Importing smartwatches into India: BIS, WPC and EPR approvals for 2026

A smartwatch is a small computer with a radio and a battery, so it picks up most of the rules that apply to phones, minus the telecom certification. You need:

1. BIS CRS registration, held by the factory. "Smart Watches" is a CRS category, tested to IS/IEC 62368-1:2023^[1].
2. WPC Equipment Type Approval (ETA) for each model with Bluetooth or Wi-Fi^[11]. WPC's self-declaration list names smart watches^[5].
3. Battery EPR, because smartwatches contain batteries^[8].
4. Plastic packaging EPR^[12].
5. LMPC importer registration and package declarations for retail packs, on our reading^[13].

E-waste EPR is unsettled: Schedule I does not name smart watches or wearables^[9].

Not required: MTCTE, because smart watches are exempt from prior mandatory testing under S.O. 2372(E)^[6], and the BEE star label^[14].

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

Smartwatches are usually classified under ITC(HS) 85176290, "Other machines for the reception, conversion and transmission or regeneration of voice, images or other data". This is backed by a tribunal decision rather than a customs ruling: CESTAT New Delhi held that a smart watch is classifiable under 8517 6290 and not under heading 9102 (wrist watches)^[4]. A tribunal decision on one importer's goods is persuasive, not a ruling for yours. Confirm the code with your customs broker before you file.

Fitness bands and activity trackers are less settled. In 2024 CESTAT Mumbai sent back a case on whether an activity tracker is classifiable as a smart watch under 8517 62 90, holding that the Revenue has to prove the classification^[26]. If you import bands without a display or without notifications, expect the classification to be argued, and get your broker's view in writing.

Borderline products for BIS and telecom:

A SIM, a tracker function or a missing display can each change the approvals: an eSIM watch may count as a mobile phone for BIS, and a GPS tracker may need MTCTE.

Variants inside one licence. Smart watches share a series if they have the same input voltage and current, enclosure (apart from decoration), battery nominal voltage and capacity, and a BIS-registered adapter^[29]. Up to 10 models fit in one series^[30]. So a new strap or dial colour usually stays in the series, while a bigger battery does not. See series guidelines and check your tariff line in the HS code approval finder. Telecom rules are explained in TEC MTCTE and WPC ETA vs MTCTE.

In this order. Steps 3 and 5 can run in parallel.

Category and standard. Smart watches have been a CRS category since 23 May 2018, originally under IS 13252 (Part 1):2010^[2]. The portal now lists IS/IEC 62368-1:2023 for the category^[1], because MeitY has replaced IS 13252 (Part 1) with it for CRS. The old standard may be used until 1 November 2028, after which it is withdrawn^[3]. For a new model, test to IS/IEC 62368-1:2023^[37].

Who applies. The manufacturer, per factory; not the importer^[15]. A foreign factory needs an AIR: its Indian branch, the brand owner in India, or another Indian entity^[38].

Brands, models and series. A separate application is needed for each brand unless the brand owner is the same^[17]. Whether variants that differ only in case colour or strap can share a report is decided under MeitY's series guidelines, using supplementary reports^[17]; ask your lab. New models go on by inclusion^[39].

Timeline and validity. BIS targets 20 working days from a complete application^[17], with at least 30 days to answer any query^[17]. Under the 2026 amendment, licences run up to five years and renew for five, with fees paid yearly in advance^[7].

See BIS CRS, IS 13252 (Part 1) and CRS renewal.

Yes, on our reading, for any model with Bluetooth or Wi-Fi^[11]. ETA is required for the import, sale and use of wireless devices in de-licensed bands^[5], and smart watches are named in WPC's list of products eligible for self-declaration^[5].

• Route. Since the OM of 9 September 2024, ETAs for licence-exempt devices are granted on self-declaration via Saral Sanchar^[18].
• Documents. RF test report, the manufacturer's authorisation if you apply as its Indian representative, and technical literature^[5].
• Fee and validity. Rs 10,000 per model^[5], valid for the lifetime of the model^[5].
• Import. For products that are "Free" under DGFT policy, the Saral Sanchar undertaking is enough to import, without a separate WPC import licence^[32].

The 2026 transition. DoT has stopped accepting new applications under the Indian Telegraph Act, 1885, and Telecommunications Act authorisations are now applied for on eservices.dot.gov.in^[40]. Whether the ETA self-declaration route moves or changes is not yet confirmed^[41]. Check the portal before filing.

No. S.O. 2372(E) of 24 May 2022 exempts mobile handsets, servers, smart watches, smart cameras and point-of-sale devices from prior mandatory testing and certification^[6].

That exemption has survived the move to the new telecom law. The Telecommunications (Framework to Notify Standards, Conformity Assessment and Certification) Rules, 2025 replaced the old Telegraph Rules, but existing exemptions continue until superseded by a new notification^[42]. The current MTCTE product list does not include smart watches as a category^[27]. On our reading, the exemption also covers cellular (eSIM) watches^[6].

Two cautions. First, if a future notification under section 19 of the Telecommunications Act supersedes the exemption, this answer will change; we track it on new rules for 2026. Second, a product marketed as a tracking device rather than a watch may fall into the MTCTE "tracking device" category, mandatory since 1 January 2024^[27].

BEE: not required either. Smartwatches are in neither BEE list^[14].

It depends, and there is no official answer yet. The E-Waste (Management) Rules, 2022 apply to equipment listed in Schedule I, including components, consumables, parts and spares^[43], and anyone who offers to sell imported EEE or its parts is a producer^[9].

Smart watches and wearables are not named in Schedule I as separate items, and we have not been able to verify how CPCB classifies them^[9]. Some read them as falling under a sports-computer entry or a telecommunications-equipment entry^[43], but neither reading is confirmed by CPCB, so we do not assign an EEE code to smartwatches.

What to do: ask CPCB how to declare your exact product when you use the CPCB e-waste portal, and keep the answer in writing. If you are told to register, the producer fee is Rs 2,500 under 50 tonnes, or Rs 10,000 for producers whose sales have just started^[19], plus Rs 5,000 a year in maintenance^[19]. Covered products must also meet the RoHS limits on lead, mercury, cadmium and other substances^[9], so get a RoHS declaration from your factory either way. Do not simply ignore the question: environmental compensation can be levied on unregistered producers^[9].

Yes. Smartwatches contain batteries, so the importer is a producer under the battery rules^[8]. The Battery Waste Management Rules, 2022 treat anyone who imports batteries or equipment containing batteries as a producer^[21], and CPCB's FAQ says such importers must register before importing^[35].

• Registration. Form 1(A) on CPCB's centralised portal; the certificate stays valid until cancelled^[21]. CPCB must decide within two weeks of a complete application, after which registration is deemed^[21].
• Fee. Rs 10,000 for turnover under Rs 5 crore, Rs 20,000 for Rs 5–50 crore, Rs 40,000 above that^[20].
• Targets. A sealed battery under 5 kg that is not industrial, automotive or EV is a portable battery^[44]. For rechargeable consumer-electronics batteries the collection target from 2024-25 is 70% of the quantity placed on the market five years earlier^[44], met with certificates from registered recyclers^[44].
• Returns. Form 1(C) by 30 June each year^[21] and the annual return in Form 3^[44]; for FY 2025-26 the deadline was extended to 30 November 2026^[45].

The battery obligation is separate from any e-waste obligation on the device: waste batteries are outside the E-Waste Rules^[9]. See battery EPR.

Yes. An importer of smartwatches sold in plastic packaging counts as an importer under the Guidelines on EPR for Plastic Packaging and needs plastic EPR registration^[12]. The micro and small enterprise carve-out in the list of obligated entities applies to producers and brand owners, not to importers^[36].

• Registration. On CPCB's centralised EPR portal^[36]; your State Pollution Control Board handles it if you operate in one or two states, CPCB if more^[22].
• Fee. Rs 10,000 if you generate under 1,000 tonnes of plastic waste a year^[23], plus 25% of that each year when you file the annual return^[23].
• Validity. One year for a fresh registration and three for a renewal, under CPCB's March 2022 SOP^[23].
• Obligation. Your eligible quantity is based on the average plastic packaging you imported and sold over the last two years, by category^[22], and the target has been 100% of it since 2023-24^[22]. The annual return, with certificate details, is due by 30 June^[36].

See plastic EPR for categories and the portal process.

Yes, if you import smartwatches 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^[24]. Our reading that this covers smartwatches in retail packs rests on the Delhi Legal Metrology importer form; we could not open the full rules text^[13]. Packages for industrial or institutional consumers are exempt from the retail-package provisions^[46].

• Where and how much. Apply to the State Controller or the Director of Legal Metrology^[24] with a Rs 500 fee^[24], within 90 days of starting to import on our reading of rule 27^[24].
• What you state. Name, complete address of the premises and the commodities imported^[24]; since 29 May 2026 a company must also name the director responsible for violations^[25].
• Validity. The certificate stays valid until cancelled^[25], but details must be updated every year on the online portal^[25].

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. The mark carries the R-number and IS number^[47], in letters at least Arial size 6^[47], with www.bis.gov.in on the product or package^[48]. Model, batch, manufacture date and the manufacturer's address go on the product, package or a label^[47].

E-labelling on the screen. Because a smartwatch has a display, the Standard Mark may be shown electronically. This is optional, and a physical label is still required on the packaging at import, storage and sale. The e-label must be reachable within four menu steps without special codes^[10]. Even with e-labelling, www.bis.gov.in must still be marked physically^[48]. See CRS labelling.

Battery marking. The crossed-out wheeled bin symbol goes on the battery; if it would be smaller than 0.5 cm x 0.5 cm, a 1 cm x 1 cm symbol goes on the packaging instead^[44]. Mark your battery EPR registration number; for imports it may go on the equipment or its packaging^[49], or in a QR code after informing CPCB^[50].

Plastic EPR marking. Rule 11 asks for your registration number on plastic packaging, but a proviso in the same clause exempts imported goods' packaging, so the text conflicts^[51]. A QR code is allowed^[52]. 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^[46]. Declare the month and year of manufacture, not of import^[24]. For electronics, the date of manufacture can reportedly appear anywhere on the retail package if it is legible^[53]. Stickers may not alter the declarations, except a reduced-MRP sticker that leaves the original visible^[24]. 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^[25].

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.

One smartwatch model, one brand, a new importer with turnover under Rs 5 crore and under 1,000 tonnes of plastic a year. Official fees only. The totals are our arithmetic, not an official figure.

• Lab testing for BIS safety and the RF report, and AIR or consultant fees, are not government fees.
• More models. Each extra CRS test report costs Rs 20,000^[16] and each extra model needs its own ETA at Rs 10,000^[5].
• The 2026 BIS fee change. A consultant reports the processing fee is now Rs 25,000 a year, paid in advance^[56]; BIS's published table is still the 2018 one.
• EPR certificates for battery and plastic targets trade within CPCB price bands^[57][36], so their cost is set by the market.

See CRS registration cost and the CRS fee calculator.

One smartwatch model costs about Rs 2,22,500 to Rs 2,47,500 in the first year with testing, and three models about Rs 5,62,500 to Rs 6,37,500, on our arithmetic from official fees and the median declared lab charge. 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^[17]; see series guidelines. Adding a model later costs Rs 30,000 by inclusion, including one report^[16], 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^[58]. Under the older IS 13252 (Part 1), still allowed until November 2028, the median declared charge was about Rs 63,750^[59]. Registration fees for EPR and Legal Metrology do not rise with the number of models; BIS fees, ETAs and testing do. A consultant reports that the 2026 amendment moved the processing fee to Rs 25,000 a year paid in advance^[56]; we use the published table until BIS releases the new one. 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^[17], and the ETA downloads on submission^[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 smartwatches the factory holds the BIS registration, the importer or the factory's Indian representative files the ETA, and the importer holds the EPR and Legal Metrology registrations. 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, own brand. The factory needs a CRS application in your brand^[17]; as brand owner you can be its AIR^[38]. File the ETA yourself, and register battery EPR before the goods ship, since Customs has been asked to check it^[70]. If you also sell a fitness band, settle its HS code early.

2. Marketplace seller. Buying cleared stock from an Indian importer, check the R-number and model against the BIS portal. If you rebrand the watches, CPCB's FAQ suggests the battery obligation may move to you: an importer has no battery EPR obligation when buyers resell under their own brand^[35]. Marketplaces must reportedly show the Legal Metrology declarations on the listing^[68].

3. Foreign brand. Your AIR must be an Indian resident who accepts responsibility for BIS compliance^[66] and generally represents only one foreign manufacturer^[66]. Your Indian representative can file the ETA with your authorisation^[5]. If your watch takes an eSIM, on our reading the watch stays exempt from MTCTE^[6].

Most holds come from paperwork that does not match the product.

BIS enforces the smartwatch rules through warehouse searches, and smart watches were among the goods reportedly seized at an e-commerce warehouse in 2025.

• In March 2025 BIS Hyderabad reportedly searched an Amazon warehouse in Shamshabad and seized 2,783 uncertified products, including 326 wireless earbuds, 170 mobile chargers and 150 smart watches^[72].
• 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^[73].
• The power behind these searches is section 28 of the BIS Act, which lets a certification officer search premises and seize goods and documents^[74].
• Radio products face a second regulator. CCPA guidelines call a device that works only in de-licensed bands but lacks a WPC ETA an 'unauthorised device'^[55], and in January 2026 CCPA reportedly fined four large platforms Rs 10 lakh each over non-compliant walkie-talkie listings^[75].
• 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^[76].

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 a notified product without a valid licence and Standard Mark breaches section 17 of the BIS Act^[69]. Under section 29 as enacted (later amendments not checked), 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^[69]. Importers and sellers are "persons" under the Act^[69], and BIS can order a recall^[69].

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^[77].

WPC. In the ETA self-declaration the importer accepts liability to prosecution for a wrong declaration^[67].

EPR. Plastic EPR shortfalls attract environmental compensation of Rs 2,900 to Rs 7,900 a tonne, multiplied for repeat defaults^[78]. Battery-rule breaches other than a target shortfall, such as missed returns or wrong labels, cost Rs 20,000, Rs 40,000 and Rs 80,000 for first, second and third defaults^[79]. CPCB's e-waste EC guidelines set the same Rs 20,000 / 40,000 / 80,000 scale for a producer's violations other than a shortfall^[80].

The biggest change is the standard: smart watches is one of 38 CRS categories moving to IS/IEC 62368-1:2023, with reports for every lead model due by 1 November 2028^[81].

• Existing licences. Migrate through the 'Standard Revision' option with complete reports for all lead models and an undertaking for series models^[82]. BIS charges no fee for this^[54], and the R-number stays the same^[54]. Renewals can still be granted under the old standard until 1 November 2028^[54].
• New applications. BIS encourages new applications under IS/IEC 62368-1:2023, though the old standard may be used until the cut-off with a declaration to migrate^[54]. For a model launching now, testing once to the new standard avoids paying for two reports.
• Components. Critical components that comply only with IS 13252 (Part 1) or IS 616 are not accepted in the critical component list after migration^[54]. Ask the factory now whether its battery and charging adaptor has a 62368 or IEC component report.

Track dates on new rules for 2026, the compliance calendar, the electronics CRS order and the QCO tracker. The standard itself is explained on IS/IEC 62368-1.

Use a lab that BIS LIMS recognises for IS/IEC 62368-1:2023; on 1 November 2026 it listed 47 entries with declared charges from Rs 50,000 to Rs 2,99,000^[61]. Search the LIMS portal by IS number to see who is recognised^[88]; each entry shows the clause-wise charge, any excluded tests and the recognition validity date^[59]. Compare quotes on the same scope, because an exclusion can mean a second lab bill later.

Where the labs are. On 1 November 2026 every IS 13252 (Part 1) lab on LIMS was in India^[89], and at least 32 of the 68 were in Delhi NCR^[90]. 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^[91]. A recognised lab may not use agents or pay referral commissions^[58], 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. Noida alone had eight labs for IS/IEC 62368-1:2023, at Rs 50,000 to Rs 2,50,000^[92]. The RF report for the ETA can come from any accredited laboratory named with its country^[67]; see WPC consultants.

Four Comploa tools cover the main checks for smartwatches, 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. Smartwatches share heading 8517 with phones and routers; see importing from China, Vietnam, phones from Vietnam and Hong Kong. For the neighbouring product, read mobile phones.

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