Toys (Quality Control) Order, 2020: which toys need the ISI mark, the standards, customs sampling, exemptions and status in 2026

It is the order that makes BIS certification compulsory for toys in India. Its full title is the Toys (Quality Control) Order, 2020^[1]. It was notified as S.O. 853(E) dated 25 February 2020^[1] by the Department for Promotion of Industry and Internal Trade (DPIIT) in the Ministry of Commerce and Industry, under sections 16, 17 and 25(3) of the BIS Act, 2016^[1].

The order requires toys to conform to the listed Indian Standards and to carry the ISI mark under a BIS Scheme-I licence^[1]. BIS is both the certifying and the enforcement authority^[1]. For an importer, the short version is: if it is a toy, the factory that makes it needs a BIS licence for it, and each piece you bring in must carry the ISI mark under that licence.

Toys also sit under a second, older import rule from DGFT that samples every consignment at the port (see below). For the step-by-step import route see import toys, and for sourcing from the largest supplier country see importing toys from China.

The order applies to products or materials designed or clearly intended, whether or not exclusively, for use in play by children under 14 years of age. It covers them as first received and after reasonably foreseeable use and abuse^[1].

The test is intent and design, not what the product is called on an invoice. A product marketed partly to adults but clearly meant for children's play is still caught by the words “whether or not exclusively”. Items commonly asked about include:

• Plush, plastic, wooden and ride-on toys. Covered when designed for play by children under 14.
• Electric and battery toys. Covered, and they need the electric toy standard IS 15644 as well^[1].
• Swings, slides and similar activity toys. Covered by IS 9873 Part 4.
• Finger paints. Covered by IS 9873 Part 7.
• Adult collectibles, puzzles for adults and sports equipment. Whether these fall outside depends on how they are designed and marketed. The order gives no list, so where a product is borderline, ask BIS before you ship.

For electronics that are also toys, the toy order and the electronics CRS order can both be relevant; see the electronics CRS order for products such as electronic video games, which BIS lists under CRS^[8].

The order text lists no HS codes^[1]. Coverage is defined by the product description, not by a tariff heading. Toys are normally declared under heading 9503, and the 8-digit lines are reported as below^[9]; confirm the line with your customs broker or the HS code approval finder.

The DGFT side is wider still. Since December 2019 the import policy says toys, dolls and similar recreational goods imported under any chapter are governed by BIS standards^[10]. So declaring a toy outside Chapter 95 does not take it out of the rules. Customs officers and BIS look at what the product is; if your classification and the product's obvious use point in different directions, expect questions at the port.

Every toy consignment is sampled, in addition to the ISI-mark rule. DGFT Notification 33/2015-20 of 2 December 2019 requires a sample to be picked at random from each consignment and sent to an NABL-accredited lab; customs may release the goods only on condition they are not sold until the sample passes, and failed goods are sent back or destroyed at the importer's cost^[6].

Each custom house runs this through its own public notice. At JNCH, Nhava Sheva, the importer or customs broker gives a No Use Bond equal to the assessable value with the Bill of Entry, a sample of each toy type is drawn at examination, and the test report is due within two months of assessment^[10]. JNCH nominated six labs in 2019^[10]; other ports name their own. The documents to prepare are on the customs clearance checklist.

Toys must conform to IS 9873 Parts 1, 2, 3, 4, 7 and 9, and electric toys to IS 15644:2006^[1]. The order lists IS 9873 (Part 1):2018 and Parts 2, 3, 4, 7 and 9 of 2017, with a note that the latest version and amendments notified by BIS apply.

The editions move on. BIS's November 2023 toys manual certifies against IS 9873 (Part 1):2019, Part 3:2020 and the 2017 editions of the other parts^[13], and in April 2026 BIS ran an industry session on IS 9873 (Part 1):2025^[7]. For certification BIS treats non-electric toys as licensed against Part 1 with the other parts as secondary standards, and electric toys against IS 15644 with the IS 9873 parts as secondary^[14]. Toys are grouped into 7 categories and 146 sub-categories, and similar toys of the same materials in one sub-category form one series^[14]. See IS 9873 Part 1.

The order was first due on 1 September 2020^[1], but S.O. 3146(E) of 15 September 2020 pushed it back to 1 January 2021^[2]. The later amendments in our sources add exemptions^[4][3] rather than further delays.

The exemptions are narrow. In our sources they are:

• Exports. The order does not apply to goods or articles meant for export^[1].
• Registered artisans and GI producers. Goods made and sold by artisans registered with the Development Commissioner (Handicrafts), and by registered proprietors or authorised users of products registered as Geographical Indications, are exempt^[4]. This helps traditional Indian toy makers; it does not help importers.
• Research and development imports. A BIS-certified manufacturer, or one that has applied, may import up to 300 units per financial year, with no more than 5 per sample type, for R&D. The units cannot be sold, must be scrapped, and records go to DPIIT^[3].

There is no small-business relief that we could find. Our review of the four amendment texts BIS lists found no MSME-specific deferral or exemption; this is our reading of what the texts do not say, not an official statement^[5]. A small importer bringing in a few hundred toys needs the same licensed, marked product as a large one.

Relief for small firms is administrative and fee-based, not an exemption from the order. Our review of the amendment texts found no MSME exemption or deferral in the QCO itself^[5].

• Testing relaxation for micro units. BIS notified special provisions on 17 December 2020 to license micro toy units without their own testing facility for one year, later extended by three years^[16]. We have not found the end date of the extension. Since December 2025 BIS no longer requires an in-house lab for most products in any case^[17].
• Marking fee concession. From 17 March 2026 to 31 May 2029, micro enterprises pay 80% less than the large-firm minimum, small ones 50% less, with an extra 10% for women-led firms^[18]. The micro figures in the fee table above reflect this.
• Artisans and GI producers. Exempt altogether^[4].

None of this helps an importer directly: the goods still need a licensed factory and the ISI mark.

On 25 June 2026 DPIIT issued the Transition Facilitation (Quality Control) Order, 2026, S.O. 3417(E). It allows DPIIT to permit companies incorporated under the Companies Act, 2013, after assessment by an Implementation Committee, to source goods under ten scheduled QCOs using BIS Scheme-II licences^[15]. The Toys QCO is entry 1 of that Schedule, listed with an issue date of 25 February 2020 and implementation on 1 January 2021^[15].

Applications are accepted for 24 months from commencement, and the order lapses after five years unless extended; DPIIT is to issue detailed guidelines^[15]. We have not found those guidelines, so we cannot say who will be approved or on what terms.

What it does not do: it is not a general exemption. It applies only to companies DPIIT specifically permits. The 2026 changes across all QCOs are summarised on QCO changes in 2026. Until you hold such a permission, assume the normal ISI-mark rule applies to every toy you import.

Not in the Toys QCO. The order took effect on 1 January 2021^[2] and its amendments added exemptions, not sell-off periods^[4][3]. DPIIT's February 2026 shipped-before and purchase-order exemptions cover QCOs notified in 2024 and 2025^[19], not this 2020 order. The only 2026 transition tool is the Transition Facilitation Order, available to DPIIT-permitted companies only^[15].

At the port, goods released under the DGFT rule are under a no-sale condition until the sample passes^[6], so plan stock arrival dates around lab turnaround. Check dates with the QCO deadline checker and see the full list in our QCO orders dataset.

Yes. As of October 2026 the order is in force, implemented since 1 January 2021. BIS's Scheme-I list shows no rescission, and the latest instrument it links is the Transition Facilitation Order of 25 June 2026^[5].

The toys order was not among the QCOs rescinded in late 2025. Those rescissions hit chemicals, polymers, fibres and metals, such as the 14 orders withdrawn on 12 November 2025^[20]. For the full list, see the QCO tracker.

Sharply. BIS had granted 1,786 toy licences to domestic manufacturers and 56 to foreign manufacturers by May 2026^[7]. Our count of BIS's FMCS list on 30 October 2026 found 60 operative foreign toy records, led by Vietnam with 28 and Thailand with 10, and none for a factory in China^[21][22].

The government links the QCO, the DGFT sampling rule and higher duty to falling imports: a DPIIT-commissioned study found toy imports down 52% and exports up 239% in FY 2022-23 against FY 2014-15^[16], and the government now reports a toy trade surplus of US$ 152 million in 2025-26^[7]. China still supplies parts: parts of electronic toys were the largest 9503 line from China in 2025-26, at US$ 35.31 million^[23].

The licence is held by the factory, not by you. A factory in India applies for a Scheme-I licence; a factory abroad applies through BIS's Foreign Manufacturers Certification Scheme (BIS FMCS). The steps below follow the official BIS process. A BIS consultant can run the factory's application; BIS samples are tested at BIS or recognised labs in India^[24], such as those on BIS labs in Delhi NCR.

For a Scheme-I licence, the BIS FAQ lists an application fee of Rs 1,000, an inspection fee of Rs 7,000 per man-day before the preliminary visit, and after the grant decision an annual licence fee of Rs 1,000 plus the product's minimum marking fee^[25]. Toys pay marking fees only on the primary standard: IS 9873 (Part 1) for non-electric toys and IS 15644 for electric toys^[29][14].

Foreign factories pay the same fees as domestic Scheme-I manufacturers, plus per-diem charges, travel, visa and insurance costs for BIS officers and a Rs 10,000 contingency fund payment^[30]. After grant, a foreign licensee also furnishes a Performance Bank Guarantee of USD 10,000^[27]. Testing charges are separate, and on top of BIS testing each import consignment is lab-tested under the DGFT rule^[6]. The full fee rules are on ISI mark fees and FMCS fees; the compliance cost estimator puts them together.

A first-time importer of plush and plastic toys. You find a factory with good prices but no BIS licence. You cannot fix that from India: the licence has to be granted to the factory, and for a foreign factory that means an FMCS application, a BIS factory inspection and sample testing^[27]. BIS gives about six months as the average FMCS grant time^[27]. Your realistic options are to wait for the factory's licence or to buy from a factory that already holds one for the right IS 9873 parts.

A marketplace seller adding battery-operated toys. Your existing supplier is licensed for non-electric toys. An electric toy also needs IS 15644^[1], and a Scheme-I licence covers only the standard and factory it was granted for^[25]. Ask for the licence scope in writing before you list the new range.

A foreign toy brand entering India. The brand's own factory, or each contract factory, needs its own licence. The factory nominates an Authorised Indian Representative^[26] and, after grant, gives BIS a USD 10,000 Performance Bank Guarantee^[27]. If the brand is an Indian-incorporated company, it may also watch the Transition Facilitation Order, which could allow sourcing under a Scheme-II licence if DPIIT grants permission^[15]; that is not available until permission is given.

An importer comparing source countries. With no Chinese toy factory on the FMCS list^[22], a buyer who needs a licensed finished toy now looks at Vietnam or Thailand, which hold most foreign toy licences^[21]. Parts of electronic toys for Indian assembly face a 20% tariff rate instead of 70%^[12], which is why many brands now import parts from China and assemble in India.

Marking fee arithmetic. A large factory making 5,00,000 non-electric toys owes Rs 2,250 on the IS 9873 unit rate of Rs 4.5 per 1,000 pieces, so it pays the Rs 98,000 minimum^[29]. An electric-toy factory making 25,00,000 pieces owes Rs 2,00,000 at Rs 80 per 1,000, above the Rs 1,46,000 minimum^[31].

Most problems are paperwork mismatches, not failed tests:

• No ISI mark on the goods. Every piece must carry the ISI mark under a Scheme-I licence^[1]. A licence on file does not help if the goods themselves are unmarked.

• Licence does not match the product or factory. The licence covers a particular standard and factory location^[25]. Goods made in a sister factory, or a toy type outside the licence scope, are not covered.

• Electric toys certified only to IS 9873. Electric toys need IS 15644 as well^[1].

• Samples treated as R&D imports. The R&D allowance is only for BIS-certified or applicant manufacturers, capped at 300 units a year and 5 per type, and the goods must be scrapped^[3]. A trader's sales samples do not qualify.

• Relying on the Transition Facilitation Order without a permission. It applies only to companies DPIIT specifically permits^[15].

• Selling before the customs lab report. Goods released under the DGFT rule may not be sold until the sample passes^[6].

• Retail packs without LMPC declarations. Pre-packaged toys are likely to need importer registration under the LMPC Rules^[32]; see LMPC importer registration.

• Electronic games treated as toys only. Some electronic games and consoles have separate e-waste codes^[33]; see e-waste EPR.

For port-side delays more generally, see why shipments get held at Indian ports. If you are bringing in pre-production samples, read importing samples for BIS testing first.

Section 17 of the BIS Act prohibits importing, selling, storing or exhibiting for sale notified goods without a Standard Mark under a valid licence^[28]. A contravention is punishable with imprisonment of up to two years, or a fine of not less than Rs 2 lakh for a first offence and not less than Rs 5 lakh for later ones, extendable to ten times the value of the goods, or both^[28]. Importers are directly bound because the Act's definition of “person” includes them^[28].

BIS also runs market surveillance by buying ISI-marked samples for third-party testing^[25], so a licence is not the end of the story: the product you sell has to keep meeting the standard.

At the border the DGFT rule adds its own sanction: a failed sample means the consignment is re-exported or destroyed at your cost^[6]. On marketplaces, have your licence and marking evidence ready before listing; see the Amazon listing checklist. For a review of your own toy range, ask for a free compliance check.