FAQ on “Electronics and Information Technology Goods (Requirements for Compulsory Registration) Order, 2012”

1.   The Compulsory Registration order will be effective based on manufacturing date or import date?

• The order will come into forces on 03 July 2013 and would apply equally to goods manufactured locally or imported from foreign.

2.     What would be the status of goods already in stock and in the market?

• The products manufactured / imported before 03 July 2013 would not be covered under the provisions of this order.

3.   What will happen to goods ordered and expected to come in July (deferment of shipments) or in transit?

• The goods landing at Indian ports on or after 03 July 2013, must comply with the  requirements of Compulsory Registration Order and carry Self Declaration Statement.

4.   Will the consignment be provisionally cleared at customs? Or will the consignment wait till the samples are tested?

• The goods, if they land on Indian ports on or after 03 July 2013 cannot be cleared at customs without the self declaration mark.

5. Can we not have voluntary declaration only and make it mandatory after Jan 2014?

• The Compulsory Registration order mandating self declaration mark is law of the land which comes into force on 03 July 2013.

6. Who is eligible to get Unique Registration Number – the manufacturer or importer?

• The Unique Registration Number will be provided by BIS. This Number is linked to manufacturer, location of factory (even if located abroad) and product. Each manufacturing unit would have to apply separately for registration even if the same product is manufactured by the same manufacturer at different locations.  However, local representatives under authorisation of the manufacturer (Factory) may file the application for Registration on behalf of the manufacturer.

7.    What are list of document and test results to be submitted for registration?

• A detailed Application Form required to be submitted for registration is available on BIS website. Wherever needed, the application may need to be substantiated with documents as required by the BIS.

8.   If being manufactured by OEM and the product is already carrying CE, UL & FCC mark or tested as per International safety standard in overseas lab or a CB testing lab – do these products have to be retested or submission of test  reports from OEM supplier is enough for registration?

• The BIS Rules require a valid test report (not older than 90 days) from any BIS recognised test laboratory to be submitted while applying for Compulsory Registration. The laboratories aspiring to test under the scheme must seek recognition from the BIS.

9.    What is the validity of test report?

• As per BIS rules, the test report shall not be older than ninety days as on the date of submission of application for registration.

10. Self declaration mark will be on the product or packaging? What labelling /location of phrase for self- declaration has been fixed and where to refer for the same for specific product?

• The declaration shall preferably be marked on the product. However, if it is not possible to mark it on the product due to limitation of size etc, it can be marked on packaging also. No location has been specified for marking. The declaration should be indelible, legible and clearly marked requirements of the relevant Safety Standards.

11. What should the label display?

• Label should display / visible on the product, as per “Self Declaration – Conforming to IS….” followed by Registration No… The standard number shall be followed by its year of publication separated with a `:’ Colon.
• For example “Self Declaration – Conforming to IS 13252:2010” Registration No. xx..xx

12. If manufacture is manufacturing under multiple brands, is registration required for each brand or allocated to manufacturer for all products which are manufactured?

• Please refer to guidelines for series approval available on deity.gov.in

13. If product is certified at one manufacturing location, is it necessary that  certification for that same product manufactured at other locations in country is done again?

• The Unique Registration Number provided by BIS is for unique manufacturing location. Hence separate application has to be made for each location.

14. Who will bear the cost of registration?

• The costs including those of surveillance are to be borne by the registered entity.

15. Is it required to get the product retested from a lab prior to renewal?

• The renewal is done by BIS on submission of application for renewal within the stipulated time. Repeat testing is not specifically envisaged. However, test samples would be picked up for testing during surveillance.

16. Who is liable for testing of imported products – Importer or Foreign Manufacture?

• The Registration is for the manufacturers (Factory). Hence, it is the responsibility of manufacturer to get the products tested from BIS recognised laboratory. Importers may function on behalf of the manufacturer and only under authorisation of the manufacturer.

17. Will the supplier’s test report be good enough for self declaration for       importer or trading company?

• The supplier’s test report is not acceptable.

18. What is the process of collecting product from foreign manufacturer?

• It is the responsibility of manufacturer to get the products tested from any BIS recognised laboratory. Such products will be picked up from the market during surveillance.

19. What is the time period of testing / collection / registration?

• The time period of testing is depending upon the work load of the laboratory chosen by the manufacturer. Samples for initial registration can be submitted directly to the labs by the Manufacturer. Independent samples need to be collected only during surveillance process. The registration will be promptly processed by BIS if all submitted documents are in order.

20. Can the manufacturer apply for recognition with BIS for its own testing laboratory?

• Manufacturer’s test laboratories are not entitled for recognition with BIS.

21. Will the testing be required for every lot?

• There is no such requirement from the scheme. However, if relevant product standards call for it, the same would apply. It is the responsibility of the registered entity to ensure the compliance of goods to the respective standards by whatever Factory Quality Assurance Mechanisms.

22. Which is the applicable standard for microwave – IS 302-1:1979 or IS-302-1:2008?

• The applicable standard is IS 302-1: 2008.

23. Which of the BIS recognized labs can be approached for testing of products? So far not many labs have been recognized for testing, so how to go about testing?

• The list of BIS recognised labs along with their capability is available on BIS web site. This list is growing as more and more labs are getting BIS recognition.

24. Electronics part ordering cycle is 3 months so changes before this duration are not possible.

• The Compulsory Registration Order comes into force on 03 July 2013 and has to be followed.

25. Will sample testing be required for same series and same enclosure in LCD / LED TVs? If the registration is for basic model which may have derivative 10 models – what is registration process?

• Please refer to guidelines for series approvals for which are available on DeitY web site

26. If any changes are implemented in product – what is regulation for registered product? What is the process involved in case of products getting upgraded with latest technology and upgraded configuration?

• Any changes must be informed and have concurrence of the Registering Authority. Repeat testing, if needed could be asked for / provided.

27. How to address if alternate sources are developed for same approved specifications? What will happen if the circuit or components or are changed?

• Refer to guidelines for series approvals which are available on DeitY web site. While implementing this order for testing of equipment, safety critical components will be accepted based on their –
  • Compliance to relevant Indian Standard / IEC standard based on testing, or
  • Certification / Testing by any NCB / Test Lab under IECEE – CB scheme or IEC 17025 accredited laboratory, or
  • Testing for suitability for applicability within the scope of equipment performed by the BIS Recognised Lab for the Product Standard. (This may be done as a part of equipment testing.)

28. Whether FR Grade material is mandatory under the standards?

• Refer to the applicable standard to confirm if this is a requirement specified by the standard.

29. What document should trader demonstrate during surveillance?

• Compliance Statement on the Goods as demanded by the Order needs to be demonstrated. If needed, the trader has to supplement with a copy of the Registration Certificate / Source of procurement and related documents to establish compliance to the law.

30. What about remote handset changes in LCD / LED products time to time?

• Any changes must be informed and have concurrence of the Registering Authority. Repeat testing, if needed could be asked for / provided.

31. If product is required to be sent abroad for maintenance, do we need to submit the product before custom clearance?

• The Compulsory Registration Order applies universally after the due date. When the new product of the same model shall stand prohibited, the question of allowing import of a repaired / refurbished item does not arise.

32. What are the standards to pass the product before submitting for testing in a lab?

• The standards are specified in the Gazette notification for Compulsory Registration.

33. Any specific label to be pasted on product if already registered?

• Marking requirements are explained in Q 11 above

34. Once the product is registered as imported, would the repeat order of same product need to again register?

• There is no requirement for re-registration for the same product. Registration once granted, is valid for 2 years. Original Registration could be revalidated, on request, as per provisions of the scheme.

35. Validity of product registration is two years. Incase plant is outside India, who will communicate with manufacturer?

• The renewal has to be requested for by the registered entity.

36. Where are the standards & specifications for IS compliant products under Compulsory Registration order?

• The Gazette notification for Compulsory Registration order gives the number of applicable Indian standards. These standards can be purchased from the offices of BIS located all over the country.

37. Is self declaration to conformity applicable for products mentioned in Gazette or can be applied to other electronics products also?

• The Compulsory Registration order mandating self declaration is applicable only to products listed in the Gazette Order notified by the DeitY

38. Is desktop computer included in the list under automatic data processing machines, since it does not appear as a separate item?

• The desktop is automatic data processing equipment as per the definition. But, the desktop or personal computer will not be covered under the provisions of the said order.

39. With this mandatory registration, will the other quality norms in tenders, empanelment like FCC, UL, CE, be removed?

• The Compulsory Registration is a regulatory requirement for placing products on Indian markets. It does not prohibit the purchaser from specifying additional technical requirements.

40. What is the penalty provision if a manufacturer is not registered with BIS and continues selling the products in Indian market?

• If the manufacturer and products are not registered with BIS as per the Compulsory Registration Order, the manufacturer is liable for prosecution under the BIS Rules as well as attract attention of clauses 3(2) (deformation of products beyond use) and 4(3) (seizure of products) of Gazette Order notified by DeitY.

41. What will happen to the registration number if the Indian Standard is amended by BIS?

• According to the BIS Rules, when an Indian Standard (IS) is withdrawn, any registration granted in respect thereof will be deemed to have been cancelled from the date of withdrawal of such standard. As per BIS Rules, there are no transitional periods where the old standards may also apply. Hence, importers and manufacturers must stop supply of products for a certain period of time to prepare for re-registration based on the new standards and replacing the labels affixed with the equipment.
• BIS is in the process of reviewing its transition policy to permit for the concurrent running of two standards for some time.

42. Will an Amplifier (PA system) with USB for playing music fall under Electronic Musical System category?

• An Amplifier (PA system) with USB for playing music still remains an Amplifier (PA system) and cannot be termed as electronic music system because its basic function remains of amplifier only.

43. Whether PA Amplifiers with MP3 Playback facility are covered under Electronic Musical System? MP3 Playback module provided in the Amplifiers is an additional feature only?

• An Amplifier (PA system) with MP3 Playback facility still remains an Amplifier (PA system) and cannot be termed as electronic music system because its basic function remains of amplifier only.

44. What are covered under Electronic Musical System?

• As given in the Standard IS 616: 2010, the electronic musical system covers –
  • Record or Disc Player
  • Tape Players and Recorder
  • Professional Sound / Video System

45. When would the testing laboratories return the tested samples?

• Since safety testing involves destructive tests, the laboratories can return / dispose of the tested samples as per their policy on retention period for tested samples.

46. What is the retention period of second sample?

• Whenever the surveillance sample is picked up from manufacturing unit, in addition to the sample to be sent for testing, another sample from the same batch or lot shall be drawn, sealed, labelled, and left with the registered user as a c sample, for use in case of any subsequent dispute. This counter sample v retained by the manufacturer till DeitY provides clearance or renev registration whichever is earlier.

47. Is there a common format for test reports which all the BIS recol laboratories have to follow?

• As of now, there is no common test report format devised by BIS and th could issue test reports in their respective test report formats till a common 1 was prepared.

48. What will happen if the circuit or components in the product are change policy of the company for continuous improvement of the product?

• Refer to guidelines for series approvals which are available on DeitY we regarding alternate source of components. While implementing this order  testing of equipment, safety critical components will be accepted based on the:
  • Compliance to relevant Indian Standard / IEC standard based on test is
  • Certification / Testing by any NCB / Test Lab under IECEE – CB s or IEC 17025 accredited laboratory, or
  • Testing for suitability for applicability within the scope of equiment performed by the BIS Recognised Lab for the Product Standard. (This be done as a part of equipment testing.)

49. What are safety critical components?

• Typical safety critical components* are –
  • Power cords
  • Switches
  • Safety Isolating Transformers
  • Fuses
  • Rechargeable Batteries
  • Picture tubes / CROs
  • PCBs
  • Thermostats
  • X and Y capacitors
  • Fusible resistors / varistors
  • Plus / sockets / connectors
  • Lamp holders

*This list is indicative only and not intended to be comprehensive.

50. Which is the applicable standard for printer, plotter – IS 13252: 2003 or IS 13252: 2010?

• The applicable standard is IS 13252: 2010 (Part – 1).

51. Are commercial and industrial printers included in IS 13252: 2010?

• The standard IS 13252: 2010 (Part – 1) does not differentiate between class or type of printers.

52. In the BIS application form, it seems no specific models are required to be filled up in the application form. What model number shall be addressed in the application form? Or shall the general product name be keyed? e.g. NOTEBOOK, PRINTER etc.

• The applicants have to submit all the necessary details about the product models or series of products as indicated in clause 16B of Chapter IV – A applicable to the Compulsory Registration of Electronic and IT Goods.

53. Are barcode readers, scanners and printers (corded or cordless) part of schedule?

• The barcode readers, barcode scanners and barcode printers (handheld or fixed type) fall under the ambit of this Order.

54. What is covered under Electronic Clocks with Mains Power?

• A. As per IS 302-2-26: 1994 – Alarm clocks, clocks controlling radio receivers and like, that are regarded as being primarily intended for time indicating purposes and spring driven clocks with an electrically operated winding mechanism, are within the scope of this standard. Clocks incorporating driving means other than motors are also within the scope.
• B. This standard does not apply to Clocks having other functions, whether or not in combination with time indication, such as master control clocks and timers for cooking ranges, washing machines and the like;
  • Clocks for `clocking-in’ purposes;
  • Clocks incorporated in mains-operated electronic and related apparatus for household and similar general use; and
  • Clocks incorporating electronic circuits only.

55. Are Multi Media Speaker Systems parts of Amplifiers or Electronic Musical Systems?

• The Multi Media Speaker Systems receive power from the stated devices and hence are not parts of Amplifiers or Electronic Musical Systems.

56. Are consumer wireless devices (Wi-fi and Blue tooth) covered under the scope?

• The wireless devices like Wi-fi modems, BT headset, BT speaker, BT mouse, USB data card and USB LAN card are not covered under the scope of Compulsory Registration order.

57. Will the Compulsory Registration order apply to spare parts of the notified products? Will the order apply to an item used as a replacement of a faulty unit?

• The Compulsory Registration order applies to finished goods and not the spare parts, CKD or SKD units, and stripped down warranty replacement units. However, complete unit being sent as replacement of faulty unit would draw the attention of this order.

58. What is the definition and scope under the title Automatic Data Processing (ADP) Machines in reference to the notified order?

• Automatic Data Processing Machines cover –
  • Data Preparation Equipment
  • Data Processing Equipment
  • Data Storage Equipment
  • Personal Computer
  • Plotter
  • Printer
  • Scanner
  • VDU

59. Can a digital media streaming device with WiFi connectivity and capability to download digital media and play it on any kind of display system be considered a set top box?

• This is a mobile technology device which is not within the scope of Order.

60. Do high definition video conferencing products need registration under this Compulsory Registration Scheme Order.

• Only video display units of high definition video conferencing products, if they are of size 32″ and above, fall under the CRS Order. The camera is not covered.

61. Are digital video recorders (Security products connected with CCTV camera) covered under the CRS Order?

• Digital video recorders (Security products connected with CCTV camera) are not covered by the Order.

62. Are thermal printers used in ATM machines covered in the definition for printers requiring Registration?

• Standalone printers are covered by the Order. The printers used as an embedded part of a larger device, like ATM here, are not covered by the Order.

63. Do the following devices fall under the scope of Compulsory Registration Order –

a) Mobile computing devices : Batch or GSM and WiFi based mobile computers?

b) RFID : HF and UHF based devices – Fixed mount or mobile computers?

c) Wireless access points, controllers / switches?

• These devices are not included under the scope of Order. Only, Laptop / Tablet / Notebook are covered by the Order.

64. Is a home entertainment system consisting of following components to be considered as an Electronic Musical System covered by the CRS Order –

a) Console system,

b) Woofer with built in amplifier (less than 2000 watts),

c) Speakers,

d) Remote, and

e) iPod dock?

• All these components taken together constitute the Electronic Musical System as defined in the Order and hence they fall under its ambit if the input power is more than 200 watts, as specified in the Schedule.

65. How will the goods imported for demonstration or R & D or testing purposes be treated?

• The said order shall not be applicable to goods if imported for demonstration / development / testing in India. Such imports shall be in limited quantities and a declaration from manufacturer would be considered necessary. Validation letters may be issued by DeitY against specific requests received from interested parties.

66. It has been observed that certain requirements of Indian Standards, like colour code and length of cord, are in conflict with the International Electro-technical Commission (IEC) standards. However, the said inconsistencies are not of a critical nature and would in no way, affect the quality of the products.  How will the said inconsistencies be considered by the BIS recognised laboratories while doing the testing of the items submitted to them?

• The industry has to follow the Indian standards.

67. Do both professional use equipment and home use equipment require registration?

• Gazette notification and the relevant Indian Standards do not differentiate between professional use equipment and home use equipment. If any such equipment falls under the ambit of this order, as notified in the Schedule, it has to be registered with BIS.

68. Are PABXs are covered by this order?

• In the table of clause 1.1.1 of IS 13252 (Part 1) : 2010 the PABXs, EPABXs, FAX machines and telephone sets are separately indicated from telephone answering machines and hence not part of the schedule of the order.

69. Will IS 694 be applicable for harness wires of the regulated products?

• Refer to the applicable standard to confirm if this is a requirement specified by the standard.

70. Are Multimedia Speaker System with USB / SD / EM Playability (with power consumption < 200 watts), Car Audio Amplifier (with power consumption <2000 watts) and Car Head Unit with USB / SD / FM / AM / Aux Playability (with power consumption < 200 watts) covered under this order?

• These products are not within the scope of the Order as the ratings are lesser than those for the mandated products in their respective category.

71. Is “Session Border Controller” or “Unified Communication Server” used for data storage part of ADP?

• By the definition and classification of ADP, these products are covered within the scope of the Order.

72. Are automation modules / switches / sensors used in automation of houses part of this order?

• These products are not within the scope of the Order.

73. Are power supply, converter and power plants for telecom application covered by this order?

• These products are not within the scope of the Order.

74. Will it be possible to get future models included in existing series (as part of 10 models in it series) after Grant of Registration to the representative model already registered?

• New products can be included in the existing Registration number with the following process –
  • Technical details of the new product along with the existing Series and test report to be submitted to the Labs for validation.
  • Validation report from Lab along with existing registration number for a series needs to be submitted to BIS.