BIS ISI Mark certification is mandatory for all toys in India under the Toys (Quality Control) Order, 2020, which came into force on 1 September 2020. Every toy manufacturer — Indian or foreign — must obtain the ISI Mark licence before toys can be manufactured, imported, or sold in India. Toys are categorised as Non-Electrical (governed primarily by IS 9873 Parts 1, 2, 3, 4, 7, and 9) and Electrical (additionally governed by IS 15644:2006). The current mechanical safety standard is IS 9873 (Part 1):2025 (aligned with ISO 8124-1) — which runs concurrently with the 2019 edition until 22 March 2027, after which only the 2025 version will be accepted for new licences. The certification covers toys for children under 14 years. Foreign manufacturers must apply under the FMCS scheme and appoint an AIR. Non-compliance carries product seizure, fines, and prosecution under the BIS Act, 2016 — BIS had conducted 159 search-and-seizure operations targeting toys as of June 2025.
The Indian toy market is one of the most closely watched consumer product sectors in India's regulatory landscape — and with good reason. Toys are the single consumer product category most directly associated with child safety, and the government's commitment to protecting children from mechanical hazards, toxic chemicals, flammability risks, and electrical dangers has made the Toys QCO 2020 one of the most rigorously enforced quality control orders in the country.
For toy manufacturers and importers, the ISI Mark is the only path to legal market access — and with BIS conducting active market surveillance, port-of-entry checks, and factory inspections, compliance is not a matter of choice. This guide covers the complete certification picture: the applicable standards, the safety tests, the process, the fees, and the step-by-step path from toy manufacturer to ISI Mark holder.
📑 Quick Navigation
- The Toys Quality Control Order 2020
- What Is BIS ISI Mark Certification for Toys?
- The ISI Mark — Anatomy and Significance
- 7 Applicable Indian Standards — Explained
- IS 9873 (Part 1):2025 — The Standard Transition You Must Plan For
- Types of Toys Covered
- Why BIS Certification Is Important for Toy Manufacturers
- Who Needs BIS Certification? Eligibility Requirements
- In-House Testing Facility Requirements
- Document Checklist
- Fee Structure
- 7-Step BIS Toy Certification Process
- Certification Guidelines by Stakeholder Type
- BIS Enforcement, Surveillance, and Renewal
- Consequences of Non-Compliance
- How Rego Services Supports Your Certification
- Frequently Asked Questions
The Toys Quality Control Order 2020
The Toys (Quality Control) Order, 2020 was issued by the Ministry of Commerce and Industry under the BIS Act, 2016. It came into force on 1 September 2020 and made BIS ISI Mark certification mandatory for all toys manufactured for sale, imported, sold, or distributed in India.
The Toys QCO 2020 covers toys designed for children under 14 years of age. Every such toy — whether manufactured in India or imported — must carry a valid ISI Mark before it can be sold in India. The ISI Mark is not a voluntary quality signal for toys — it is the mandatory legal condition for market access.
The Toys QCO 2020 applies equally to domestic manufacturers and foreign exporters. Indian manufacturers apply under BIS Scheme I (Domestic Certification). Foreign manufacturers apply under the Foreign Manufacturers Certification Scheme (FMCS) with a physical application to BIS headquarters in New Delhi and mandatory appointment of an AIR.
Two categories are exempt: (1) toys produced exclusively for export (not for sale in India); and (2) toys sold by artisans registered with the Office of the Development Commissioner (Handicrafts). As per the October 2024 amendment, up to 300 toy samples per year (maximum 5 units per type) may be imported without a BIS licence for R&D purposes only — they cannot be sold and must be disposed of as scrap after evaluation.
BIS enforces the Toys QCO through regular market surveillance, factory inspections, and enforcement raids across India. As of June 2025, BIS had conducted 159 search-and-seizure operations targeting non-compliant toy manufacturers and sellers. Of over 17,000 toy samples tested since January 2021, approximately 91% were found compliant.
What Is BIS ISI Mark Certification for Toys?
BIS ISI Mark certification for toys is the mandatory product certification system under which toy manufacturers demonstrate that their products comply with Indian safety standards before placing them in the market. BIS evaluates both the product (through independent laboratory testing) and the manufacturing facility (through factory inspection) — and if both satisfy the requirements, an ISI Mark licence is granted.
BIS ISI Mark certification is granted only to the manufacturer of the toy — not to importers, traders, distributors, or online sellers. Each combination of manufacturer, factory address, and toy category requires its own separate BIS licence number.
If a manufacturer operates multiple factories, a separate licence is required for each location. Separate applications are also required for electrical and non-electrical toy categories — a manufacturer producing both needs at minimum two licences per factory.
Foreign toy manufacturers must apply under the Foreign Manufacturers Certification Scheme (FMCS) with a physical application to BIS headquarters in New Delhi and must appoint an Authorised Indian Representative (AIR) who manages the certification and ongoing compliance in India.
The initial certification process typically takes 30 to 60 working days from complete application submission. Once granted, the ISI Mark licence is subject to periodic surveillance inspections and market sample testing to verify ongoing compliance throughout the licence validity period.
The ISI Mark — Anatomy and Significance
The ISI Mark on BIS-certified toys is not just a logo — it is a structured regulatory identifier containing two essential elements that enable BIS, enforcement authorities, consumers, and retail buyers to verify the validity and scope of the certification.
Illustrative — not an actual licence
Two Elements of Every ISI Mark on Toys
7 Applicable Indian Standards — Explained
BIS toy certification under the Toys QCO 2020 is based on seven key Indian Standards aligned with ISO and IEC international norms. Understanding what each standard addresses — and why it protects children — is essential context for manufacturers preparing their products and testing programmes.
Aligned with ISO 8124-1. Covers mechanical and physical hazards — sharp edges, sharp points, protrusions, structural integrity, small parts (choking risk for children under 36 months), projectile hazards, and folding/hinging mechanisms. Valid from 22 March 2025; replaces the 2019 edition for new licences from 22 March 2027.
Specifies flammability requirements — ensuring toys do not catch fire easily or sustain burning in contact with a small flame source. Critical for stuffed toys, doll clothes, fabric-based play items, and foam-filled toys where rapid fire spread could injure a child before they can react.
Specifies migration limits for hazardous chemical elements — lead, cadmium, mercury, chromium VI, barium, arsenic, antimony, and selenium — in toy materials. Protects children from toxic chemical exposure through mouthing, sucking, and prolonged skin contact. Aligned with EN 71-3.
Specifies safety requirements for swings, slides, climbing frames, seesaws, rocking toys, and similar indoor and outdoor activity equipment that bears the weight and dynamic loads of children during play — covering structural integrity, anchoring, impact resistance, and fall height considerations.
Specifies non-toxicity and safety requirements for finger paints and similar aqueous-based craft materials — covering chemical composition, absence of harmful substances, and microbial safety for craft materials intended for direct skin contact during use by young children.
Specifies restrictions on phthalate ester plasticisers (DEHP, DBP, BBP, DINP, DIDP, DNOP) in toy materials that may be mouthed, sucked, or in prolonged skin contact — protecting children from endocrine-disrupting chemical exposure through the soft PVC materials widely used in children's products.
Specifies electrical safety requirements for battery-operated and mains-connected electric toys — covering insulation, earthing, motor protection, temperature limits, battery compartment design, creepage and clearance distances, and protection against electric shock hazards. Applied in conjunction with IS 9873 Parts 1, 2, 3, 4, 7, and 9.
| Toy Type | Primary Standard | Secondary Standards |
|---|---|---|
| Non-Electrical Toys | IS 9873 (Part 1):2025 — Mechanical & Physical Safety | IS 9873 Parts 2, 3, 4, 7, and 9 |
| Electrical Toys | IS 15644:2006 — Safety of Electric Toys | IS 9873 Parts 1, 2, 3, 4, 7, and 9 |
IS 9873 (Part 1):2025 — The Standard Transition You Must Plan For
IS 9873 (Part 1):2025 is the updated mechanical and physical safety standard for non-electrical toys, aligned with ISO 8124-1. It was published in March 2025 and currently runs concurrently with IS 9873 (Part 1):2019 until 22 March 2027. After that date, BIS will only grant new ISI Mark licences under the 2025 version. All new applicants are strongly advised to apply under IS 9873 (Part 1):2025 now. Manufacturers already licensed under the 2019 standard must transition to the 2025 version before March 2027 to maintain their certification without interruption.
New toy manufacturers and importers applying for BIS ISI Mark certification in 2025 or 2026 should apply under IS 9873 (Part 1):2025 — not the 2019 edition. This avoids the need to re-test and re-apply in 2027 and ensures the licence remains valid beyond the March 2027 transition date.
Manufacturers holding existing BIS licences under IS 9873 (Part 1):2019 must plan and execute their transition to IS 9873 (Part 1):2025 before 22 March 2027. This requires fresh testing under the updated standard and a BIS licence amendment or renewal application. Rego Services manages the transition process as a structured compliance engagement.
Types of Toys Covered Under BIS Certification
BIS ISI Mark certification applies to the full range of toys intended for children under 14 years of age. All of the following product types require a valid BIS licence before they can be manufactured for sale or imported in India.
Why BIS Certification Is Important for Toy Manufacturers
Toys cannot be legally manufactured, imported, or sold in India without a valid ISI Mark licence. Non-compliance results in seizure, fines, and prosecution under the BIS Act, 2016. This is not a risk management option — it is a binary legal boundary.
BIS certification ensures rigorous independent testing for mechanical hazards (choking, sharp edges), toxic chemicals (lead, cadmium, phthalates), flammability risks, and electrical safety — protecting children under 14 from the full spectrum of toy-related hazards.
Customs authorities verify BIS certification at every point of import. Toys without the ISI Mark are held or rejected at ports of entry — creating immediate supply disruption, demurrage costs, and logistical crises for importers unprepared for compliance.
Major Indian e-commerce platforms (Amazon, Flipkart, Meesho) and large toy retail chains require BIS certification for toy listings. ISI-marked toys gain faster shelf access, fewer listing restrictions, and stronger buyer confidence at point of sale.
BIS toy standards are aligned with ISO 8124 and IEC international norms — helping manufacturers who achieve BIS certification also position their products for export certification to European (EN 71) and other major markets with comparable standards frameworks.
With 159 enforcement operations and over 17,000 toy samples tested since 2021 — and a 91% compliance rate suggesting vigorous market penetration — the risk of operating without BIS certification is not theoretical. Enforcement is active, systematic, and expanding.
Who Needs BIS Certification? Eligibility Requirements
BIS ISI Mark certification for toys is required by Indian manufacturers producing toys at factories within India, foreign manufacturers exporting toys to the Indian market (under the FMCS scheme), and global toy brands whose products are manufactured and sold in India. Importers, distributors, and online sellers cannot hold the ISI Mark licence in their own name.
An active, operational manufacturing facility ready for BIS inspection — not a trading unit, warehouse, or design studio. BIS visits the factory to verify manufacturing infrastructure, production processes, and quality control systems. There is no certificate without a manufacturable facility.
The toy must meet the requirements of IS 9873 (Part 1):2025 for non-electrical toys or IS 15644:2006 for electrical toys — verified through independent laboratory testing as part of the BIS certification process. Products that fail the tests must be redesigned before certification can be granted.
The BIS Scheme of Inspection and Testing (SIT) specifies certain tests that manufacturers must be able to perform in-house at their own facility. Compliance with the SIT facility requirements is a mandatory precondition for BIS inspection — factories without the required in-house testing equipment will fail the audit.
Documented QC processes, trained QC personnel, production records, raw material test records, and in-process testing logs are required at the BIS factory inspection. A functioning quality management system — not just physical equipment — is essential for a successful audit.
In-House Testing Facility Requirements
The BIS Scheme of Inspection and Testing (SIT) specifies that certain tests must be conducted within the manufacturer's own in-house testing facilities — not only at external BIS-approved laboratories. This is one of the most critical eligibility requirements that manufacturers frequently overlook until the BIS auditor arrives at their factory.
BIS certification for toys is not simply about passing a one-time laboratory test — it is about demonstrating that the manufacturer has the ongoing capability to verify the safety of their products throughout production. The SIT framework ensures that manufacturers do not simply test pre-production prototypes for certification purposes while running unchecked production afterwards. In-house testing equipment allows BIS auditors to verify during the factory inspection that the quality control processes are operational, calibrated, and in active use.
Non-electrical toy manufacturers must maintain in-house testing facilities that meet the requirements specified in the SIT document for IS 9873 (Part 1):2025 — covering equipment for mechanical and physical safety testing such as small parts cylinders, torque testers, sharp point and sharp edge gauges, and bite force simulation apparatus.
Electrical toy manufacturers must maintain in-house testing facilities meeting the SIT specifications for IS 15644:2006 — including electrical safety testing equipment, insulation resistance measurement, temperature measurement capability, and leakage current measurement.
All in-house testing instruments must hold current, valid calibration certificates at the time of BIS factory inspection. An instrument with an expired calibration certificate is treated as non-operational for audit purposes — a deficiency that can delay certification until calibration is renewed and documented.
Tests not covered by the in-house SIT facility must be conducted at a BIS-recognised laboratory. The BIS auditor selects and sends representative samples to the laboratory during the factory audit visit — manufacturers do not submit samples independently; the BIS auditor controls the sample selection and dispatch process.
Document Checklist for BIS ISI Mark Certification of Toys
- Factory registration certificate or manufacturing licence — Official documentation confirming the legal registration and operating status of the toy manufacturing facility.
- Company registration documents — GST registration certificate, certificate of incorporation (for companies), partnership deed (for partnerships), or proprietorship declaration — confirming the legal entity structure of the applicant.
- Identity proof of authorised signatory — Government-issued photo identification for the person authorised to sign the BIS application and all related declarations on behalf of the company.
- Factory layout plan — A floor plan of the manufacturing facility showing production areas, storage, testing room, raw material receipt, and finished goods zones — required for BIS's pre-audit planning.
- Manufacturing process flow chart — A documented flowchart of the complete manufacturing process from raw material receipt through production stages to finished toy inspection and packaging — demonstrating the production process BIS will inspect.
- List of manufacturing machinery with specifications — A comprehensive list of all production machinery in use at the facility, with make, model, capacity, and specification details — reviewed by BIS auditors to assess manufacturing capability.
- In-house testing equipment list with calibration certificates — A complete list of all in-house testing equipment held by the facility, with current calibration certificates for each instrument confirming that all equipment meets SIT requirements and is calibrated to the applicable Indian Standard.
- Quality control parameters and records — Documentation of all QC checkpoints in the manufacturing process, acceptable quality levels (AQLs), rejection and rework procedures, and sample production records demonstrating that QC is actively practised — not just documented.
- Laboratory test records and reports (as per BIS norms) — Available pre-certification test records or reports from BIS-recognised laboratories for the toy products being certified — used as supporting evidence during document scrutiny and factory audit preparation.
- Product model specifications and design details — Technical specifications for all toy models to be covered under the BIS licence, including dimensions, weight, materials, age group, construction method, and all safety-relevant design features.
- Raw material specifications and test certificates — Specifications of all raw materials used in toy manufacture — plastics, fabrics, paints, stuffing, electronic components — with test certificates demonstrating that incoming materials meet the chemical and safety requirements of the applicable IS standards.
- Trademark registration certificate (if applicable) — Copy of the registered trademark for the brand under which the toy is marketed — required if the ISI Mark is to be applied alongside a specific brand name on toy packaging.
- Board resolution or authorisation letter — A board resolution (for companies) or authorisation letter authorising the signatory to apply for and manage the BIS certification on behalf of the legal entity.
- AIR appointment documents (foreign manufacturers only) — The formal AIR appointment letter, AIR company registration proof, and photo ID of the AIR's authorised signatory — mandatory for all foreign manufacturers applying under the FMCS scheme.
Fee Structure for BIS ISI Mark Certification of Toys
The following government fees are prescribed by BIS for ISI Mark certification of toys. Note that these are the official BIS government fees — additional costs including laboratory testing charges, marking fees (based on production scale), and professional consultancy fees apply separately.
| S. No. | Fee Type | Amount (INR) | When Payable |
|---|---|---|---|
| 1 | Application Fee | INR 1,000/- | At time of application filing |
| 2 | Annual Licence Fee | INR 1,000/- | At licence grant and every year at renewal |
| 3 | Renewal Application Fee | INR 1,000/- | After first year and with each subsequent renewal |
| 4 | Minimum Marking Fee | As Applicable (Scale-Based) | 50% at application, 50% at grant; annually at renewal. MSME concessions: Micro — 80% off; Small — 50% off; Medium — 20% off |
| 5 | Sample Testing Fee | As Applicable (Lab Charges) | Charged by the BIS-recognised laboratory for testing samples drawn during the factory audit |
7-Step BIS Toy Certification Process
The BIS ISI Mark certification process for toys follows seven defined steps. Domestic manufacturers apply online through the BIS ManakOnline portal. Foreign manufacturers submit a physical application to BIS headquarters. The typical timeline is 30 to 60 working days from complete application submission — shorter for well-prepared domestic manufacturers, longer for foreign manufacturers due to international inspection scheduling.
Compile all required documentation — factory registration, company registration, authorised signatory identity, factory layout plan, manufacturing process flowchart, machinery list, in-house testing equipment list with current calibration certificates, QC records, product specifications, raw material test certificates, and AIR appointment documents (for foreign manufacturers). Ensure every document is current, accurate, and internally consistent before filing.
Domestic manufacturers apply online via the BIS ManakOnline portal. Foreign manufacturers submit a physical application to BIS Foreign Manufacturers division at BIS headquarters, New Delhi. Pay the application fee of INR 1,000 and 50% of the minimum marking fee at this stage.
BIS reviews the submitted application and supporting documents for completeness and consistency. Any missing information, inconsistencies, or clarification queries from BIS must be responded to promptly and accurately — delayed responses are a common cause of extended processing timelines at this stage.
BIS nominates an auditor who conducts a comprehensive factory inspection — verifying manufacturing infrastructure, in-house testing equipment and calibration status, quality control systems, raw material controls, production records, and process flow compliance with the applicable IS standard. A well-prepared factory with comprehensive, readily accessible documentation significantly reduces both audit duration and the risk of non-conformity findings.
The BIS auditor draws representative toy samples during the factory audit visit. Samples are selected by the auditor, sealed, and dispatched to a BIS-recognised laboratory for independent testing — manufacturers do not select, prepare, or submit samples independently. This ensures the tested samples are genuine production outputs rather than purpose-built pre-production units.
The BIS-approved laboratory tests the drawn samples against all applicable clauses of IS 9873 (Parts 1, 2, 3, 4, 7, and 9) for non-electrical toys, or IS 15644:2006 plus the IS 9873 suite for electrical toys — covering mechanical and physical safety, flammability, chemical element migration, phthalate limits, and electrical safety as applicable.
BIS evaluates the factory audit report and laboratory test results together. If both are satisfactory — no major non-conformities at the factory and no test failures in the lab — BIS grants the ISI Mark licence. The manufacturer pays the remaining fees (50% of marking fee balance and annual licence fee) and receives the CM/L-XXXXXXXXXX licence number authorising application of the ISI Mark on toys produced at the certified facility.
Certification Guidelines by Stakeholder Type
- Ensure toy product is under the Toys QCO 2020 mandatory list and tested by a BIS-recognised lab
- Apply online via BIS ManakOnline portal with complete factory documentation
- Maintain compliant in-house testing facilities per SIT requirements before audit
- Apply under IS 9873 (Part 1):2025 (not 2019) for all new applications to avoid re-testing in 2027
- Use the CM/L-XXXXXXXXXX mark only after BIS licence is formally granted
- Must appoint an Authorised Indian Representative (AIR) before application
- Submit a physical application to BIS Foreign Manufacturers division at BIS HQ, New Delhi
- BIS auditor conducts factory inspection at the overseas manufacturing facility
- Product samples are tested at a BIS-recognised laboratory in India
- Registration issued in the manufacturer's name with AIR details on record at BIS
- Importers cannot apply for BIS certification directly — only manufacturers are eligible
- Obtain and maintain a copy of the manufacturer's valid BIS ISI Mark licence for compliance
- Can act as AIR if formally appointed and authorised by the foreign manufacturer
- Must verify that the specific toy model and brand being imported is covered by the BIS licence held by the manufacturer
- Ensure ISI Mark is correctly displayed on all imported toy packaging and products
- Not eligible to apply directly — BIS certification must be done by the manufacturer
- Must maintain a copy of the manufacturer's BIS licence for every toy product they stock or list
- Can act as AIR if formally authorised by the manufacturer
- For e-commerce listings: valid BIS certification documentation is required by major platforms as a mandatory listing condition for toys
- BIS conducts market surveillance of retail channels — non-compliant toys at retail level attract immediate enforcement action
BIS CRS Registration for Crystalline Silicon PV Modules India 2026 — Complete Guide
For manufacturers with diversified product portfolios that include both toys and electronics, Rego Services manages BIS ISI Mark certifications under the Scheme I and FMCS frameworks alongside BIS CRS registrations for electronics. See our guide to BIS CRS Registration for PV Modules for an example of the CRS framework for a different product category.
BIS Enforcement, Surveillance, and Renewal
BIS enforcement of the Toys QCO 2020 is among the most active and systematic of any QCO category in India. The scale of enforcement has grown significantly since September 2020 — and the data demonstrates both the reach of BIS surveillance and the high compliance rate that vigorous enforcement has driven.
Surveillance After Licence Grant
BIS ISI Mark certification for toys is not a one-time approval — it is an ongoing regulatory relationship that includes post-certification surveillance to verify continued compliance throughout the licence validity period.
- Scheduled factory inspections — BIS auditors conduct periodic planned surveillance visits to the manufacturing facility to verify ongoing compliance with quality control processes and in-house testing practices.
- Surprise factory inspections — BIS may conduct unannounced factory visits between scheduled surveillance cycles to verify that the production standards maintained during certification audits are representative of normal operations.
- Market sample testing — BIS purchases ISI-marked toys from retail outlets and tests them in BIS-recognised laboratories. Toys bearing the ISI Mark that fail market surveillance tests may result in licence suspension or cancellation.
- Production record review — Surveillance visits include review of production records, QC logs, in-house test records, and raw material certificates to verify the quality management system is being actively maintained.
Licence Renewal
The BIS ISI Mark licence for toys must be renewed periodically. Failure to renew or maintain compliance during surveillance may result in licence suspension or cancellation, requiring the manufacturer to immediately cease use of the ISI Mark — with immediate legal and commercial consequences for ongoing production and distribution.
Consequences of Non-Compliance
BIS and enforcement authorities have statutory power to seize non-compliant toys — those without the ISI Mark, or with an invalid or counterfeit ISI Mark — at manufacturers, warehouses, distributors, retail stores, or e-commerce fulfilment centres. With 159 enforcement operations conducted by June 2025, seizure risk is active and material.
Imported toys without valid BIS ISI Mark certification are refused customs clearance at Indian ports and airports. Held consignments incur demurrage, create supply disruption to retail buyers, and cannot be released without obtaining valid certification — which cannot be retroactively applied to goods already in customs detention.
The BIS Act, 2016 prescribes monetary penalties for manufacturing, importing, or selling toys without valid ISI Mark certification. Penalties escalate for repeat violations and wilful non-compliance, and can be assessed against both the corporate entity and responsible individual officers.
For serious, repeated, or wilfully deliberate non-compliance with the Toys QCO 2020, the BIS Act, 2016 provides for imprisonment of the responsible persons — making the personal legal exposure dimension of non-compliance a material risk consideration for directors, importers, and proprietors in the toy supply chain.
How Rego Services Supports Your BIS Toy Certification Journey
BIS ISI Mark certification for toys involves complex multi-standard compliance, precise in-house testing facility preparation, a demanding factory audit, independent laboratory testing across up to 7 Indian Standards, and ongoing surveillance management. Rego Services Private Limited manages the complete certification journey for toy manufacturers — Indian and foreign — ensuring every step is executed correctly, efficiently, and without avoidable delay.
- Standard selection and IS 9873:2025 transition advisory — We confirm the applicable IS standards for your toy category, advise on whether to apply under IS 9873 (Part 1):2025 or the 2019 edition (and strongly recommend the 2025 edition for all new applications), and manage the transition process for existing licence holders ahead of the March 2027 deadline.
- Scope and eligibility assessment — We review your toy product range, manufacturing setup, and in-house testing capability against BIS SIT requirements to identify any gaps that need to be addressed before the factory audit — preventing audit failures and certification delays.
- Documentation preparation and review — We prepare and review the complete documentation set — factory registration, process flowchart, machinery list, testing equipment and calibration records, QC documentation, product specifications, raw material certificates, and AIR documents — ensuring full internal consistency before BIS filing.
- Factory audit preparation — We prepare your manufacturing facility and quality team for the BIS factory inspection — ensuring in-house testing equipment is calibrated and SIT-compliant, production records are complete, and QC documentation is structured for efficient BIS auditor review.
- BIS application filing — Domestic (ManakOnline) and Foreign (FMCS physical) — We manage the complete BIS filing process for both Indian manufacturers (ManakOnline portal) and foreign manufacturers (FMCS physical application to BIS HQ) — handling all portal interactions, fee payments, and document uploads.
- BIS scrutiny query response — We respond to all BIS document scrutiny queries and clarification requests promptly and accurately, drawing on our experience with IS 9873 and IS 15644 certifications to resolve queries in the fewest possible rounds.
- Laboratory coordination (for pre-certification testing) — Where manufacturers wish to conduct pre-certification testing before formal BIS sample draw — to identify and address compliance issues in advance — we coordinate with BIS-recognised laboratories and manage the testing programme.
- AIR services for foreign manufacturers — We provide or coordinate AIR appointment and services for toy manufacturers based outside India, satisfying BIS's mandatory Indian regulatory liaison requirement for the FMCS certification process.
- Post-certification surveillance management — We maintain compliance calendars for your BIS toy licence — including scheduled surveillance inspection preparation, QC record maintenance, and licence renewal management — ensuring your ISI Mark certification remains active and in good standing throughout the licence validity period.
Frequently Asked Questions
What is the difference between BIS Scheme I (Domestic) and FMCS (Foreign) for toy certification?
BIS Scheme I is the domestic product certification route for Indian toy manufacturers — applied through the BIS ManakOnline portal with an online application and standard factory inspection at the Indian manufacturing facility. FMCS (Foreign Manufacturers Certification Scheme) is the route for foreign toy manufacturers — applied with a physical paper application to BIS headquarters in New Delhi, with a BIS auditor conducting a factory inspection at the overseas manufacturing facility and product samples tested at a BIS-recognised laboratory in India. The safety standards, testing requirements, and ISI Mark format are identical under both routes — the difference is purely the application mechanism and inspection logistics.
How many BIS licences does a toy company with two factories and both electrical and non-electrical products need?
A minimum of four separate BIS licences would be required: Factory A — Non-Electrical Toys (IS 9873); Factory A — Electrical Toys (IS 15644); Factory B — Non-Electrical Toys (IS 9873); Factory B — Electrical Toys (IS 15644). Each unique combination of manufacturer, factory address, and toy category (electrical vs non-electrical) requires its own independent BIS ISI Mark licence. Each licence has its own CM/L-XXXXXXXXXX number, and each requires its own factory audit and laboratory testing.
Can toys made of recycled or biodegradable materials be BIS certified?
Yes. The BIS ISI Mark certification process under IS 9873 and IS 15644 is materials-agnostic — it focuses on the safety performance of the finished toy product rather than the specific materials used to manufacture it. Toys made from recycled plastics, natural materials, bamboo, organic cotton, or biodegradable materials are subject to the same IS 9873 test programme as conventional toys. The chemical safety tests under IS 9873 (Part 3):2017 and IS 9873 (Part 9):2017 are particularly relevant for toys made from recycled materials, where chemical contamination from recycled content is a potential concern that the testing programme is designed to screen.
What is the R&D import exemption under the Toys QCO 2020 (October 2024 amendment)?
The October 2024 amendment to the Toys QCO 2020 introduced an R&D import exemption: up to 300 toy samples per year (maximum 5 units per toy type) may be imported without a BIS ISI Mark licence, but only for bona fide research and development purposes. These toys cannot be sold, distributed, or used commercially in India — they must be disposed of as scrap after R&D evaluation. Importers using this exemption must maintain clear documentation of the R&D purpose for each imported sample and comply with any procedural requirements specified by Customs and BIS for the exempted R&D import category.
✓ Key Takeaways
- BIS ISI Mark certification is mandatory for all toys for children under 14 years under the Toys (Quality Control) Order, 2020 — in force since 1 September 2020
- Seven Indian Standards apply: IS 9873 Parts 1, 2, 3, 4, 7, and 9 for non-electrical toys; IS 15644:2006 additionally for electrical toys
- IS 9873 (Part 1):2025 is the current standard for mechanical and physical safety — aligned with ISO 8124-1. All new applicants should apply under the 2025 edition. The 2019 edition is only valid for existing licences until 22 March 2027
- The ISI Mark contains two elements: the Indian Standard number (above) and the CM/L-XXXXXXXXXX licence number (below) — both must be correctly displayed on every certified toy
- Certification is manufacturer-specific, factory-specific, and category-specific — each unique combination requires its own BIS licence number
- Foreign manufacturers must apply under the FMCS scheme with a physical application to BIS HQ and must appoint an AIR
- In-house testing facilities compliant with the BIS SIT are a mandatory eligibility requirement — factories without required equipment will fail the BIS audit
- The typical timeline is 30 to 60 working days from complete application submission — assuming clean factory audit and no test failures
- BIS had conducted 159 enforcement operations as of June 2025 — active, systematic enforcement across all supply chain stages including e-commerce
- Non-compliance carries customs refusal, market seizure, monetary penalties, and potential imprisonment — with no exemption by scale, brand origin, or distribution channel
Your Next Step
BIS ISI Mark certification for toys is a mandatory compliance requirement with no substitutes and no grace period — and with 159 enforcement operations and active e-commerce monitoring, the risk of operating without it is both real and immediate. Whether you are a domestic toy manufacturer building your BIS compliance infrastructure for the first time, a foreign toy brand entering India through the FMCS route, or an existing licence holder managing the IS 9873:2025 standard transition, getting the certification journey right requires regulatory expertise, factory preparation, and disciplined documentation management.
Rego Services' regulatory team manages the complete BIS ISI Mark toy certification process — from standard selection, SIT facility preparation, and document compilation through BIS filing, factory audit support, BIS query response, and post-certification surveillance management — ensuring your toys reach Indian consumers compliantly, efficiently, and bearing a genuine ISI Mark that builds lasting buyer trust.
Contact Rego Services today to begin your BIS ISI Mark certification for toys and build a clear, compliant path to India's toy market.