India BIS migration FAQs for IS/IEC 62368-1:2023
India has issued new guidance on the transition to IS/IEC 62368-1:2023. The new BIS migration FAQs help manufacturers manage product certification under the Compulsory Registration Scheme (CRS). The document does not create new obligations. Instead, it explains the licensing, testing, labeling, and migration steps that apply during the transition period.
India is replacing IS 13252 (Part 1):2010 and IS 616:2017 with IS/IEC 62368-1:2023 under a Hazard-Based Safety Engineering (HBSE) framework. XR products must migrate by 1 May 2026. ICT, consumer electronics, and AV equipment must migrate by 1 November 2028. After those dates, BIS will withdraw the legacy standards. The FAQ confirms that these deadlines remain unchanged.
What the BIS migration FAQs clarify
The FAQ issued on 22 July 2026 confirms that existing R-numbers stay the same after successful migration to IS/IEC 62368-1:2023. Manufacturers may also keep separate licences for different product categories. They must migrate each licence separately under the implementation guidelines.
BIS also confirms that compliant products must continue to carry the BIS Standard Mark and must reference IS/IEC 62368-1:2023 on the label. In addition, BIS-recognized laboratories can perform testing under the new standard through the BIS LIMS portal.
Licensing and transition period
Manufacturers may renew licences under IS 13252 (Part 1):2010 or IS 616:2017 until 1 November 2028. This date marks the end of concurrent use with IS/IEC 62368-1:2023. However, BIS encourages applicants to submit new applications under the new standard as early as possible.
Manufacturers may add new models tested to IS/IEC 62368-1:2023 to an existing legacy licence during the transition period, provided they meet the applicable requirements.
If a manufacturer does not complete migration by the deadline, BIS may cancel the licence or remove models from its scope.
Testing, components, and factory-specific requirements
The guidance includes several important testing clarifications:
- Manufacturers must submit complete test reports for all applicable lead models.
- If a lead model reaches end-of-life, the manufacturer may choose another suitable model from the same series.
- Each manufacturing location requires a separate test report because CRS licences apply per factory.
- Manufacturers may test critical components and end products in parallel under BIS parallel testing rules.
- BIS does not charge a migration fee for already registered models submitted through the Standard Revision process.
Critical Component List obligations
BIS places special attention on the Critical Component List (CCL). Critical components that act as safeguards must comply with IS/IEC 62368-1:2023. Components certified only to the old standards will no longer qualify for the CCL after migration. Manufacturers may still register components and end products in parallel under the applicable BIS guidelines.
Early testing encouraged
BIS allows manufacturers to begin testing products to IS/IEC 62368-1:2023 before they submit a migration application. Existing licensees must submit complete test reports for all applicable lead models through the Standard Revision or related provision in the BIS CRS portal.
Why this guidance matters
The BIS migration FAQs do not change India’s regulatory timeline. However, they help manufacturers plan migration projects, especially when they manage multiple factories, legacy product lines, or end-of-life lead models. BIS also encourages manufacturers to move new product development, testing, and certification activities to IS/IEC 62368-1:2023 well before the November 2028 deadline.
Keeping track of Regulatory Updates, News, and certification changes in India helps companies maintain market access under the BIS CRS framework.
How can Entirety help?
For organizations preparing migration strategies, certification planning, and conformity assessment activities related to IS/IEC 62368-1:2023, explore Entirety’s Product Certification Service: https://entirety.biz/services/product-certification-service/
Impact Assessment
Technical Standards? ✅ Yes
Type Approval & Market Access? ✅ Yes
Imports, Customs, Trade, or Market Surveillance? ❌ No
Spectrum Management? ❌ No
