India requires a long list of electronics, including most LED lighting products, to be registered with the Bureau of Indian Standards before they can be sold or moved through customs. Unlike some certification schemes, the registration is granted to the manufacturer rather than to the seller, which changes how a supply chain has to be set up.
The Scheme in Outline
The requirement sits under the Electronics and Information Technology Goods (Requirements for Compulsory Registration) Order, 2012, administered by BIS as the Compulsory Registration Order, or CRO. Products on the list must be registered before they enter the market, and the registration number, sometimes written as an R-number, must appear on the product.
Foreign manufacturers can register directly through the BIS portal. The registration covers a defined model and a defined factory, so a new model or a new production site generally means a new application rather than an amendment. (to be verified)
Who Applies and Who Cannot
The application is submitted by the manufacturer. For a foreign manufacturer, BIS requires an Indian Authorized Representative, known as an AIR, who acts as the local contact and accepts service of notices. Traders and importers cannot apply on the manufacturers behalf.
That structure matters commercially. An importer buying from a factory that has not registered cannot simply certify the goods on arrival. The registration has to exist before shipment, and the R-number on the carton has to match the model that was tested.
Standards That Apply to Lighting
The lighting product standards fall under the IS series. The table below lists the main families; the exact part and section depends on the product category. (to be verified)
| Product group | IS standard family |
|---|---|
| Self-ballasted LED lamps | IS 16102 (Part 1 and Part 2) |
| LED modules for general lighting | IS 16103 (Part 1 and Part 2) |
| DC or AC supplied electronic controlgear for LED modules | IS 16104 |
| Luminaires | IS 10322 series, with the relevant part and section |
Safety and performance are handled in separate parts of the same standard. The safety part covers insulation, creepage, thermal limits and fault behaviour. The performance part covers luminous flux, efficacy, color rendering and chromaticity tolerance. A registration application normally needs test reports covering both.
The Application Sequence
The manufacturer appoints an AIR, then selects a laboratory recognised by BIS under the scheme. Samples are tested against the applicable IS standard, and the test reports are submitted with the application through the portal. BIS reviews the file and, once it is accepted, issues the registration number.
The number is then marked on each product or on the packaging, and it must be traceable to the model that was tested. Registration has a validity period and must be renewed. (to be verified)
Market Surveillance and Delisting
BIS draws samples from the market and from the factory as part of surveillance. If a sample fails, or if the marking does not match the registered model, the registration can be suspended or cancelled, and the listing removed.
For a supplier this is the operational risk to watch. A registration that exists on paper but covers a different batch of LEDs or a different driver than the one shipping will fail surveillance, and the importer carries the commercial damage.
What an Importer Should Verify
Check the R-number directly on the BIS portal rather than accepting a scan from the supplier. Match the registered model number against the items on the commercial invoice, not just the family name. Confirm the registration is still valid on the shipment date, because the validity window can lapse between order and delivery.
Keep the test reports on file. Customs and market surveillance both ask for them, and a supplier who cannot produce the tested model is a supply risk regardless of the paperwork on the carton.
Fact-check status: source list pending
FAQ
Can an importer register on behalf of the factory? No. Registration is granted to the manufacturer, and a foreign manufacturer needs an Indian Authorized Representative rather than an importing company acting alone.
Does one registration cover every LED product from a factory? No. The registration follows a model and a production site. New models and new factories generally require separate applications.
Is the R-number enough on its own? No. The number must match the tested model and remain valid at the time of shipment, and the underlying test reports should be available on request.
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