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Frequently Asked Questions for BIS:-

The date of manufacturing for domestically produced goods and date of landing of consignments in India for goods manufactured overseas would apply for consideration against deadlines notified.

The products manufactured / imported before the due date of coming into effect of Order are not covered under the ambit of the Order.

The goods landing at Indian ports on or after the due date must comply with the requirements of Order.

The manufacturer is eligible to apply and get unique registration number which is linked to manufacturer, location of factory, product and brand.

As per BIS Rules, the test report shall not be older than ninety days as on the date of submission of application online as well as physical application for registration.

The Standard Mark shall be placed on the product & the packaging both however, if it is not feasible to place the same on the product for size constraints, it can be put on the packaging only. For the products with display screen, provisions of e-labelling of products also exist.

Different brands are required to be registered separately. However, it is feasible to do so based on a common test report, if the product and the manufacturing location are the same.

All brands with respective model numbers should be listed in the test report. Test samples of all brands are not required to be submitted. However, product labels for respective brands must be placed in the test report. Lab may also include statement about coverage of this brand and respective model numbers to be covered based on the representative model tested and the declaration submitted by the manufacturer about multiple brands and respective model numbers.

The unique registration number provided by BIS is for unique manufacturing location. Hence, separate application has to be made for each location and supported with a test report for product from that manufacturing location.

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

Communications are addressed to the registered entity / its authorized Indian representative.

The manufacturer is liable for prosecution under clauses 3(2) (deformation of products beyond use) and 4(3) (seizure of products) of Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012 notified by MeitY on 03 Oct. 2012 and 2(a)(2) of amendment order dated 25 June 2013. Other provisions under BIS Act, also apply.

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
  • Plug / sockets / connectors
  • Lamp holders
  • Cells (For batteries)
  • External and internal wire for LED Luminaires
  • Insulation tape
  • Electrolytic Bulk Capacitor

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

The Compulsory Registration Order applies to finished goods and not the spare parts/components used in the manufacturing of the finished goods, unless they are notified separately as independent products under CRO. Further, the import of the notified items in CKD (complete knock down) condition is allowed. However, for the import of notified goods, in SKD (semi knock down) condition, the import should be allowed only to the manufacturer of the end finished product which are having IEM license for manufacturing the same. If the products are imported in SKD condition, the customs shall ensure that the importer has valid authorization from the brand owner for assembling/manufacturing the end product

The said Order shall not be applicable to goods if imported for demonstration / development / testing in India.

Highly Specialized Equipment (HSE), as per the criteria given below, shall stand exempted from the application of this Order provided they are manufactured / imported in less than 100 units per model per year-

  • Equipment Powered by Three phase power supply, or
  • Equipment Powered by Single phase power supply with current rating – exceeding 16 Ampere, or
  • Equipment with dimensions exceeding 1.5 m x 0.8 m, or
  • Equipment with weight exceeding 80 Kg.

The plugs/sockets may be pre-certified to international standards. However, the configuration and dimensions of pins of sockets and plugs or plug part of products with built-in plugs should be as per the current edition of IS : 1293. However, ISI marking on plugs and sockets is not mandatory.

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

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

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

Electronic Clocks with mains power are covered under the scope of IS 302-2-26

Automatic Data Processing Machines cover –

  • Data Preparation Equipment
  • Data Processing Equipment
  • Data Storage Equipment
  • Personal Computer
  • Plotter
  • Printer
  • Scanner
  • VDU

In the products where battery is forming an inseparable part of the product and the host product (e.g. shavers and trimmers) is not covered under the CRO, rechargeable batteries are not covered under CRO.

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.

Mobile phones are sold along with Battery and Adaptor in a single corrugated box. So the overall box / mobile phone itself is required to have BIS Registration Number of the mobile device. However, when the mobile phone battery and adaptor are segregated / separated from the main box / mobile phone, these individual items must also be supporting their respective independent BIS Registration Numbers on them.

Yes, products that do not fall under the scope of other sections (sections 2 to 8) of IS 10322 (Part 5) would be treated as covered under Section 1 (General Purpose Fixed Luminaire). Baylight, Bulkhead etc are covered under LED Flood lights product category.

LED Portable lights are not covered under CRO.

FREQUENTLY ASKED QUESTIONS (FAQs) REGARDING ETA:-

Answer: 'ETA through self-declarationʼ is applicable to the products which comply both the following conditions, i.e.,

  • Exempted from import licensing requirement as per Import Policy of DGFT and;
  • Working in de-licensed frequency band)s (as per applicable Gazette Notifications from Ministry of Communications.

For example: - Mobile handsets, Smartphones, Electronic notepads, Laptops, Smart watches, SRDs including accessories, microphones, headphones, speakers, earphones, printers, scanners, mouse, keyboard, TV, camera, etc.

Answer: The RF test report issued by Accredited Laboratory for the product is required for issuance of ETA. In case the imported product contains multiple RF modules, then test report(s) of all RF modules without any alteration to be uploaded.

Answer: Yes, if it satisfies both the following conditions, i.e.,

  • Exempted from import licensing requirement as per Import Policy of DGFT and;
  • Working in de-licensed frequency band)s (as per applicable Gazette Notifications from Ministry of Communications.

Answer: A product operating in licensed exempt band(s) should have equipment type approval (ETA). In the cases, when the product is manufactured in India and RF module(s) having ETA is/are fitted in it without any modification/alteration; then no separate ETA is required for such finished product. However, if product(s) are manufactured outside India, then ETA is required for each product before its import.

Answer: There is no period restriction for ETA and no further renewal is applicable.

Answer: Such items may be imported by submitting a copy of the existing ETA along with a signed undertaking clearly stating that:-

  • The product contains RF module(s) operating in de-licenced frequency bands only and;
  • The product is exempted from import licence requirement as per Import policy of DGFT.

Answer: Once an ETA is issued for a product either through Self-Declaration or through RLO, it can be used subsequently by other persons for the purpose of import without any additional payment.

Frequently Asked Questions for EPR:-

The new date of implementation for E-waste management rules, 2016 is 1st May 2017.It is applicable to all the producers who were already producing and marketing their products prior to 1st October 2016. However, in case of new Producers, who are planning to setup business post 1st Oct 2016, they have to obtain the EPR Authorization prior to commencing business.

Whose liability is it to take back the e-waste generated by the products sold on their platform?=Most of the e-commerce companies work as a market platform and they do not sell any product under their brand name. The responsibility of taking EEE back from the consumers rests on the brand owner in case the product is sourced from within India. In case they are importing any product/brand from outside India, it is the responsibility of the e-commerce company to take-back and recycle the EEEs.

The responsibility of a third party manufacturer would be for the e-waste discard generated from undertaking the manufacturing at its plant/factory. Since the third party manufacturer does not own the brand, it would not come under the purview of EPR.

Yes, since the manufacturer authorization was not there in the e-waste rules, 2011

Yes, under the provision of the rules, any transportation of e-waste shall mandatorily follow the manifest system.

The technical documents in respect of RoHS compliance should be available with the producer and a declaration can be submitted to CPCB that such technical documents have been maintained. It is not mandated to submit the technical documents to CPCB.

Components or consumables or parts or spares required for the electrical and Electronic equipment placed in the market prior to 1st May, 2014 may be exempted from the provisions of RoHS under sub-rule (1) of rule 16 provided Reduction of Hazardous Substances compliant parts and spares are not available.

The target mentioned under the rules is national target and thus an average of all the states where producer have the business need is to be met.

For the first two years of implementation, the targets are 30% of the total e-waste generated. On pro-rata basis the target for FY2017-18 is 27.5% of the total e-waste generated.

In case a DRS is introduced to make EPR more effective and target based, the producer has toobtain all applicable approvals/permissions as per the laws of India. The deposit and subsequent return to the customer could come under the purview of NBFC activity and hence approvals could be required from the Reserve Bank of India. Also, the producer has to decide an appropriate amount of interest rate to be offered to the customer so that the customer feels incentivised to return the EEE to the producer.

The sub-Rule 1 of Rule 16 is about Reduction of Hazardous substances (ROHS) in the items mentioned in Schedule I. Nowhere in the E-waste Rules it is written that any item listed in Schedule I is exempted from application of these E- waste Management Rules, 2016. Since, fluorescent and other mercury containing lamps are listed in Schedule I as CEEW5, the producers of such items have to comply with the provisions of E-waste (Management) Rules, 2016 as well with the Schedule II with respect to ROHS.

In case you are partially/not compliant with RoHS, you can provide a roadmap to CPCB to be fully compliant at a planned future date. It is highly recommended that you meet RoHS compliance within six months of providing this plan.

The unit for calculation for waste generation and target is either Quantity/Number or Weight or both, and same has to be mentioned in the form for filing annual returns to Central Pollution Control Board.