firms or the market set them) and are not included.

One pack model costs about Rs 1,27,500 in the first year once testing is counted, and three models about Rs 3,27,500, on our arithmetic. Unlike the example above, this table leaves out the plastic EPR annual fee. The three-model column assumes one brand, one factory and one application in which each model needs its own test report. If MeitY's series guidelines let the models share a series, the factory pays for fewer reports^[14]; see series guidelines. Adding a model later costs Rs 30,000 per inclusion application^[4], so it is cheaper to put every model you plan to sell in the first application. Use the BIS CRS fee calculator to rerun the numbers for your own model count. Lab charges are the lab's own, declared on BIS LIMS excluding taxes and fixed for three years unless the standard changes^[49]. The spread is wide: one Bengaluru lab declares Rs 4,80,000, mostly for the 'reasonably foreseeable misuse' tests^[50]. From 2027 you also need rated-capacity verification, which is not in these figures^[51]. Registration fees for EPR and Legal Metrology do not rise with the number of models; BIS fees, ETAs and testing do. The BIS processing fee recurs: from year two the licence costs Rs 26,000 a year in BIS fees (Rs 25,000 processing plus Rs 1,000 licence fee), paid in advance^[4]. Plug your own numbers into the compliance cost estimator, and compare with the cost of importing electronics.

The official clocks are short: BIS targets 20 working days for a CRS grant once a valid test report is filed^[14], and CPCB must decide battery EPR within two weeks^[18]. The table lists every official clock we could source. The steps that no rule times, such as lab queues, sample shipping and your own artwork changes, usually decide the real date, so ask for those in writing. Run EPR and Legal Metrology registrations while the factory is testing, so they are ready when the CRS licence arrives. See how long BIS registration takes and put renewal dates into the licence renewal date tool.

For battery packs the cell or pack factory holds the BIS registration, and the importer is the producer under the battery rules, with plastic EPR and Legal Metrology on top. A common mistake is to assume that whoever holds the paperwork carries the risk alone: in practice every business in the chain can be asked for it. If you are new to this, start with first-time importers; brands should read D2C brands and foreign manufacturers; marketplace sellers should read Amazon sellers and Flipkart sellers. You also need an IEC before you import anything.

1. First-time importer of a branded replacement pack. Ask the factory for a CRS R-number that covers your brand^[14]. Register with CPCB as a battery producer before the first shipment, because CPCB has asked Customs to check registration certificates at clearance^[57]. Then register for plastic EPR and LMPC, and make sure your EPR number is on each pack or its packaging^[44].

2. Marketplace seller buying packs from an Indian importer. The BIS Act's ban on unmarked goods covers sellers and retailers too^[56], so check the Standard Mark and R-number on the stock. If the importer sells to you and you resell under your own brand, the battery EPR obligation may move to you; CPCB's FAQ says an importer has no obligation where buyers resell under their own brand^[6]. Settle in writing who is the producer.

3. Foreign battery brand selling in India. The factory holds the CRS registration and nominates an AIR^[14]. The AIR is responsible for compliance on the manufacturer's behalf^[54]. Your Indian importer, or your Indian subsidiary if it imports, registers as the battery producer and files the annual returns^[8]. Each brand needs its own CRS application unless the brand owner is the same^[14].

• No CRS registration, or the wrong model or brand. Covered goods cannot be imported without the Standard Mark and a registration number^[32].
• No battery EPR certificate. CPCB asked CBIC in December 2022 to have Customs verify registration certificates for batteries and equipment with batteries^[57].
• Old test reports. A report more than 90 days old when BIS receives the application cannot be used^[14].
• Pack outside the portable category. A heavy, traction or storage pack needs a different CRS route or none, and a different battery-rule category^[8].
• Missing plastic EPR proof. CPCB has also asked Customs to check plastic EPR registration, according to its court affidavit^[58].
• Labels. Check the wheeled-bin symbol, the EPR number and the Legal Metrology declarations before the goods sail, because fixing packs after landing costs time (see labelling above).

Battery packs are enforced at the port and afterwards: CPCB asked Customs to verify battery EPR registration for battery consignments^[57], and BIS can search and seize unregistered stock.

• In June 2026 a BIS team reportedly seized 112 products, including wireless earbuds, power banks and speakers, from a Surat firm whose goods bore BIS markings but allegedly lacked valid registration^[59]. A mark on the box is not proof, so verify the licence before you buy stock.
• A ministry reply in Parliament reportedly said that in FY 2024-25 BIS bought 344 samples of certified-only products from e-commerce platforms, found 142 without valid certification, and searched 22 e-commerce warehouses^[60].
• The power behind these searches is section 28 of the BIS Act, which lets a certification officer search premises and seize goods and documents^[61].
• At the port, goods imported against a prohibition can be confiscated, and the penalty can reach the value of the goods or Rs 5,000, whichever is greater^[62].

The pattern is the same each time: officers check whether the model in the warehouse matches a live registration, not whether the box looks right. Read what happens if you sell without BIS and why shipments get held at Indian ports.

BIS. Importing or selling covered goods without a Standard Mark under a valid licence breaks section 17 of the BIS Act^[56]. The penalty is 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, or both^[56]. These amounts are from the Act as enacted and may have been amended since.

Battery EPR. Environmental compensation for an EPR shortfall on Li-ion is set per kg of recovered metal, for example Rs 2,400 for lithium and Rs 555 each for cobalt, nickel and manganese^[63]. Other breaches, such as not filing returns or wrong labelling, draw Rs 20,000 for a first default, Rs 40,000 for a second and Rs 80,000 for a third, rising 10% a year^[63]. Late payment carries interest of 12% to 24% a year^[63].

Legal Metrology. A package without the required declarations gets an improvement notice first, then a penalty of up to Rs 5 lakh, then a fine of Rs 25 to 50 lakh^[64].

The change that matters most is rated capacity: from 30 April 2027 no new lithium CRS licence is granted without capacity verification to IS 16047 (Part 3), and existing licensees must file reports for all lead models by then^[51].

• Not part of the 62368 move. The 38 categories migrating to IS/IEC 62368-1:2023 do not include cells and batteries^[65], so IS 16046 stays the standard. Power banks do migrate; see power banks.
• Battery returns. The FY 2025-26 annual return is due by 30 November 2026^[37].
• Recycled content. Portable batteries must contain 5% domestically recycled material from 2027-28, rising to 20% from 2030-31^[38]. Ask your cell supplier now how it will document this.
• Licence term. CRS licences are now granted for five years^[5].

Track dates on new rules for 2026, the compliance calendar, battery EPR targets and the QCO tracker.

Use a lab recognised for IS 16046 (Part 2):2018; on 1 November 2026 BIS LIMS listed 35 labs for it, with declared charges from Rs 37,500 to Rs 4,80,000 and a median of about Rs 80,000^[50]. Search the LIMS portal by IS number to see who is recognised^[67]; each entry shows the clause-wise charge, any excluded tests and the recognition validity date^[68]. Compare quotes on the same scope, because an exclusion can mean a second lab bill later.

Where the labs are. Eight Noida-named labs test to IS 16046 at Rs 45,000 to Rs 80,000^[69], Bengaluru has four^[70], Hi Physix in Pune lists Rs 1,23,000 for Part 2^[71], and no Mumbai-named lab appears^[71]. A foreign factory therefore ships samples to India; see importing samples for BIS testing, BIS labs, labs in Delhi NCR and CRS test labs. When the report comes back, check it against how to read a BIS test report.

Consultants. Consultant fees are not regulated. One consultancy, for example, lists a Rs 14,999 professional fee on its CRS page^[72]. A recognised lab may not use agents or pay referral commissions^[49], so be wary of a consultant who is paid by the lab. Our BIS consultants guide and how to choose a BIS consultant explain what to ask.

Four Comploa tools cover the main checks for lithium-ion battery packs, and they are free.

• Approval checker: answer a few questions about radio, battery and packaging and get the approval list for your model.
• HS code approval finder: start from the tariff line your broker proposes and see which approvals usually follow it.
• Compliance cost estimator: official fees for your model count, with your own lab quotes added.
• Label checker: tick the box and product markings before the factory prints.

Before the first shipment, work through the first electronics import checklist, the BIS CRS application checklist, the EPR registration checklist and customs clearance documents. Before you list, use before listing on Amazon or before listing on Flipkart.

Country guides. India imported lithium-ion accumulators under 85076000 worth US$ 3,927.70 million from China in 2025-26^[73], and HS 8507 goods worth US$ 430.40 million from Hong Kong^[74] and US$ 189.72 million from South Korea^[74]. See importing from China, Hong Kong, South Korea and Japan.

If your model does not fit neatly, ask us for a free compliance check with the spec sheet and the box artwork.