Importing electric water heaters and geysers into India: BIS licence, BEE star label and EPR

It depends on the type of heater, but every electric water heater needs a BIS licence:

1. BIS ISI licence. The Electrical Appliances for domestic water heating (Quality Control) Order, 2025 covers storage heaters (IS 302-2-21 and IS 2082), instantaneous heaters (IS 302-2-35), immersion heaters (IS 368) and mini PNG heaters (IS 17150), from 1 March 2025 for most makers^[1].
2. BEE star label, storage heaters only. Stationary storage type electric water heaters are on BEE's mandatory list^[2], at Rs 5 per heater^[3]. Instantaneous and immersion heaters are on neither BEE list^[8].
3. E-waste EPR. Schedule I does not name water heaters; on our reading they fall under "Electric heating appliances", LSEEW11^[7].
4. Plastic EPR^[9] and LMPC^[10].

Smart geysers with Wi-Fi need a WPC ETA^[11].

Electric instantaneous or storage water heaters and immersion heaters are declared under 85161000^[6]. We did not confirm this on DGFT's lookup. Within that one line, the approvals differ by type:

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.

The Electrical Appliances for domestic water heating (Quality Control) Order, 2025 (S.O. 355(E), dated 16 January 2025, published 21 January 2025) replaced the 2023 order. It requires the ISI mark under Scheme-I for five products^[1]:

• stationary storage water heaters: IS 302 (Part 2/Sec 21):2018 and IS 2082:2018;
• electric instantaneous water heaters: IS 302 (Part 2/Sec 35):2017;
• electric immersion water heaters: IS 368:2014;
• mini domestic PNG water heaters: IS 17150:2019.

Dates. 1 March 2025 for most manufacturers, 1 June 2025 for small and 1 September 2025 for micro enterprises^[1]. The Transition Facilitation Order records the same 1 March 2025 date^[25].

Older immersion heater rule. BIS's Scheme-I table also lists immersion water heaters to IS 302 (Part 2/Sec 201) under the Electrical Wires, Cables, Appliances and Protection Devices and Accessories QCO of 2003^[19]. Check with BIS which standard your immersion heater licence should cover.

Exemption. Up to 200 units a year imported for R&D by manufacturers are exempt, if not sold^[1].

Transition route. Indian companies assessed by DPIIT may source goods under this QCO through BIS Scheme-II licences^[25].

For a storage geyser the BIS minimum marking fee is Rs 1,30,000 a year for a large enterprise, with Rs 6 per heater as the unit rate; IS 2082 and IS 302 (Part 2/Sec 21) carry the same figures^[26][27]. BIS's 2021 rule says a product certified to both a safety and a performance standard pays one marking fee, the higher of the two^[28], so a geyser pays Rs 1,30,000, not double.

The unit rate matters more here than for most appliances. At Rs 6 a heater, the unit-rate total passes the minimum at about 21,700 storage heaters a year. A BIS grant letter reportedly says the higher of the two is payable^[29], so a brand selling 25,000 geysers would owe about Rs 1,50,000.

Instantaneous and immersion heaters have their own, lower minimums, and each standard is a separate application^[12]. Indian micro and small enterprises get 80% and 50% off the minimum until 31 May 2029^[30]. See BIS ISI fees and the ISI licence cost guide for the other fee lines.

Stationary storage type electric water heaters are on Schedule A (mandatory)^[2], with a label fee of Rs 5 per heater^[3]. The programme dates from S.O. 2901(E) and S.O. 2902(E) of 7 September 2016, with IS 2082 and IS 302-2-21 as reference standards^[31].

Two tables in 2026. S.O. 5970(E) of 23 December 2025 extended the old Table 3.4 to 30 June 2026 and inserted Table 3.5, valid from 1 July 2026 to 31 December 2027^[4]. BEE describes the new table as a one-star upgrade. Approved models had until 20 July 2026 to convert, with no renewal fee, and unconverted models were deactivated^[32].

How the rating works. Heaters are rated on standing losses, the energy lost in 24 hours holding water at 45°C^[4]. Selected limits from Table 3.5^[5]:

BEE rates storage geysers by standing loss in kWh per 24 hours at 45°C, and the allowed loss rises with tank size^[4]. A 15 L geyser needs 0.346 kWh/24h or less for 5 stars, while a 25 L geyser may lose up to 0.423^[5]. Anything above the 1-star upper limit cannot be labelled at all.

Worked example: a 25 L geyser tested at 0.45 kWh/24h misses the 5-star limit of 0.423 but sits well under the 1-star ceiling of 0.618^[5], so it gets a rating between 1 and 4 stars depending on the intermediate bands. Because BEE moved the whole table up by one star from 1 July 2026^[32], a model that was 5-star in 2025 may now be 4-star. Re-check the test report against Table 3.5 before you print boxes, and see the BEE products list for other appliances' tables.

• Company registration: Rs 5,000^[2].
• Label security deposit: Rs 3 lakh per appliance category, Rs 50,000 for small-scale industry^[2].
• Model registration: Rs 5,000 per model^[2].
• Label fee: Rs 5 per heater, paid quarterly with a production statement and a yearly CA-certified reconciliation^[3][2].

The label goes on the front of the heater and may also be on the box^[3]. It must carry a QR code^[2].

On our reading, yes. Schedule I does not list water heaters by name, but lists "Electric heating appliances" as LSEEW11^[7]. Choose codes carefully on the CPCB portal; Schedule I coverage depends on the product being one of the listed EEE^[7]. Importers who sell EEE are producers^[33]. LSEEW environmental compensation is Rs 76 per kg^[34].

Plastic EPR. Heaters ship in foam and film, so the importer is obligated^[9] and must file annual returns by 30 June^[21].

LMPC. Register for Rs 500^[10] and print the mandatory declarations^[35]. Capacity in litres is the net quantity customers compare, so state it clearly.

Only smart geysers with Wi-Fi or Bluetooth control. These are wireless devices in de-licensed bands^[11]; the ETA is by self-declaration^[18] for Rs 10,000 per model^[11], with an RF test report^[11].

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: two storage geyser models (15 L and 25 L) from a foreign factory, 10,000 heaters a year. Government fees only; BIS marking fees for IS 2082 are not shown^[39].

One storage geyser model costs about Rs 2.1 lakh in government fees in year one and three models about Rs 2.7 lakh. The example assumes a large foreign factory, three storage models (10 L, 15 L and 25 L) under one licence, 5,000 heaters of each, a two-day factory visit by one officer and all models in the first application. Testing, consultants, travel and GST are extra.

At 15,000 heaters a year the unit-rate total is Rs 90,000^[26], still under the minimum. Swap one storage model for an instantaneous heater and you need a second BIS application^[12] with its own Rs 1,04,000 minimum^[27], but that model needs no BEE label^[2]. Try other mixes in the compliance cost estimator; the BEE side is on BEE fees and the BIS side on FMCS fees.

1. Importer of instantaneous heaters. BIS IS 302-2-35 applies^[1], but no BEE label, because only storage heaters are on the mandatory list^[2]. Many importers pay for BEE registration they do not need.

2. Brand with storage geysers approved in 2024. Labels under Table 3.4 needed conversion to Table 3.5 by 20 July 2026^[32]. Approved models that were not converted were deactivated, so check your portal status before shipping old stock.

3. Marketplace seller of immersion rods. BIS applies (IS 368)^[1]; e-waste and plastic EPR apply to the importer^[33][9].

Each approval sits with a different party, and the importer of record carries more than most people expect. For water heaters, only storage models carry a BEE label, so the brand owner's BEE duties depend on the range; the BIS and EPR duties apply to every type. 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.

Water heater files most often fail because the range mixes heater types under one licence, or because the 2026 star upgrade was missed. The fixes are mostly paperwork if you act before shipping. Use the approval checker to confirm which standard each heater type needs.

Storage geysers have had a BEE label since 2016; BIS arrived for all electric water heaters in 2025. Newest first:

Two dates matter in 2027: 23 February, when old and new editions of the storage and immersion heater safety standards stop running together, and 31 December, when the geyser star table expires. BIS's January 2026 circular moved the end of concurrent running to 23 February 2027 for storage water heaters (Sec 21) and for immersion heaters moving from old Sec 201 to new Sec 74^[47]. Ask your lab which edition your reports cite, and plan changeover tests before that date.

The 2026 household appliances QCO, compulsory from 1 October 2026^[48], does not change anything for heaters already under the water heating QCO, because it excludes goods under other orders^[48]. Follow later notices on the QCO tracker, the new rules 2026 ledger and the electrical appliances QCO page; IS 302 Part 1 explains the general safety standard.

BIS: up to two years' imprisonment or fines from Rs 2 lakh, up to ten times the goods' value^[43]; BIS can also direct recall^[43]. BEE: deposit forfeiture and a one-year suspension^[2]; Energy Conservation Act penalties of up to Rs 10 lakh plus Rs 2,000 to Rs 5,000 per appliance^[49].

Enforcement now runs through warehouse searches, online test purchases and public lists of failed licences, not only port checks. Geysers are one of the few appliances named in a reported warehouse seizure, which shows BIS is checking them on marketplaces. We found no published case that names water heaters 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.

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 water heater.
• 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 Germany: BIS records show German FMCS licences under IS 302, including instantaneous water heaters.

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.

• The e-waste code: Schedule I names "Electric heating appliances" (LSEEW11) but not water heaters^[7].
• The HS line 85161000 comes from tariff listings^[6].
• Which immersion heater standard BIS expects when both IS 368 and IS 302-2-201 entries are listed^[19].