Hard disk drives in India brought under BIS mandatory registration scope

India's compulsory registration scheme (CRS) requires products brought into scope to be registered with the Bureau of Indian Standards (BIS) before they can be placed on the Indian market. Registration is by product and by factory: making the same product at a different facility means a new registration.

Tests are carried out in laboratories in India recognised by BIS. This means a report obtained from a laboratory abroad cannot be used directly and forms the longest item in the timetable.

After registration, the standard mark and the registration number must be shown on the product and its packaging. Marking is a heading checked as often as registration itself.

When a product group is brought into scope, an implementation date is given in the announcement; after that date, importing and selling an unregistered product is not possible. The date has no retrospective effect but a separate arrangement is usually made for stocks.

For component-like products such as hard disk drives, an additional question arises: is it placed on the market as a component or as a finished product. A drive supplied inside a computer and a drive sold separately may not be under the same obligation; the decision must be made against the text of the announcement.

The laboratory queue and the BIS application period must be calculated together. Because the volume of applications rises close to the implementation date, the periods lengthen.

Factory details, the product family definition and the model list form the basis of the application. Submitting an incomplete model list means a separate transaction for every model added later; the list should be kept broad from the outset.

Items such as storage drives can be both a product sold on its own and a component inside another product. The scope decision runs through that distinction: a product placed on the market on its own obtains its own registration; the position of a component fitted inside another product is assessed against the scope of that product.

That distinction has direct consequences in the supply chain: a computer manufacturer cannot assume that using a registered drive satisfies the registration of its own product; the finished product is assessed separately against its own scope.

The reverse also holds: registration of the finished product does not legitimise selling that drive separately as a spare part.

A transition period is typically defined for categories brought into scope and at its end the import of unregistered products stops. The work items within that period are, in order: confirming the scope, determining the national standard, preparing samples, the laboratory queue and the registration application.

The items that determine the timetable are the laboratory queue and shipping the sample; technical conformity is usually already there and what is waiting is the process.

For products with model variety, which models require separate registration is settled at the outset: a difference in capacity or interface counts as a separate model in some cases and the number of registrations exceeds expectations.

The visible output of registration is the standard mark and registration number on the product. The format, position and legibility of the number are governed; it is also required to appear on the packaging.

Market surveillance runs through that number: an inspection queries the product in the system and compares the information on the product against the scope of the registration. Model information that does not match the scope is treated as a non-conformity even where the product is registered.

Writing the model name identically in the registration record and on the product is therefore the smallest detail at the end of the process but the one that causes the most problems.