On 28 January 2025, officers from the Bureau of Indian Standards conducted a search and seizure operation at a business premises in Bhiwandi, Maharashtra. During the operation, BIS seized 367 electrical and non-electrical toys that did not carry the mandatory ISI Mark.
According to the official government release, the toys were being stored and sold without valid BIS certification. BIS also stated that a criminal complaint would be filed under the Toys Quality Control Order, 2020 and the BIS Act, 2016.
For a toy business, such action is not limited to the value of the seized stock. It can interrupt sales, block marketplace listings, affect retailer relationships and place the business owner, importer and authorised representatives under regulatory scrutiny.
This case demonstrates why BIS certification for toys in India must be completed before manufacturing, importing, storing or selling covered toys. Laboratory testing alone is not enough. The manufacturing unit, product series, testing facility, quality-control system, packaging and ISI marking must all comply with BIS requirements.
BIS certification is a conformity-assessment process through which the Bureau of Indian Standards verifies that a toy complies with the applicable Indian safety standards.
The Toys Quality Control Order, 2020 was notified on 25 February 2020. After an extension, the compulsory certification requirement became effective from 1 January 2021. The Order applies to products designed or clearly intended for play by children below 14 years of age.
Covered toys must conform to the relevant Indian Standard and carry the BIS Standard Mark under a valid licence. The licence is connected to the actual manufacturing location, the applicable standard and the product varieties included in the approved scope.
Important points include:
Toys are used by children who may pull, throw, bite, bend, swallow or misuse them in ways that adults may not anticipate. A product that appears harmless can create choking, chemical, electrical, fire or injury risks.
BIS testing considers both intended use and reasonably foreseeable use or abuse. Depending on the product, the assessment may cover sharp edges, small parts, impact strength, flammability, restricted chemicals, phthalates, electrical heating and abnormal operation.
Compliance is also important for business continuity. A valid BIS licence can support customs clearance, organised retail onboarding, e-commerce listings, distributor confidence and long-term market access.
BIS certification helps businesses address:
An Indian manufacturer producing covered toys for the domestic market must obtain a BIS licence for its manufacturing unit.
A foreign manufacturer exporting toys to India must ordinarily obtain certification under the Foreign Manufacturers Certification Scheme. The foreign factory must appoint an Authorised Indian Representative who can coordinate with BIS and fulfil responsibilities in India. BIS has operated the FMCS framework since 2000.
Importers, brand owners and retailers may not be the primary licence holders, but they must verify that the toys they purchase or import are manufactured under a valid BIS licence.
Before placing an order, an importer should verify:
An importer should not assume that European EN 71 reports, ASTM reports, CE markings or laboratory reports from another country automatically replace BIS certification.
The BIS product manual identifies 7 principal toy safety standards used for certification. These consist of 6 parts of IS 9873 and the electrical-toy standard IS 15644.
| Indian Standard | Safety Requirement | Typical Applicability |
|---|---|---|
| IS 9873 Part 1:2025 | Mechanical and physical properties | Most electrical and non-electrical toys |
| IS 9873 Part 2:2017 | Flammability | Toys with combustible materials |
| IS 9873 Part 3:2020 | Migration of certain elements | Paints, coatings, plastics and accessible materials |
| IS 9873 Part 4:2017 | Swings, slides and activity toys | Indoor and outdoor activity toys |
| IS 9873 Part 7:2017 | Finger paints | Finger-paint products |
| IS 9873 Part 9:2017 | Certain phthalate esters | Applicable plastic toys and children’s products |
| IS 15644:2006 | Safety of electric toys | Battery, transformer and dual-supply toys |
For non-electrical toys, IS 9873 Part 1 is normally the primary standard. Parts 2, 3, 4, 7 and 9 may apply as secondary standards depending on the product.
For electrical toys, IS 15644 is the primary standard. Relevant parts of IS 9873 may still apply for mechanical, chemical, flammability and physical safety.
IS 9873 Part 1:2019 has been revised as IS 9873 Part 1:2025. BIS has fixed 22 March 2027 as the withdrawal date of the 2019 version.
Existing licence holders must complete the transition before the deadline. After 22 March 2027, licences cannot continue under the old version.
The revised standard includes changes relating to warnings, folding mechanisms, electrically driven ride-on toys, sound levels and other mechanical-safety provisions.
For electrically driven ride-on toys, the revised maximum-speed structure includes:
Manufacturers of ride-on toys should review motor speed, age grading, packaging warnings and approved licence scope before moving to the revised standard.
| Regulation or Standard | Numerical Requirement | Applicable To | Main Business Risk |
|---|---|---|---|
| Toys Quality Control Order, 2020 | Effective from 1 January 2021 | Toys intended for children below 14 | Seizure and blocked sale |
| IS 9873 Part 1:2025 | Mandatory transition by 22 March 2027 | Mechanical and physical safety | Licence transition failure |
| BIS Product Manual | 2 toy types | Electrical and non-electrical toys | Wrong primary standard |
| BIS Product Manual | 7 categories and 146 subcategories | Product classification | Incorrect sample grouping |
| Sampling guideline | Normally 3 to 10 pieces | Application and scope addition | Insufficient sample quantity |
| Option-2 test report | Normally not more than 90 days old | Simplified application route | Report rejection |
| Initial licence validity | Up to 2 years | Approved varieties only | Expiry or deferment |
| Licence renewal | Up to 5 years | Existing licence holders | Loss of marking permission |
| R&D import exemption | Up to 300 samples per financial year | Eligible manufacturers | Commercial-use violation |
The numerical requirements are important because toy certification is based on exact product classification. A business cannot simply obtain one general toy certificate and use it for every model.
BIS classifies toys into 2 main types, electrical and non-electrical. These are further divided into 7 categories and 146 subcategories according to their intended purpose and function.
For certification purposes, toys may be grouped as one series when they have a similar design, are made from the same materials and fall within one subcategory.
A series may contain multiple colours, decorative changes or model variations, but the manufacturer must declare the models covered under each series. BIS records the approved series and models within the licence scope.
Incorrect grouping can increase cost and delay approval. For example, a battery-operated musical toy, a ride-on car and a plastic rattle cannot be placed in one series merely because they are sold under the same brand.
Product grouping should consider:
The BIS product manual generally requires 3 to 10 fully packaged and labelled pieces for testing. The final quantity depends on the size of the toy, applicable tests and laboratory requirements.
A manufacturer should not send loose or unfinished production pieces unless specifically permitted. Samples should normally represent the actual product that will be sold, including the packaging, model number, age grading and warnings.
Insufficient or incorrectly selected samples can result in additional sample requests, repeat courier costs and extended laboratory timelines.
Before dispatching samples, verify:
The process begins by identifying whether the product is an electrical or non-electrical toy.
The manufacturer must then determine the relevant category, subcategory, starting age, applicable standard and product series. This classification controls the laboratory tests and the final licence scope.
Errors at this stage can affect the complete application.
BIS certification evaluates both the product and the manufacturing facility.
The factory should have adequate machinery, trained quality-control personnel, calibrated test equipment, documented inspection procedures and records showing control over raw materials and finished products.
The facility should be able to demonstrate that production can remain consistent after the initial laboratory sample passes.
A factory readiness review should cover:
Under the applicable certification route, samples are tested in a BIS laboratory or a BIS-recognised or empanelled laboratory.
For Option-2 applications, the product test report should generally be no more than 90 days old when used for the application.
The testing programme may include mechanical, physical, chemical, electrical and flammability tests depending on the toy.
Common causes of test failure include:
Domestic manufacturers submit the application through the Manak Online portal.
Separate applications are required where different products are covered by different Indian Standards. A separate application is also required when the same product is produced at different manufacturing locations.
The online application must contain consistent company, factory, product and technical information.
BIS reviews the application and conducts a factory inspection.
The officer may verify manufacturing infrastructure, production controls, test facilities, calibration records, quality-control personnel and product-testing capability.
Samples may also be drawn for independent testing. Any difference between the declared process and the actual factory arrangement can generate queries or require corrective action.
BIS reviews the application, factory-inspection findings, laboratory reports and fee payments.
The official average timeline is generally 1 month under Option-2 and 4 months under Option-1, calculated from the date on which a complete application is received and recorded. Actual processing may take longer where queries, inspections, sample deposition or payments are delayed.
The licence is initially granted for up to 2 years and is valid only for the varieties mentioned in the approved scope. It may subsequently be renewed for up to 5 years.
| Step | Responsible Entity | Numerical Timeline or Requirement | Main Risk |
|---|---|---|---|
| Product classification | Manufacturer | Complete before testing | Wrong standard selection |
| Sample preparation | Manufacturer | Normally 3 to 10 pieces | Repeat sampling |
| Option-2 test report | BIS-recognised laboratory | Generally valid for up to 90 days | Expired report |
| Online application | Manufacturer | Separate application per product and standard | Application rejection |
| Application processing | BIS | Around 1 month under Option-2 | Delay due to queries |
| Application processing | BIS | Around 4 months under Option-1 | Testing and inspection delay |
| Initial licence | BIS | Up to 2 years | Limited model scope |
| Renewal | BIS | Up to 5 years | Licence deferment |
| Revised standard transition | Manufacturer | By 22 March 2027 | Old-standard licence closure |
These timelines are not automatic guarantees. They begin after a complete application has been accepted and recorded by BIS.
Incomplete documents, unsuitable test reports, incorrect model grouping and factory-readiness gaps can extend the process.
The exact document list depends on whether the applicant is an Indian or foreign manufacturer.
The application should demonstrate the legal identity of the manufacturer, control over the manufacturing facility, technical capability and traceability of the toys.
Typical documents include:
Foreign manufacturers may also require:
All names and addresses should remain consistent across the factory records, test reports, application forms and packaging.
The total cost of BIS certification varies according to the number of product series, applicable standards, testing requirements and factory location.
BIS specifies an application fee of Rs. 1,000. The preliminary inspection fee is Rs. 7,000 per man-day. After approval, the applicant must pay an annual licence fee of Rs. 1,000, along with the applicable minimum marking fee.
Laboratory-testing charges are separate and depend on the number of applicable standards, samples and tests.
The overall budget may include:
A quotation should clearly state whether retesting, additional samples, factory modifications and new model inclusion are covered.
A 2024 amendment introduced a limited exemption for research and development samples.
An eligible BIS-certified manufacturer, or a manufacturer that has already applied to BIS, may import up to 300 toy samples per financial year, subject to a maximum of 5 samples of each type.
These samples cannot be sold commercially. They must ultimately be disposed of as scrap, and the manufacturer must maintain year-wise records and submit the required declaration to DPIIT.
The exemption should not be used for trial selling, distributor sampling or commercial market testing.
Key conditions include:
After receiving the licence, the manufacturer may apply the BIS Standard Mark only to approved products that conform to the relevant standards.
The licence number is normally displayed in the CM/L format. The product and packaging should also carry applicable model details, age grading, warnings, instructions and statutory declarations.
A licence granted to one factory cannot automatically be used by another factory. A CM/L number also cannot be used on product models that are outside the approved scope.
Before production release, the packaging team should verify:
The Bhiwandi enforcement action provides a practical compliance lesson for manufacturers, importers and sellers.
On 28 January 2025, BIS officers inspected a business and seized 367 toys without the mandatory ISI Mark. The seized stock included both electrical and non-electrical toys. BIS stated that the products were being stored and sold without valid certification and that a criminal complaint would be filed.
From a business owner’s perspective, the problem does not begin on the day of the raid. It usually begins much earlier, when purchasing, product testing and packaging decisions are made without verifying the manufacturing unit’s BIS status.
The case shows why a seller should never rely only on a supplier’s verbal assurance, foreign test report or image of an ISI logo. The CM/L number, factory name, licence validity and approved product scope must be independently checked.
The practical lessons are:
Section 17 of the BIS Act restricts the manufacture, import, distribution, sale, storage and exhibition for sale of covered products without compliance with the applicable standard and certification requirements.
BIS certification officers have powers to inspect, search and seize goods and relevant documents where a violation is suspected.
A violation of Section 17 may result in imprisonment for up to 2 years. The minimum fine is Rs. 2 lakh for the first contravention and Rs. 5 lakh for the second or subsequent contraventions. The fine may extend to 10 times the value of the affected goods.
Business consequences can include:
The penalty provisions for toy certification arise primarily under the BIS Act, 2016 and the Toys Quality Control Order. Section 15 of the Environment Protection Act, 1986 is not the principal penalty provision for BIS toy certification.
A BIS consultant should support more than document uploading.
The most important work is usually completed before the application is filed. This includes product classification, series planning, laboratory selection, factory-gap assessment and packaging review.
A structured approach can prevent repeated testing, incorrect applications and models being left outside the licence scope.
Professional support may include:
BIS certification for toys in India is not a one-time laboratory formality. It is a continuing system of product testing, manufacturing control, factory inspection, correct marking and market surveillance.
The certification framework covers 2 toy types, 7 categories, 146 subcategories and 7 principal safety standards. Samples generally range from 3 to 10 pieces, Option-2 reports should generally be within 90 days, initial licence validity may be up to 2 years, and renewal may be granted for up to 5 years.
Businesses should also prepare for the transition to IS 9873 Part 1:2025 by 22 March 2027. Waiting until the deadline may create testing, packaging and licence-scope difficulties.
The cost of early compliance is usually far lower than the financial and operational impact of seized inventory, blocked imports, product recalls or criminal proceedings. A well-planned application protects both children and the long-term commercial interests of the business.
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Yes. Covered toys intended for children below 14 years must comply with the applicable Indian Standards and carry the BIS Standard Mark under a valid licence.
IS 9873 Part 1 is normally the primary standard. Parts 2, 3, 4, 7 and 9 may also apply depending on the materials, design and use of the toy.
IS 15644:2006 is the primary standard for electrical toys. Relevant parts of IS 9873 also apply for mechanical, chemical and flammability safety.
The BIS product manual generally specifies 3 to 10 fully packaged and labelled samples. The laboratory may require additional pieces depending on the product and tests.
