Mandatory BIS and DGFT Compliance for Importers of Electronic Goods

When Rohit Sharma, an electronics importer from Bengaluru, shipped a new batch of smart watches in early 2025, his plan was to launch by the Republic Day sale. Instead, his consignment sat at port for three weeks — flagged for missing BIS-CRS registration and DGFT authorization. Customs wouldn’t clear it, BIS hadn’t validated the test report, and the packaging lacked the mandatory EPR barcode.

Rohit’s story is increasingly common. As India tightens its trade and sustainability standards, importers of electronic goods must now navigate a triple-layer compliance regime — DGFT import authorizations, BIS certification, and EPR obligations.

This guide breaks down the new 2025 rules, product categories, and a step-by-step compliance roadmap so your imports don’t get stuck at the dock.

Why 2025 Is a Turning Point for Importers

The last two years have completely redefined import compliance for electronics:

• DGFT’s new Import Management System (IMS) now restricts laptops, tablets, and IT hardware under the HSN 8471 category. Importers must secure DGFT authorization before every consignment.
• BIS expanded its Compulsory Registration Scheme (CRS) to over 80 categories of IT and electronic equipment — from chargers and LEDs to CCTV systems.
• CPCB’s EPR mandates now make importers legally responsible for the lifecycle of the goods they introduce — including electronic, plastic, and battery waste.

Together, these regulations aim to improve product quality, data security, and environmental accountability — but they also mean that every importer must coordinate licensing, testing, and packaging compliance from the start.

DGFT’s Restricted Import List & IMS Authorization

The Directorate General of Foreign Trade (DGFT) has reclassified several IT and electronic products as “restricted”, requiring prior authorization through the Import Management System (IMS) portal.

Products now restricted under HSN 8471:

Product Category	HS Code	Authorization Required	Validity / Notes
Laptops, Tablets, Personal Computers, Servers	8471	IMS Import Authorization from DGFT	Valid till Dec 2025
Ultra-small form factor computers & mini PCs	8471 sub-set	Same DGFT approval route	Application portal active 2024–25

What it means for business:
No DGFT license = no customs clearance. Importers must apply early, upload product details, supplier invoices, and BIS certificates, and track approval on the IMS portal.

Failing to secure authorization can result in:

• Shipment detention or re-export orders
• Loss of demurrage + warehouse costs
• Suspension of IEC (Import Export Code)

Tip: Keep BIS and DGFT filings synchronized. The DGFT portal cross-references BIS registration numbers for electronics under the CRS category.

BIS-CRS Registration — India’s Quality Gate

Under the Compulsory Registration Scheme (CRS) of the Bureau of Indian Standards (BIS), importers must ensure that every model of notified electronics meets Indian safety and performance standards before it enters the market.

Key Product Categories (as of 2025)

• Mobile phones, smartphones, and feature phones
• Laptop computers and tablets
• Power banks, chargers, and USB adaptors
• LED lighting modules and bulbs
• CCTV systems and set-top boxes
• Smart speakers, routers, and wearables

Registration Process (simplified):

1. Testing: Send product samples to a BIS-recognized laboratory for compliance with relevant IS standards.
2. Application: File online at www.crsbis.in with reports, technical files, and brand ownership documents.
3. Marking: Affix BIS logo + CRS registration number on product and packaging.
4. Renewal: Valid for two years; renewal requires new test report.

For foreign manufacturers, registration is done under the Foreign Manufacturer Certification Scheme (FMCS) via an Authorized Indian Representative (AIR).

Example: A Chinese OEM producing smart TVs for Indian brands must register through FMCS; the Indian importer acts as AIR for correspondence with BIS and DGFT.

Customs Enforcement

Indian Customs now verifies BIS numbers through the ICEGATE system. Shipments without valid registration are detained for re-testing or re-export. In 2024 alone, BIS and DGFT jointly stopped over 1,500 non-compliant consignments, mostly of lighting and IT hardware.

BIS CRS Stage	Typical Timeline	Common Delays / Risks	Mitigation
Product Testing	2–3 weeks	Lab backlogs / re-sample failures	Engage BIS-recognized labs early
Application Review	2–4 weeks	Incomplete technical files	Hire experienced compliance consultant
Label Approval / Marking	1 week	Design revision or printing errors	Pre-approve artwork with BIS
Renewal / Amendment	1–2 weeks	Change in model or supplier	Plan overlap period before expiry

EPR Compliance: The Third Pillar of Import Regulation

Importers are now treated as “producers” under India’s Extended Producer Responsibility (EPR) framework. This means they must take responsibility for collection, recycling, and safe disposal of the electronic goods — and their packaging — once they reach end-of-life.

Key EPR Regulations Affecting Importers

Waste Type	Relevant Rules / Year	2025 Highlights
E-Waste	E-Waste (Mgmt) Rules 2022	Mandatory EPR registration on CPCB portal; quarterly returns; tie-up with registered recyclers
Battery Waste	Battery Waste Mgmt (Amendment) Rules 2025	Barcode or QR code with EPR No. on battery packs and equipment
Plastic Packaging	Plastic Waste Mgmt (Amendment) Rules 2025	Barcode or QR code on plastic packaging from July 2025

What you must do:

• Register on CPCB’s EPR portal (eprplastic.cpcb.gov.in / eprewastecpcb.in / eprbatterycpcb.in).
• Obtain unique EPR number for each product stream.
• Print barcode / QR code on product packaging linked to your EPR registration.
• File quarterly and annual returns showing collection and recycling data.

Non-Compliance Risks

• Customs hold for missing barcodes
• Environmental Compensation up to ₹1 lakh per MT of waste
• Suspension of import license by DGFT for persistent violations

Advisory: Green Permits simplifies EPR registration and connects importers with authorized recyclers for e-waste, plastic, and battery streams — reducing long-term liability.

Integrated Compliance Roadmap

Below is a practical business roadmap that aligns DGFT, BIS, and EPR obligations.

Stage	Compliance Action	Approx. Time Frame	Business Impact if Ignored
1. Pre-Import Due Diligence	Identify if product is restricted under DGFT IMS and listed under BIS-CRS; map EPR stream.	1 week	Incorrect classification → license rejection.
2. DGFT Authorization	Apply on IMS portal with BIS test report and supplier details.	2–4 weeks	Shipment blocked at Customs.
3. BIS Registration (CRS / FMCS)	Submit application & label approval; print BIS mark.	4–6 weeks	Goods re-exported / penalties.
4. EPR Registration + Barcode	Register on CPCB portal; print EPR QR code on packaging.	2–3 weeks	Port rejection / EC fines.
5. Customs Clearance & Returns	Submit DGFT license + BIS + EPR proof at Customs; file returns quarterly.	Ongoing	Audit notices / blacklisting.

Interpretation:
Build a two-month buffer between purchase order and shipment to accommodate licensing, testing, and labeling.

Risks and Penalties of Non-Compliance

Violation	Penalty / Consequence
Importing without BIS certificate	Detention, re-export, fine under BIS Act ₹2 lakh + per day continuing offence
Import without DGFT IMS license	Goods confiscated or held until authorization is produced
Missing EPR barcode on packaging	Environment Compensation by CPCB + public notice of defaulters
False documentation / lab reports	Blacklisting for future imports + criminal proceedings under EPA 1986

Real-World Example: In late 2024, a Delhi importer’s consignment of LED drivers worth ₹1.2 crore was re-exported after Customs found the BIS certificate belonged to a different model series.

Best Practices for 2025 and Beyond

• Start early: Initiate BIS testing and DGFT license applications before placing orders.
• Integrate compliance into design: Ensure packaging can accommodate QR / EPR codes and BIS mark.
• Track deadlines: Renew BIS certificates every two years and EPR returns quarterly.
• Work with registered recyclers: It reduces your EPR burden and audit risk.
• Engage professionals: Green Permits provides end-to-end support for BIS, DGFT, and EPR compliance.

Conclusion

The 2025 regime leaves little room for shortcuts. Whether you import smartphones, tablets, or power banks, BIS certification, DGFT authorization, and EPR barcoding are now interlinked prerequisites for market access.

Early registration and proactive planning can cut weeks off your supply chain, avoid costly demurrage, and protect your brand from penalties.

At Green Permits Consulting, we help importers simplify every stage — from BIS testing and DGFT licensing to EPR setup and reporting.

📞 +91 78350 06182 | 📧 wecare@greenpermits.in
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