A Story Every Importer Can Relate To
Picture this:
A Delhi-based electronics importer proudly secures a bulk order of refurbished printers from Germany. The deal is good, margins are solid, and customers are waiting.
But when the shipment lands at Mumbai Port, Customs halts it—citing DGFT authorisation missing under restricted category goods.
By the time the paperwork catches up, the importer has spent lakhs on demurrage and watched a full month slip away.
This is not rare anymore—it’s the reality many Indian importers are facing in 2025, where trade and environmental compliance now go hand in hand.
Why DGFT Tightened Its Grip in 2025
Over the past decade, India has emerged as one of the world’s largest markets for used and refurbished electronics. However, that boom brought a darker side—unregulated imports, toxic components, and a flood of e-waste that bypassed the country’s recycling ecosystem.
To control this, the Directorate General of Foreign Trade (DGFT) now works hand-in-hand with the Ministry of Environment (MoEFCC), CPCB, and BIS to ensure that imported goods are safe, traceable, and environmentally responsible.
The 2025 policy introduces three major shifts:
- Imports of used, refurbished, or reconditioned electronic items are now officially classified as “restricted.”
- Every importer must obtain DGFT import authorisation, BIS registration, and EPR (Extended Producer Responsibility) approval.
- Products and packaging must carry traceable QR codes or barcodes connected to the importer’s EPR registration.
In short: no certificate, no clearance.
Understanding the Language of the Law – “Used” vs. “Refurbished”
Many businesses still trip up on these three terms. Here’s the difference in plain words:
| Term | What It Means | Regulatory View |
|---|---|---|
| Used / Second-Hand | Any product that has already been operated or owned before resale. | Import restricted; requires DGFT licence and compliance with BIS & CPCB norms. |
| Refurbished | Equipment repaired or restored to extend its life with minor replacements or servicing. | Allowed, but only if tested, certified, and declared under refurbished category in import documents. |
| Reconditioned | Products extensively repaired or overhauled to near-new condition. | Treated the same as “used” — restricted import requiring prior DGFT approval. |
For regulators, the label matters less than the lifecycle.
If an item has been in use before, it must enter India through the compliance channel.
The New Compliance Roadmap — What Importers Must Do
Navigating India’s trade laws can feel like walking a maze. The good news? Once you understand the flow, it’s predictable and manageable.
Before Import
The preparation starts long before the shipment leaves the supplier’s country.
- Check the ITC (HS) Code of your product to confirm whether it’s under “Restricted” or “Prohibited” category.
- Apply for DGFT Import Authorisation online under the Restricted Imports – Used Electronics section.
- Secure BIS Certification under the Compulsory Registration Scheme (CRS) or ISI Mark (depending on product type).
- Obtain EPR Authorisation via the CPCB portal (https://eprewastecpcb.in) to declare how you’ll manage end-of-life waste.
- For refurbishers and recyclers, ensure valid CTE/CTO from your State Pollution Control Board.
This paperwork is your license to trade. Without it, the consignment cannot legally enter India.
At the Port
When your consignment reaches Customs:
- Ensure BIS certificate numbers and EPR registration IDs appear clearly on invoices, labels, and packaging.
- Keep copies of CPCB registration and testing certificates ready for inspection.
- From 2025 onwards, every package must carry a QR code linking it to the EPR registry—enabling real-time tracking from port to recycler.
Customs officials now use digital verification systems, so even minor data mismatches can lead to delays or detention.
What Happens If You Skip Compliance
The financial and operational consequences of skipping even one compliance step are severe—and often underestimated.
| Violation | Outcome | Impact |
|---|---|---|
| Import without DGFT Licence | Shipment confiscation or forced re-export | 1–2 months delay, high storage fees |
| No BIS Certification | Customs sends items for lab testing | Additional ₹1–2 lakh testing + re-labelling |
| Missing EPR Registration | Penalty under Environment Act | ₹5 lakh fine and blacklisting from CPCB portal |
| No QR Code / Traceability | Blocked entry under 2025 PWM/BWM amendments | Repackaging and relabelling cost ₹50,000–₹1 lakh |
Every detained shipment is more than lost money—it’s lost reputation. For many MSMEs, one such incident can break an entire trading cycle.
The Numbers Behind the Policy
| Indicator | India 2024–25 Snapshot |
|---|---|
| Annual e-waste generated | 1.6 million tonnes |
| Portion linked to imported electronics | ~12% |
| DGFT licences for refurbished imports | Over 1,200 active |
| BIS-registered electronic models | Above 23,000 |
| Customs penalties for unauthorised imports | 170+ recorded cases |
The trend is clear—India is cleaning up its import ecosystem, not closing it. The aim is to promote responsible imports, not ban trade.
Common Mistakes Businesses Still Make
- Assuming BIS certification is needed only for new items.
- Using a supplier’s BIS number instead of their own registration.
- Confusing DGFT licence with CPCB authorisation—they are two separate systems.
- Uploading incorrect addresses or missing documents on the e-waste portal.
- Ignoring QR-code labelling, thinking it’s optional—it isn’t from July 2025.
These oversights are simple to avoid with early consultation and professional filing support.
A Practical Compliance Checklist
Here’s a simplified roadmap to stay compliant and avoid last-minute panic:
- Confirm your product’s ITC (HS) code and import status.
- Apply for DGFT restricted goods licence well before shipment.
- Obtain BIS CRS / ISI certification based on product category.
- Register for EPR Authorisation on CPCB portal (for electronics, batteries, or plastics).
- Ensure your factory, refurbishing, or recycling unit has valid SPCB CTO.
- Label every product and packaging with QR codes and EPR numbers.
- Maintain digital copies of approvals and file quarterly returns on the CPCB portal.
Doing this early saves weeks of delay and thousands in storage costs.
What Non-Compliance Really Costs
It’s not just about fines; it’s about lost opportunity.
Importers have reported 3–6 months of disruption, losing supply contracts and credibility with international partners.
Penalties include:
- Suspension of your Importer-Exporter Code (IEC).
- Seizure or destruction of goods at Customs.
- Legal notices under the Environment (Protection) Act, 1986.
- Forfeiture of performance bonds and loss of BIS registration.
Preventing these costs is far cheaper than fixing them.
The Bigger Picture: Compliance as a Competitive Advantage
In the past, regulatory paperwork was seen as a burden.
Today, it’s your competitive moat. Buyers, OEMs, and investors increasingly prefer suppliers who are fully compliant with BIS, EPR, and DGFT norms.
Having the right registrations not only keeps you legal—it also earns trust, faster customs clearance, and brand credibility.
Green Permits has seen this transformation first-hand.
Clients who took early action on EPR and BIS compliance now clear shipments in half the time and attract global partners who value sustainability.
Conclusion
India’s 2025 DGFT import guidelines mark a turning point—not to block trade, but to make it cleaner and future-ready.
For importers, refurbishers, and distributors, the smartest move is to shift from reactive compliance to proactive preparation.
By aligning your paperwork, plant, and packaging today, you’re not just meeting a law—you’re building a resilient, responsible business.
At Green Permits Consulting, we simplify this journey. From DGFT and BIS filings to EPR registration and recycling tie-ups, our team ensures every box is ticked before your shipment lands.
📞 +91 78350 06182
📧 wecare@greenpermits.in
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FAQs
Yes, but only with DGFT licence, BIS certification, and EPR authorisation from CPCB.
Used goods are previously operated; refurbished ones are repaired and tested before resale. Both need DGFT and BIS clearance.
No. Even certified foreign goods must be registered with BIS India before sale.
Your EPR registration may be suspended, and future import licences may be withheld until compliance is restored.
We manage the full process—from DGFT authorisation and BIS CRS registration to EPR licence filing and recycling tie-ups—ensuring your imports move without interruption.
