FAQs – Generic Issues

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Part - I : Generic Issues

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

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.

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

The products manufactured / imported before the due date of coming into effect of Order are not intended to carry the self declaration.

3- What will happen to goods ordered and expected to come on or after the due date (on account of deferment of shipments) or in transit?

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

4- Who is eligible to get Unique Registration Number – the manufacturer or importer?

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

5- What are list of document and test results to be submitted for registration?

Kindly refer to BIS website http://www.bis.org.in/cert/ProcGrantReg.asp.

6- 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 report 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 test reports issued by BIS Recognised Labs are only accepted for Registration.

7- 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 online as well as physical application for registration.

8- Self-declaration mark will be on the product or packaging?

The Standard Mark/statement shall be placed on the packaging if it is not feasible to place the same on the product for size constraints.

9- What should the label display?

Label should display “Self-Declaration – Conforming to IS…………., R- xxxxxxxxx”, or alternatively, the Standard Mark as notified vide Gazette No.2559 dated 01st December 2015.

10- If manufacturer is manufacturing under multiple brands, is registration required for each brand?

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. (TAC 37).

Please refer to “Process for Registration” under Registration Scheme available

at BIS website www.bis.org.in.

11- If product is certified at one manufacturing location, is it necessary that registration for that same product manufactured at other locations 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 and supported with a test report for product from that manufacturing location.

12- Who will bear the cost of registration?

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

13- Is it required to get the product retested from a lab prior to renewal?

The renewal is done by BIS on submission of renewal application in prescribed format by the registered user. The renewal application along with requisite fee shall be submitted at least one month in advance from the date of expiry of registration. Repeat testing is not specifically envisaged. However, test samples would be picked up for testing during surveillance.

In accordance with para 3 of Order dated 13 Nov. 2014, testing may be needed if test report as per latest version of upgraded standard is not available at the time of renewal.

14- Who is liable for testing of imported products – Importer or Foreign Manufacture?

Once registered by the manufacturing unit, the order allows imports of registered goods by multiple importers. The Registration is for the manufacturers (factory). Hence, it is the responsibility of manufacturer to get the products Registered.

15- 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.

16- 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 or from the local representative of the foreign manufacturer during surveillance.

17- 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 and submission of requisite technical details by the manufacturer for testing the product. Samples for initial registration can be submitted directly to the labs by the Manufacturer. The registration will

promptly be processed by BIS if all submitted documents are in order. Independent samples are picked up only during surveillance process.

18- Can the manufacturer apply for recognition with BIS for its own testing laboratory?

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

19- 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 following appropriate process and product assurance procedures.

20- Which of the BIS recognized labs can be approached for testing of products?

The list of BIS recognised labs for each product / standard is available on BIS

web site http://www.bis.org.in/lab/osladd1.asp.

21- How would identical models with minor changes be accommodated for registration without any testing?

Please refer to the series guidelines for series approvals, which are available on DeitY web site http://deity.gov.in/sites/upload_files/dit/files/Guidelines%20for%20Series%20
Formation%20(2).pdf and http://deity.gov.in/sites/upload_files/dit/files/Revised_SeriesGuidelines_R4_01

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

An updated / supplement test report with alternate sources included in the updated Construction Data Form (CDF) are required to be submitted to BIS for placing such changes on records. BIS recognized labs may also conduct testing if such changes shall have impact on safety considerations of the registered product.

23- Whether FR Grade material is mandatory under the standards?

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

24- 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.

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

Products sent abroad for maintenance are allowed to be brought in without BIS registration number provided the serial number does not change. Faulty units when replaced with new units of a different serial number, the new units would call attention of Order.

26- 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 two years. Original Registration could be revalidated, on request, as per provisions of the scheme.

27- In case plant is outside India, who will communicate with manufacturer?

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

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

The Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012 mandating self-declaration is applicable only to products listed in the Gazette Order notified by the DeitY.

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

The Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012 is a regulatory requirement for placing products on Indian markets.

It does not prohibit the purchaser from specifying additional technical requirements.

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

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 DeitY on
03 Oct. 2012 and 2(a)(2) of amendment order dated 25 June 2013. Other provisions under BIS Act, also apply.

31- 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. However, labs are expected to retain samples collected during surveillance particularly when test results are non-compliant for a period of three months from the date of uploading / issue of such test report to DeitY.

32- What is the retention period of second sample?

This counter sample will be retained by the manufacturer or sample pick up agency till DeitY closes surveillance cycle for that product positively or renewal of registration is granted for the product whichever is earlier.

33- Is there a common format for test reports which all the BIS recognised laboratories have to follow?

BIS issues common formats

34- What are safety critical components?

Typical safety critical components* are –

∙ Power cords

∙ Switches

∙ Safety Isolating Transformers

∙ Fuses

∙ 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.

35- 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. However, complete unit even when sent as replacement of faulty unit would draw the attention of this Order.

36- 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. Reference is made to para 2(b) of Gazette notification dated 05 July 2013 available on DeitY website

37- 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 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. Wherever feasible, BIS has permitted the use of internationally approved components.

38- Will it be possible to get future models included in existing series (as part of 10 models in a 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 –

a. Technical details of the new product along with the existing Series and test report to be submitted to the Labs for validation.

b. Validation report from Lab along with existing registration number for a series needs to be submitted to BIS along with processing fee.

39- Is pocket photo product using AC adopter DC 5V, 1A which is similar to Polaroid camera covered by this order?

This product is not within the scope of the Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012. However, AC adopter and battery used in the camera are covered under the Order.

40- What is “Highly Specialized Equipment” (HSE) and is it covered by this order?

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 –

a. Equipment Powered by Three phase power supply, or

b. Equipment Powered by Single phase power supply with current rating exceeding 16 Ampere, or

c. Equipment with dimensions exceeding 1.5 m x 0.8 m, or d. Equipment with weight exceeding 80 Kg.

41- What kind of batteries are covered under the Order?

The scope of coverage is as defined in the clause 1.1 of the standard IS 16406 :

2012. This is deemed to cover rechargeable batteries / single cells (other than button) like Lithium ion batteries, Nickel-Cadmium and Nickel-Metal Hydride cells.

42- Would cells and batteries require to be independently registered?

These items are required to be independently registered. However, a battery using registered cells would only list cells in the CDF of the battery and testing on registered cell is not expected to be done as part of battery.

43- What is implied by cells of same construction design in series guidelines issued by DeitY?

Cells of same construction design means the shape in which these cells are normally available, i.e. “Cylindrical”, “Prismatic”, etc.

44- What is the definition of portable application? Batteries, cells, power banks themselves are portable but they can be used in non-portable devices laptop, mobile phone, etc.

It is clearly defined in clause 1.3.14 of the standard IS 16046 : 2012 applicable to Secondary Cells/ Batteries. As per the definition “a battery for use in a device or appliance which is conveniently hand carried is a portable battery and cells intended for assembly in a portable battery is a portable cell”. The products laptop, mobile phone are portable appliances as per above definition.

45- How will the battery of a product be tested if it is an integral part of the product and cannot be detached?

If battery is an integral part of the host product and is not detachable, the battery would be tested as a part of the host product itself. More number of samples of host product may be needed in such a case.

46- What registration number will a consolidated product (like laptop / mobile) using the battery and adaptor display?

Registration is required for Power Adaptors & Batteries also, as these are independently notified under CRO, and hence these items must independently

be registered, and in turn, support the registration label. Similarly, the consolidated product (e.g. laptop / mobile) would only bear the registration no. of the overall product, i.e., Laptop/Mobile itself. Label for respective sub parts, like: Adaptor & Battery would independently be visible on these subparts when these items are disintegrated from the main product.

47- Will the host product that are currently registered but utilize unregistered batteries or adaptors be exempted or will they be stopped at customs when the implementation of phase II of Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012 becomes due?

Pre-certified batteries/adaptors would not be accepted after coming into effect of the CRO on these items. For the product, which are already registered with BIS with unregistered batteries/adaptors, only registered adaptors/batteries would qualify subsequently to coming into effect of CRO for Adaptors/Batteries.

48- Will UPS / Inverter only include standalone units or Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012 will also cover UPS / Inverter units that are installed in a host system? Will such components also require registration?

Only standalone UPS / Inverters are covered under Electronics and IT Goods

(Requirement for Compulsory Registration) Order, 2012.

49- Are the plugs and sockets conforming to other International Standards acceptable?

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.

50- How are the power adapters or battery chargers for the products which are not covered under CRO to be treated?

The power adapters or battery chargers for the products not covered under CRO
may be tested for either IS 616 : 2010 or IS 13252 (Part 1) : 2010.

51- Is the latest / revised edition of IEC 62133 (i.e. 2nd Edition) applicable for CRO?

Indian Standard (IS 16046), as adopted and notified by BIS on any date, shall apply.

52- Does BIS Registration require original test report to be submitted for each brand covered based on the common testing report for multiple brands?

For registration of multiple brands, photocopies of original report authenticated by the test lab could be submitted to BIS. (TAC 37).

53- Can the ADP type of sample (e.g., huge servers) be tested on-site at manufacturer’s premises?

The goods covered under CRS are required to be at BIS recognized Labs only. Power supply and other areas of the equipment crucial for electrical safety may be extracted from the equipment and tested separately, in case of such a situation of huge size, etc. (TAC 37).

54- Whether samples of all models, for products covered in a series, need to be submitted to the Labs?

Samples of all models for products covered in a series need not be submitted to the Labs. Worst case sample must be tested and documentary support should be provided to justify the series formation.

55- Whether the pre-certified/pre-registered cells would be accepted for Registration of batteries under CRO?

Registration of cells or their independent testing shall not be insisted while granting registration to the Batteries under the CRO. Cells internationally pre-certified to IEC standards shall continue to qualify for registration of batteries.

The regulation for independent registration of Cells shall come into effect only on the date notified in the CRO after which prohibitions as listed in the CRO shall come into force for Cells.

Part - II : Decisions Related to Product Coverage under the Order

1- 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.

2- 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.

3- 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.

4- 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.

5- 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

6- 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.

7- 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.

8- Are Multi Media Speaker Systems parts of Amplifiers or Electronic Musical Systems?

i) Multimedia Speakers with independent power supply are covered under CRS. ii) Multimedia Speakers with built-in amplifiers and having diverse audio input
connectivity, would also fall in the category of Electronic Musical Systems, and hence are covered under CRS if input power is equal to or more than 200W.

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

The wireless devices like Wi-fi modems, BT headset, BT speakers, BT mouse, USB data card and USB LAN card are not exclusively covered under the scope of Compulsory Registration Order. These items are tested when supplied as accessory to the main system, while approval of the main system itself.

10- 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 –

a. Data Preparation Equipment b. Data Processing Equipment c. Data Storage Equipment
d. Personal Computer *

e. Plotter f. Printer
g. Scanner h. VDU
* Specially exempted from the coverage under the Electronics and IT Goods

(Requirement for Compulsory Registration) Order, 2012.

11- Do high definition video conferencing products need registration under this Order?

Video display units of high definition video conferencing products, if they are
of size 32” and above, fall under the Order.

12- Are digital video recorders (Security products connected with CCTV camera) covered under the Order?

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

13- 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.

14- Are built-in rechargeable batteries which cannot be detached by user (e.g. shavers and trimmers) covered under the Compulsory Registration Order?

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

15- 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?

The products mentioned under a) and b) above are covered under the Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012 dated 13
Nov. 2014. However, items under c) are networking devices and are not covered under this order.

16- Is a home entertainment system consisting of following components to be considered as an Electronic Musical System covered by the Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012? 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.

17- 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.

18- Are PABXs covered by this order?

The PABXs are not covered by the Order.

19- 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.

20- 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.

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

These products are not within the scope of the Order.

22- Do wall mounted video display panels (generally of size 55”) operating together with the controller unit which drives these video panel fall under the ambit of the order?

The wall mounted video display panels (generally of size 55”) operate together with the controller unit which drives these video panels. The video display panels are already covered as video display units of size > 32” whereas the controller is covered under ADP.

23- Is Feature Rich Voice over IP is covered under the Order?

This product is not within the scope of the Order.

24- Are Peripheral devices such as external HDD or Blu-ray drives, Refurbished internal hard disk drive (which forms part of the laptop or personal computer for storage of data) or External hard disk drives (which can be attached to laptops and personal computers for the purposes of taking back up of data) covered by this order?

Such devices with facility for independent power supply and having capability as a stand-alone product would be covered.

25- Are BDU (Bill Dispenser Unit) and GBNA / GBRU (Bill recycler / Deposit Unit) for ATMs covered in the definition for printers requiring registration?

BDU (Bill Dispenser Unit for ATM) and GBNA / GBRU (Bill recycler / Deposit
Unit for ATM) or ATM itself are not covered by the Order.

26- Does Transcoder which distributes content over IP network without the use of compression require registration?

Transcoder distributes content over IP network without the use of compression. This digital platform uses the network to distribute Video, Graphic, Audio and computer data in Raw uncompressed format. This is a telecom device and hence out of scope of Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012.

27- Do Electronic Data Projectors, Electronic Cinema Projectors, Electronic meeting room projectors etc., which are video projection units, require registration?

Electronic Data Projectors, Electronic Cinema Projectors, Electronic meeting room projectors etc., are video projection units and all these are data process equipment and hence are covered under scope of Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012 as ADP machines.

28- Does Network attach storage (NAS) device connected to a computer network for data require registration?

Network attach storage (NAS) device which is connected to a computer network is a data storage device covered under scope of Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012 as ADP machines.

29- Hard Device Media Player (HDMP) is a hard drive enclosure with Hardware and Software for playing audio, video through a home cinema or home theatre PC. This device can be used either as an external hard drive or to play computer based media files without the need for a separate computer. Is this HDMP an ADP machine?

This is data process equipment and hence covered under scope of Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012 as ADP machines.

30- Are All-in-one computers / workstations / thin-clients / mini PCs same as a personal computer?

These cannot be treated as desktop / personal computer because they are structurally different from desktop / personal computer, and hence covered under scope of Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012 as ADP machines.

31- Are digital duplicators covered under Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012?

Digital duplicators work in conjunction with a computer, and thus are functionally printers and scanners, and hence covered under Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012.

32- AV Receivers, Speakers and Sub-woofers are packed and MRP labelled separately when imported. But, they are sold under one brand name and customer has option for mixing and matching of an AV receiver with any different set of speakers or sub-woofers of choice. Are these covered under Order?

These products were being imported as separate items; they may or may not attract the provisions of Order depending upon power rating as specified in schedule ‘A’ of the Electronics and IT Goods (Requirement for Compulsory Registration) Order, 2012.

33- Are power banks with USB covered under the Order?

Power banks with USB charging facility and having no electronic circuit and charge controlling unit etc. within the bank have to be treated as battery for the purpose of the Order and will be tested as per IS 16046. However, power banks supporting internal electronic circuit besides batteries would continue to be treated as Power Banks covered under IS 13252 (Part 1), as notified.

34- Are mobile phone chargers covered under the Order?

Mobile phone chargers are covered under the Order.

35- Can single BIS Registration number be allowed for the corrugated Mobile Sales-Pack?

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.

36- How to carry out the Photometric test (for the purpose of CRS) for fixed General Purpose LED Luminaires as per IS 10322 (Part 5 / Sec 1) : 2012 on LED luminaries / lamps since the parameters in the cross referred standard are not defined to cover LEDs and there is no Indian Standard to indicate method of test for photometry of LED Luminaires? Further, standard LED lamps are also not available.

Photometric test shall stand exempted for the purpose of CRS as the scope of existing Indian Standard IS 13383 (Part 1) does not cover such products.

37- Are luminaire products (such as Baylight, Bulkhead, etc.) covered under CRS, as they do not fall under any section of the standard?

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).

38- Are LED Bulbs with B22/E27/E14 caps only covered under CRS?

LED Bulbs with all type of caps mentioned in Tables I and II of IS 16102 (Part

1) : 2012 are covered.

39- Are Non - Encapsulated LED Drivers as per IS 15885 (Part 2/Sec 13) : 2012 covered under CRS?

Non-Encapsulated LED Drivers if they are not sold as a standalone product in open market are not covered. However, since a final lighting product manufacturer covered by the CRS would need to rely on designs and safety of drivers supplied in non-encapsulated form by respective suppliers,

40- What are the different scenarios in a typical LED luminaire and clarification may be provided on applicability of CRS in such conditions?

Possible Scenario Coverage under CRS
Locally manufactured  LED Driver board (without

encapsulated in box – sub assembly stage) on job work for soldering only. LED Driver not to be sold as finished goods in market.

Not  covered  since  not  sold  as  finished


Locally manufactured  LED Driver board (without

encapsulated in box – sub assembly stage) – original design know-how is under control of supplier. LED Driver not to be sold as finished goods in market.

Not  covered  since  not  sold  as  finished


Locally manufactured LED driver by another agency but encapsulated in box. It could be used for making LED luminaire product by manufacturer. Covered.

Imported LED Driver PCB board with components mounted, but not as finished goods (not encapsulated in box) for direct selling in Indian market.

Not covered if complies with definition of

SKD / CKD product. Such sale is expected to be restricted to manufacturers of luminaires only and not to end users of luminaries.

Imported LED Driver in encapsulated box, but not for

selling  directly  in  market.  It  would  be  used  for making LED luminaire product by manufacturer.

Imported / locally manufactured LED Driver finished goods to be sold directly in market. Covered.
Imported / locally manufactured Self-Ballasted LED

lamp with integral driver. Do drivers need to be tested separately?

No need for separate testing of LED Driver

as long as it is tested as part of Self Ballasted


Imported  /  locally  manufactured  LED  luminaire

(battens + surface mounted luminaires) with integral driver. Do drivers need to be tested separately?

No need for separate testing of LED Driver

in Fixed General Purpose Luminaire, if manufacturer of luminaire is in control of design and production of driver, else he should use a pre-registered driver and notify in CDF (Construction Data Form) in test report.

Non – CRS covered LED Luminaire ( i.e. Recessed

Downlighter + Streetlight + Floodlight) with independent driver (separate driver encapsulated in box).

Drivers covered.
Non – CRS covered LED Luminaire ( i.e. Recessed

Downlighter + Streetlight + Floodlight) with built-in driver (separate driver board, not encapsulated separately but within the luminaire fixture). Do (this sub-assembly) drivers need to be tested separately since not being sold as loose driver in market and the complete product is not covered under CRS Scheme.

Non – encapsulated LED Drivers (built-in

type) are not covered provided it complies with definition of SKD / CKD product.


Drivers imported by trading company and sold to local OEM who is then exporting complete luminaire.

Such  products  would  normally  land  in

bonded territory and not covered, since CRS is not applicable to products manufactured for exports.

LED  Luminaire  ( i.e.   battens  +  surface  mounted

luminaires) with or without Integral Driver.

Fixed   General   Purpose   Luminaires   are


Non – CRS covered LED Luminaire ( i.e. Recessed

Downlighter   +   Streetlight   +   Floodlight)   with independent or built-in LED Driver.

Built-in type drivers for such products are

covered if sold in open market.

Independent type (encapsulated) driver are covered even when sold as spares.

LED   Luminaire   used   for   industrial   /   outdoor

application ( i.e. Bay Light) or for hospitality / home usage ( i.e. Chandelier).

Self-Ballasted Lamp with Integral Driver Covered.

41- Whether Solar Inverter (< 5KVA) used for Solar application is covered under CRO?

Solar inverters are covered under the standard IEC 62109, which is not mandated under CRS. Therefore, it is not covered under the scope of CRO. (TAC 30).

42- Whether BIS Registration is mandatory for the power supply (a detachable module) to be imported separately to be used with servers? The server has the option for both AC & DC power supply module that can be pulled out (detachable) from the enclosure?

Functionally, this device is identical to Adaptors. Hence, if this device is imported as a standalone device, it stands covered under CRO. (TAC 30).

43- Whether different capacities of cell (e.g. one cell of 2400mAh & other of 3000mAh) or one or two cells of different model can be used in the battery if there is no change in the output voltage?

Cells of different manufacturer, capacity, size or type cannot be mixed as per good advices to manufacturer at Annex A(h) of IS 16046.

44- Whether the cell having a protective device (i.e., PTC, attached as an integral part of the cell to protect it from over charging) is covered under IS 16046 and whether PTC is required to be treated as Critical Component and reported in the test report?

The rechargeable alkaline cells of all types (including those having some special circuitry, i.e. PTC) are covered under IS 16046. PTC in such a case is required to be treated as Critical Component and reported in the test report.

45- Whether LED lighting chains used in Christmas and New Year are covered under the Order?

The CRO has notified only IS 10322 (Part 5/Section 1) on Fixed General Purpose Luminaires, Sections 2 to 8 of the Standard are not covered under the ambit of CRO. Lighting Chains are covered by Section 7 of Standard.

46- Are 3D Scanners (used for making images for 3D printing), covered under the Order?

3D scanners are covered under the Order.

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