IS/IEC 62368-1:2023 for Foreign Manufacturers: FMCS Application Guide

Foreign manufacturers of IT and audio/video equipment must obtain BIS CRS registration for IS/IEC 62368-1:2023 compliance. This guide covers both the FMCS route and the Indian importer route.

Two Routes for Foreign Manufacturers

Route 1: Indian Importer Holds the Registration

The Indian importer applies for BIS CRS registration in their own name. The importer is the registrant and bears all compliance responsibility. Foreign manufacturer provides samples for testing and supports documentation but is not directly named in the BIS registration. Faster (10-16 weeks) but importer bears all liability.

Route 2: FMCS — Foreign Manufacturer Holds Own Licence

Under FMCS, the foreign manufacturer applies for and holds the BIS licence directly. This is distinct from the CRS importer route — FMCS applies to products under ISI mark schemes (QCOs), not the CRS registration scheme. For electronics under CRS, the importer typically holds the registration unless the foreign manufacturer has an Indian subsidiary.

For IS/IEC 62368-1:2023 Specifically

IS/IEC 62368-1:2023 products (laptops, TVs, phones) fall under the CRS scheme, not the ISI mark FMCS route. Foreign manufacturers of these products:

• Partner with an Indian importer who registers the product
• Or establish an Indian subsidiary/liaison office that can hold the CRS registration
• Provide samples for testing at a BIS-recognized Indian laboratory
• Support documentation including factory details, quality control procedures

Key Practical Considerations

• BIS CRS registration is in the registrant's name — if the importer changes, the registration must be transferred or a new one obtained
• Product design changes after registration may require notifying BIS and possibly re-testing
• Series model coverage must include all variants the importer sells under that registration