DPIIT Introduces Transition Facilitation QCO: A Simpler Route to BIS Certification for products covered under Specified Quality Control Orders

Under the Bureau of Indian Standards Act, 2016 ("BIS Act") and the Bureau of Indian Standards (Conformity Assessment) Regulations, 2018 ("BIS Regulations"), manufacturers of goods covered under notified Quality Control Orders ("QCOs") are required to obtain a BIS licence to use or apply the Standard Mark before manufacturing, importing, selling, distributing or otherwise placing such goods in the Indian market.

Under the existing framework, products covered by most Quality Control Orders (“QCOs”) are required to obtain BIS certification under Scheme I, which involves a rather lengthy and complex process of grant of a licence requiring the physical assessment of the manufacturing facility, testing of product samples and verification of compliance with the applicable Indian Standard ("IS"). In contrast, Scheme II provides a comparatively simplified registration-based certification mechanism under which the manufacturer obtains registration based on self-declaration of conformity, subject to compliance with the prescribed requirements. Until now, this route has generally been available only for specific products notified by the Government. 

To strengthen India's quality ecosystem and enhance industrial competitiveness, the Department for Promotion of Industry and Internal Trade (“DPIIT”) has notified the Transition Facilitation (Quality Control) Order, 2026 ("Transition QCO”).

Earlier, manufacturers supplying products covered under the specified QCOs notified by DPIIT (listed in Annexure-A) were required to obtain BIS certification under Scheme I. Whereas, the Transition QCO provides manufacturers supplying goods covered under specified QCOs to permitted companies with an option to obtain BIS certification under Scheme II. The specified QCOs broadly relate to sectors such as toys, air conditioners, footwear, electrical appliances, hinges and furniture.

The benefit under the Transition QCO is available only through a permission-based mechanism. Broadly, the following conditions must be satisfied:

1. the products are covered under one of the specified QCOs;
2. the goods are supplied to an eligible company that has obtained permission from DPIIT; and
3. the manufacturer obtains the requisite BIS licence under Scheme II for the relevant goods.

Permission for procuring companies is granted by DPIIT based on the recommendations of an Implementation Committee (“Committee”) constituted under the Transition Order. 

The Committee comprises representatives from DPIIT, Department of Consumer Affairs, Department of Commerce, Directorate General of Foreign Trade, Bureau of Indian Standards and other concerned Ministries/ Departments. 

While evaluating applications, the Committee considers, inter alia: 

• technical capability, demonstrated experience; 
• manner of ensuring quality assurance across its supply; 
• history of conduct and compliance integrity; 
• commitment towards establishing manufacturing or supply chain capabilities in India;
• continuous compliance with the relevant QCO for at least 3 years; 
• any other relevant factors, including protection of human, animal or plant health, safety of the environment, prevention of unfair trade practices, and national security.

The recommendations of the Committee are submitted to Union Minister of Commerce and Industry for approval.

Eligible Applicant: 

A company incorporated under the Companies Act, 2013.

Application: 

Applications are required to be submitted in the prescribed form through the designated online portal or, until such facility is operational, in physical form together with the prescribed supporting documents.

Key information to be furnished: 

The application is required to provide, inter alia: 

• products for which permission is sought;
• annual quantity proposed to be supplied;
• applicable 8-digit ITC (HS) codes; and
• details of the manufacturing facilities from which the goods will be supplied.

Approval:

Upon approval, DPIIT will issue a permission letter specifying, inter alia:

• approved products;
• quantity limits;
• milestones;
• validity period;
• approved manufacturer(s);
• reporting requirements; and
• other applicable terms and conditions.

The permission is, inter alia, subject to cooperation with BIS market surveillance and compliance with the applicable import-export and foreign direct investment policies.

Key timelines:

Companies granted permission under the Transition QCO are required to:

• ensure continued conformity with the applicable IS(s) and the conditions specified in the permission;
• submit quarterly details regarding consignments and the BIS licence status of manufacturers; and
• furnish an annual compliance report certified by a practising Chartered Accountant within 60 days from the end of each year.

Permission granted under the Transition QCO may be suspended, modified or withdrawn where:

• material misrepresentation is discovered, 
• the product fails to conform to the applicable IS(s), 
• non-compliance is identified during review or market surveillance; or
• the conditions or milestones specified in the permission are not fulfilled.

The Transition QCO represents a significant policy initiative aimed at balancing regulatory oversight with ease of doing business. By permitting eligible companies to procure goods from manufacturers certified under Scheme II, instead of Scheme I, in specified cases, the framework introduces an alternative certification route without diluting compliance with the applicable Indian Standards.

From an industry perspective, the framework offers several practical advantages:

a. Reduced certification timelines and greater sourcing flexibility:

Companies granted permission under the Transition QCO may procure goods from manufacturers holding BIS certification under Scheme II, instead of requiring manufacturers to obtain certification under Scheme I.  This is expected to simplify procurement, reduce certification timelines and facilitate faster market access while maintaining compliance with the applicable Indian Standards.

b. Recognition of established compliance: 

Uninterrupted QCO compliance is recognised as eligible criteria for obtaining permission, without requiring the Companies to demonstrate investment commitments.

c. Recognition of technology and manufacturing capabilities:

The framework also recognises companies committed to establishing design, technology, research and development, and manufacturing or supply chain capabilities in India. This is expected to encourage technology transfer, innovation and indigenisation while strengthening domestic manufacturing ecosystems.

d. Facilitative regulatory framework: 

The Transition QCO establishes a structured approval mechanism through DPIIT with clearly defined eligibility criteria, approval timelines and continuing compliance requirements. The framework remains in force for a period of five years, providing businesses with an opportunity to strengthen domestic manufacturing and supply chain capabilities through a structured transition mechanism.

e. Regulatory certainty: 

Permissions granted prior to the Transition Order's rescission continue to remain valid for the period specified therein, providing certainty of operations.

The effectiveness of the framework will ultimately depend on its implementation in practice and the consistency with which permissions are granted and monitored. Businesses operating in the relevant sectors should closely monitor developments as the Transition QCO is operationalized.

1. Toys (Quality Control) Order, 2020
2. Personal Protective Equipment - Footwear (Quality Control) Order, 2020
3. Air Conditioner and its related Parts, Hermetic Compressor and Temperature Sensing Controls (Quality Control) Order, 2019 
4. Footwear made from All Rubber and all Polymeric Material and its components (Quality Control) Order, 2024 
5. Footwear made from Leather and other Materials (Quality Control) Order, 2024 
6. Electrical appliance for domestic water heating (Quality Control) Order, 2025 
7. Electrical appliance for domestic clothes washing (Quality Control) Order, 2024
8. Hinges (Quality Control) Order, 2025 
9. Furniture (Quality Control) Order, 2025
10. Safety of Household, Commercial and Similar Electrical Appliances (Quality Control) Order, 2026