As noted in my previous blog post for the India CRS (Compulsory Registration Scheme), the regulations can seem like they are in a constant state of change. This has ramped up recently with the Registration Scheme and it continues to be something to keep a careful watch on to ensure products being produced and shipped into India continue to meet the current regulations.
There has been the recent expansion in scope which I had noted in my previous post which BIS is working to formalize the exact specifications for. However, we now have the additional onset of the standard changing as well! This time we have a major change that will also affect current registered products as well as any new submittals for BIS Registration. The additional requirements come as part of the Amendment 1 to the IS 13252(Part1):2010 standard and it is now in effect. It should be noted that this Amendment 1 is identical to that of the Amendment 1 to the IEC 60950-1, 2nd edition standard. Therefore, products that were affected by the revised requirements to IEC 60950-1, 2nd edition +A1 would also be affected by the update to IS 13252 to include Amendment 1.
As with many requirements put into place for this registration scheme, there is a short amount of time to comply. As of now, any new applications or inclusions to current registrations submitted to BIS must include a test report from a BIS recognized laboratory that includes the Amendment 1 requirements.
What does this mean for manufacturers?
- If your testing has been completed but the report has not been submitted to BIS, it is very important to work with your test lab to include the Amendment 1 evaluation and possible testing as part of the product’s BIS test report. This is where the relationship of the chosen lab comes into play and you realize the value of a good test lab in working with you to address the changes in a timely fashion.
- If your product is already registered with BIS, the registration must be updated to reflect the addition of Amendment 1. Manufacturers have been given until May 31, 2015 to submit updated test report(s) along with undertaking documents to BIS to review and update the registration. It is best to get the process started as soon as possible to ensure products entering the Indian market are not delayed and will continue to meet your customer’s expectations.
- If the registered manufacturer does not submit the updated test reports and documents to BIS by the May 31 deadline, the registration will be cancelled.
With all the changes taking place at the current time and the potential new backlogs with BIS reviews occurring due to the expanded scope, it is wise to ensure that these additional submittals are planned for in early 2015 to ensure the product meets the deadline and the registration isn’t put in jeopardy.
It is important to note that even if testing according to the Amendment 1 requirements are not required for the product(s), that the evaluation by a BIS recognized test lab must still occur and the test report(s) to Amendment 1 is still required.