Common Mistakes to Avoid During BIS CRS Application Process

Introduction – When Compliance Meets the Clock

Last year, an electronics importer in Noida faced a two-month delay in customs clearance for a shipment of smart adapters. The issue was simple but costly: the BIS CRS registration file had been submitted with an incorrect test report upload. By the time the corrected certificate arrived, the importer had missed the retail season and lost valuable market time.

In today’s compliance-driven market, mistakes in the BIS Compulsory Registration Scheme (CRS) process can lead to heavy losses, shipment detention, or even product seizure. Whether you are an Indian manufacturer or an importer, avoiding these errors can save time, money, and reputation.

Understanding the BIS CRS Scheme

The Compulsory Registration Scheme (CRS) under BIS Scheme II applies to electronics and IT products notified by the Ministry of Electronics & Information Technology (MeitY). Every manufacturer or importer must:

• Get the product tested in a BIS-recognised laboratory.
• Register the model with BIS before sale or import.
• Mark the product with the Standard Mark and R-number (or an approved e-label).

As of 2025, more than 80 product categories—from LED lamps and mobile adapters to smart TVs—are covered under CRS.

Mistake 1 – Selecting the Wrong Indian Representative

Foreign manufacturers must appoint an Authorised Indian Representative (AIR) to handle the BIS CRS registration. A mismatch between AIR details in the BIS application, IEC, or GST certificate often leads to rejection.

Avoid it:

• Choose an Indian entity with valid GST registration and legal presence.
• Use the same name and address across IEC, GST, and BIS documents.
• Ensure the AIR understands post-approval duties such as renewals and surveillance.

An incorrect AIR declaration can result in customs detentions and demurrage charges.

Mistake 2 – Using a Non-Recognised Test Laboratory

Only laboratories recognised by BIS can test CRS products. Submitting reports from unlisted or expired-license labs voids the results.

Avoid it:

• Confirm the lab’s recognition and validity for your product’s IS standard (e.g., IS 13252 for IT equipment).
• Request direct digital upload of the test report to the BIS portal.
• Keep copies of sample submission receipts for traceability.

Mistake 3 – Inconsistent or Incomplete Documentation

Roughly one-third of rejected applications show inconsistent details, such as:

• Address mismatch between GST and Test Report.
• Brand name differences between product labels and application forms.
• Product photos not matching the tested sample.

Before you submit, check:

• Updated GST certificate and PAN card.
• CTE/CTO documents (for Indian manufacturers).
• Import Export Code (IEC) for importers.
• Test Report number and date identical in all forms.
• User manual or catalogue displaying model number and brand.

Mistake 4 – Incorrect Use of the BIS Logo or R-Number

Some companies start printing the BIS mark before their registration number is issued. This constitutes a violation under the BIS Act 2016 and may lead to seizure or a fine of up to ₹ 2 lakh.

CRS Label Checklist (2025)

Item	Requirement	Common Error	Correct Action
Standard Mark	Must read “Self-Declaration – Conforming to IS xxxxx (R-xxxxxx)”	Only R-No printed	Add IS standard and R-number together
e-Labelling	Allowed for devices with display screens	Label not shown in menu	Display within three menu steps or startup screen
Packaging Mark	BIS mark and R-number required on outer box	Carton missing label	Print or sticker on package
User Manual	Must contain mark and IS No.	Not included in digital manual	Insert before submission to BIS

Mistake 5 – Submitting Expired Test Reports

A BIS test report remains valid only 90 days from its issue date. Delays in document collection can push it beyond this limit.

Avoid it:

• Collect all documents before testing.
• Submit the application within the 90-day window.
• Track expiry dates on the BIS portal dashboard.

Mistake 6 – Ignoring Latest Notifications and CRO Updates

MeitY frequently expands the CRS product list through new Compulsory Registration Orders (CROs).
In 2025, categories like smart controllers, adapters, and TVs over 105 inches were added.

Avoid it:

• Review the CRSBIS notification page each month.
• Start testing for new models as soon as draft CROs appear.
• Watch for extension notices that shift implementation dates.

Mistake 7 – Missing User-Manual and E-Label Requirements

According to the 2024 e-labelling guideline, devices with display screens must show the BIS mark digitally and repeat it in the user manual. Products without a screen must carry a permanent label on the body and packaging.

Avoid it:

• Display the R-number and IS standard in the settings menu.
• Match the numbers in manual and on the box.
• Upload a PDF manual with the application.

Mistake 8 – Overlooking Renewal and Surveillance Duties

CRS registration is valid for two years. The Software Technology Parks of India (STPI) regularly conducts market surveillance by purchasing samples for verification.

Avoid it:

• Apply for renewal at least 30 days before expiry.
• Keep a reference sample ready for inspection.
• Maintain production and testing records for audit.

Non-compliance can result in suspension or removal from the BIS CRS portal.

Mistake 9 – Confusing BIS CRS with ISI Certification

CRS and ISI are two separate schemes with different procedures.

Parameter	BIS CRS (Scheme II)	ISI Mark (Scheme I)
Coverage	Electronics and IT Goods	Industrial and Engineering Products
Testing	Third-party lab testing	Factory inspection by BIS officials
Validity	2 years (renewable online)	1 year (after audit)
Marking	R-number label	ISI logo with CM/L number

Applying under the wrong scheme causes delays and resubmission.

Mistake 10 – Underestimating Time and Coordination

Even well-prepared applications need time for testing and approval.

Typical BIS CRS Timeline (2025)

Stage	Duration (Business Days)	Responsible Party
Product Testing in Recognised Lab	15 – 25	BIS-approved Lab
Application Review and Clarifications	10 – 15	BIS Evaluator
Registration Number Issuance	5 – 7	BIS Scheme-II Division
Total Estimated Time	30 – 45 Days

Delays in clarifications or report uploads can extend the process to 60 days. Plan the BIS application well before product launch.

Penalties and Compliance Risks

Under the BIS Act 2016 and Rules 2018, selling or importing non-registered goods can lead to:

• Fines up to ₹ 2 lakh and seizure of goods.
• Import restrictions by DGFT for unregistered models.
• Brand reputation damage from recall or public notice.

Always verify your R-number on the official CRS portal before shipment or customs clearance.

How Green Permits Assists with BIS Compliance

Green Permits Consulting offers end-to-end support for manufacturers and importers throughout the BIS process:

• Coordination with recognised testing labs and BIS officials.
• Detailed document review before submission.
• Renewal and surveillance management to avoid suspensions.
• Importer support for AIR nomination and customs clearance.

Contact Green Permits

BIS certification is not just a paperwork step—it is your product’s passport to the Indian market. Green Permits helps businesses achieve faster, error-free registrations and smoother import approvals.

Phone: +91 78350 06182
Email: wecare@greenpermits.in
Book a Consultation with Green Permits today.