What is BIS CRS — the Compulsory Registration Scheme?

What is BIS CRS?

The Compulsory Registration Scheme was introduced by the Ministry of Electronics and Information Technology (MeitY) in collaboration with BIS and is operated under Scheme II of BIS (Conformity Assessment) Regulations, 2018. Before any notified product can be manufactured, imported, sold or stored in India, it must be tested against the applicable IS code (Indian Standard Code) that specifies technical parameters, safety thresholds and test methods for that product category.

CRS currently covers approximately 75 product categories, including mobile phones, laptops, tablets, LED televisions, power adapters, power banks, CCTV cameras, printers, bluetooth speakers and smartwatches. This list expands regularly through QCOs notified in the Gazette of India.

Upon successful registration, BIS issues an R-number (a unique ten-digit identifier) that must appear on the product and its packaging. The R-number is checked by customs authorities at the point of import clearance and is a listing requirement on major e-commerce platforms like Amazon India and Flipkart.

How CRS works

CRS registration is issued exclusively in the foreign supplier’s name. An importer or buying agent cannot apply on behalf of a supplier. Where a supplier has not registered, the goods cannot legally enter India regardless of the importer’s commercial relationship with that supplier.

The process under the scheme has four stages. First, the manufacturer sends product samples to a BIS-recognised laboratory in India. For a laboratory to qualify for CRS, it must hold specific BIS recognition for the relevant product category. NABL (National Accreditation Board for Testing and Calibration Laboratories) accreditation alone is insufficient. Second, the laboratory tests the product against the IS code and issues a test report. Third, the manufacturer submits the test report, technical documentation and a self-declaration of conformity through the BIS portal. Fourth, the BIS reviews it and if conformant, issues the registration certificate and R-number.

For Indian manufacturers, the end-to-end timeline may typically run from four to six weeks. Foreign manufacturers should plan for two to three months as the samples would travel to India for testing in addition to BIS processing. Registration is valid for two years and a lapse may render every shipment during that period non-compliant.

Note: Foreign manufacturers should initiate the CRS process before commercial conversations with Indian distributors begin to avoid transferring market entry timing to a process outside the manufacturer’s control.

Implications for businesses

Foreign manufacturers exporting electronics to India are subject to QCO requirements in the same way as Indian manufacturers in the notified categories. The underlying obligation, i.e., mandatory BIS certification before market entry remains the same as in the case of ISI Mark Scheme with a procedural difference of absence of a factory inspection.

For Indian manufacturers, a mandatory CRS removes both, uncertified domestic domestic goods and uncertified imports from the market once a category is notified.

For importers, the structural exposure is that registration belongs to the foreign supplier. A supplier’s lapse, renewal failure, or failure to register a new model variant creates a non-compliance that the importer cannot remedy on their own. The only effective controls are pre-order R-number verification and a contractual obligation on the supplier to maintain valid registration as a condition of each purchase order.

Note: Importers should treat the supplier’s R-number and renewal date as procurement-critical data, tracked with the same discipline as commercial terms. (www.manakonline.in)

Legality and risks

Customs clearance is verified against the BIS portal in real time. A lapsed, suspended or mismatched registration results in immediate consignment detention. Container demurrage and ground rent begin accruing from the first day. The available remedies include re-export, apply for conditional exemption or confiscation.

Two failure points account for most avoidable detentions. The first is the Renewal Gap where CRS registration expires after two years and a supplier who does not renew it before expiry creates a lapse the importer cannot address from their side. The second is the Laboratory Specificity where an application submitted with a test report from a laboratory that the BIS does not recognise for the relevant product category is rejected in full, requiring testing to start afresh.

Manufacture, import, sale or storage of a notified product without valid CRS registration is an offence under the BIS Act, 2016, attracting monetary penalties and repeated violations may lead to criminal liabilities.

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