Parts
Parts of primary cells and primary batteries (dry cell components)
HSN 8506 90 00 (parts of primary cells and primary batteries) is covered by a Bureau of Indian Standards Quality Control Order. Conformity to IS 8144:2018 is mandatory under the ISI Mark Scheme, with the Steel and Steel Products Quality Control Order 2024 (S.O. 3716(E)) imposing an additional input-material standard-mark requirement on tin plate and tin-free steel components. Extended Producer Responsibility authorisation under the Battery Waste Management Rules and the E-Waste (Management) Rules apply as separate customs-clearance overlays.
Procedural directions for customs clearance are issued by: Central Board of Indirect Taxes and Customs.
- 1Source only from a Bureau of Indian Standards CM/L-licensed manufacturer holding a current licence against IS 8144:2018. Verify the supplier's CM/L number, licensed product scope, and manufacturing facility on the BIS online register before placing the purchase order.IS 8144:2018 · S.O. 516(E) dated 25-05-1987 · BIS (Conformity Assessment) Regulations, 2018
- 2Where the parts are fabricated from tin plate or tin-free steel (Schedule 2, serial numbers 3–7 of the Steel and Steel Products QCO), confirm the input material itself bears the BIS standard mark per Schedule 1 serial numbers 108–109. The consignment must be accompanied by the input-material test certificate.Steel and Steel Products Quality Control Order, 2024 · S.O. 3716(E) dated 29-08-2024 · Scheme-I of Schedule-II to the BIS (Conformity Assessment) Regulations, 2018
- 3Ensure each part bears the ISI mark and the supplier's CM/L number in accordance with Scheme-I of Schedule-II to the BIS (Conformity Assessment) Regulations, 2018. Marking must appear on the product itself; packaging-only marking is not sufficient.BIS (Conformity Assessment) Regulations, 2018 · F.No. BS/11/11/2018 dated 04-06-2018
- 4Obtain Extended Producer Responsibility authorisation from the Central Pollution Control Board under the Battery Waste Management Rules before import. Verify compliance with the Battery Waste Management (Amendment) Rules, 2023. Micro enterprises as defined under the MSMED Act, 2006 are exempt from the E-Waste EPR requirement.S.O. 3984(E) dated 22-08-2022 · S.O. 4669(E) dated 25-10-2023 · E-Waste (Management) Rules, 2022 · G.S.R. 801(E) dated 02-11-2022
- 5If the steel input material is imported without a BIS licence or certification, apply through the TCQCO portal for clarification on each such steel consignment as mandated by the Ministry of Steel circular dated 20-10-2023. Ensure compliance with CBIC clarification F.No. 401/88/2023-CUS.III dated 09-11-2023 on that circular.Ministry of Steel circular F.No. S-20011/14/2021-Tech dated 20-10-2023 · CBIC clarification F.No. 401/88/2023-CUS.III dated 09-11-2023
The most common error on this tariff line is treating the finished-part BIS CM/L obligation under IS 8144:2018 as the only compliance hook, while overlooking that the steel input materials used to fabricate those parts — tin plate and tin-free steel — independently require BIS standard-mark certification under the Steel and Steel Products QCO 2024. Customs has authority to detain a consignment where the test certificate for the input material is absent, even when the finished part itself carries a valid ISI mark; importers who delegate input-material compliance entirely to the overseas supplier without documentary verification are the ones most frequently caught at port.