What is a Quality Control Order (QCO)?

What is a QCO?

India has always had product standards since 1947. What changed over the last decade is that compliance with those standards became mandatory. That shift is called a Quality Control Order, also known as QCO

A QCO is a notification issued by the Central Government under Section 16 of the Bureau of Indian Standards Act, 2016. It identifies a specific product, assigns it a mandatory Indian Standard (an IS code), and declares that no unit of that product may be manufactured, imported, or sold in India unless it carries the BIS Standard Mark, commonly known as the ISI mark.

The scale of this regime is now substantial. India has issued over 187 QCOs covering approximately 769 product categories across steel, chemicals, electrical goods, electronics, industrial machinery, consumer products, and more. The number was 88 in 2019. The pace of expansion is accelerating.

Why BIS certification is worth pursuing

India's consumer market now exceeds 2.2 Trillion USD with a working-age population close to 1 billion. For any manufacturer or importer, access to that market is a strategic prize. A QCO is the quality credential that makes that access possible for a notified product category. Without it, the door to India’s markets is closed. With it, you are operating in one of the fastest-growing consumption economies in the world, with the assurance that every competitor on the shelf has met the same standard as you and that your product can be sold in the market without any compliance risks.

For domestic manufacturers, BIS certification under a QCO creates a level competitive environment. Uncertified products cannot legally enter the market, which means manufacturers investing in quality compliance are not undercut by cheaper, non-standard alternatives . The certification is therefore not just a regulatory requirement; it is a market position. Buyers, distributors, and institutional procurement bodies treat the ISI mark as a baseline condition of purchase. End consumers often seek the ISI mark on products.

For foreign manufacturers, BIS certification under FMCS (Foreign Manufacturers Certification Scheme) is the entry credential for the Indian market. Companies that obtain it early, and maintain it well, build a durable advantage over competitors who have not yet invested in the process. In product categories where BIS certification timelines are extended, approvals can take anywhere between 6 to 12 months, particularly for products involving factory inspections, foreign manufacturer certification, or constrained testing capacity. In such cases, obtaining certification ahead of competitors can translate directly into earlier market access and a meaningful competitive advantage.

The quality standards embedded in QCOs are aligned with internationally recognised benchmarks. A manufacturer that meets the applicable Indian Standard is typically demonstrating a quality level that is competitive globally. The certification process, though demanding, is also a discipline that leads to production improvements which will benefit you across all markets, not just India.

How does QCO compliance work?

The compliance pathway under a QCO differs depending on whether you are an Indian manufacturer, a foreign manufacturer, or an importer. Each faces a different route to the same destination - a valid BIS licence, valid for 1–2 years initially and renewable for up to 5 years, that permits use of the ISI mark.

Indian manufacturers apply under the ISI Mark Scheme. They submit an application to BIS, get their product tested at a BIS-recognised laboratory against the applicable Indian Standard, and submit to a factory inspection. If the product and manufacturing process meet the standard, BIS grants a licence. The licence is subject to ongoing surveillance audits.

Foreign manufacturers who want to export to India apply under the Foreign Manufacturers Certification Scheme (FMCS). The application must come from the overseas manufacturer directly. An Indian importer cannot apply on behalf of their supplier. BIS sends an inspection team to the foreign factory, the product is tested, and if compliant, a licence is granted. The licence is product-specific and factory-specific. It does not cover other products from the same company or the same product from a different facility. FMCS timelines in practice often run six to nine months, and sometimes longer.

Electronics and IT products follow a separate route called the Compulsory Registration Scheme (CRS). Here, manufacturers self-declare conformity through testing at a BIS-recognised laboratory and register with BIS. The ISI mark is then applied to the product.

For importers, the obligation is straightforward in law but difficult in practice: ensure your supplier is BIS-certified before the goods reach an Indian port. Customs authorities verify compliance at the time of import. Goods without the requisite BIS certification are detained.

Legality and risks

Penalties for QCO non-compliance are provided under Sections 29 to 33 of the Bureau of Indian Standards Act, 2016. These include monetary penalties, prohibition on sale and imprisonment depending on the severity of the violation. These are not merely regulatory infractions. The Act treats the use of the ISI mark without authorisation, and the manufacture or sale of goods without mandatory certification, as serious offences — carrying criminal liability not just for the business entity, but also for the directors, managers, and officers responsible for its conduct.

At the import stage, enforcement is exercised by Customs. A consignment without the required BIS certification will be detained at the port of entry. From Day One of detention, demurrage charges on the container and ground rent on the goods begin to accrue. We have seen cases where such charges may be 1000s of dollars a day. The importer has limited options: re-export the goods, obtain a specific exemption (which is narrow and conditional), or face confiscation and destruction. There is no administrative grace period once the enforcement date has passed.

For importers specifically, the risk that is most frequently overlooked is the supplier dependency problem. The BIS licence under FMCS belongs to the foreign manufacturer, not to you. If your supplier lets the licence lapse, does not renew it, or loses it due to a surveillance failure, your shipment is non-compliant the moment it arrives in India. You have no control over the licence and no direct remedy. The only protection is contractual: requiring your supplier to maintain valid BIS certification as a condition of your purchase order and conducting periodic verification through the BIS public portal.

Traders and distributors holding inventory at the time a QCO comes into force face a related risk. After the enforcement date, non-certified goods in stock cannot legally be sold. There is no grandfather clause for existing inventory. The financial loss falls entirely on the holder of the goods.

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