BIS License Modification Process: Do Changes in Components, Suppliers or Design Require Retesting?

Does a Change in Components, Supplier or Design Affect BIS Testing?

A product may have already completed testing and received BIS certification, but that does not mean every future modification can automatically be covered by the same approval. Manufacturers regularly change component suppliers, source alternative raw materials, improve product designs, or introduce revised models to manage production costs and availability. These decisions may seem routine from a manufacturing perspective, but they can affect the product configuration originally evaluated for conformity.

The important question is not simply whether a component has changed. It is whether the modification affects the product's compliance with the applicable Indian Standard, its approved configuration, or the scope and conditions of its existing certification.

BIS certification component change requirements depend on the product, certification scheme, applicable standard, and technical significance of the modification. A supplier change involving an identical, suitably certified component may be treated differently from replacing a safety-critical component with a different specification. Similarly, a minor manufacturing adjustment may have different implications from a design change affecting electrical safety, mechanical strength, or product performance.

For manufacturers, the safest approach is to assess a proposed change before introducing it into commercial production. This article explains how to evaluate component substitutions, supplier changes, design modifications, raw-material changes, and new product models, and when additional testing or a licence-scope update may need to be considered.

1. BIS License Modification Process: When Must Manufacturers Update Their Existing Certification?

A common misunderstanding among manufacturers is that once a BIS licence has been granted, all products manufactured under the same brand or within the same factory are automatically covered. This is not how product certification works. The licence identifies the product and its approved scope, including the varieties, grades, sizes, or other characteristics covered under the applicable Indian Standard.

The Bureau of Indian Standards explains that a licence cannot be used for product varieties outside its approved scope. Manufacturers seeking to add or remove varieties must follow the applicable change-in-scope procedure.

When should a manufacturer consider a BIS licence modification?

A scope review may be necessary when a manufacturer intends to:

• Introduce an additional product variety, grade, size, or rating.

• Add a new configuration that is not covered by the existing licence.

• Modify the product in a way that affects its approved scope.

• Introduce additional raw materials or components that require assessment under the relevant product manual.

• Make changes to manufacturing machinery, testing facilities, or other declared arrangements where the applicable procedure requires updated information.

It is important to distinguish between a change to an existing component and the addition of a new product variety. They are not necessarily handled through the same procedure.

For example, a manufacturer holding a licence for a particular electrical product may wish to introduce another rated variant. Whether this can be included under the existing licence depends on the Indian Standard, product grouping guidelines, and the conditions specified in the relevant product manual. It should not be assumed that the original test report automatically covers the additional variant.

How does the BIS licence modification process work?

Under Scheme I, BIS provides a formal procedure for applying for a change in the scope of an existing licence. Applications are submitted through the applicable online portal, and the supporting documents and testing requirements depend on the nature of the proposed addition or modification.

BIS guidance identifies documents that may be relevant, including declarations concerning manufacturing machinery and testing equipment, reports or certificates for additional raw materials and components, and third-party laboratory test reports where required by the applicable option and procedure. The submitted information is evaluated before a scope change is permitted.

Manufacturers should therefore review the applicable product manual before starting production of a modified or additional variety. A licence amendment, supporting technical evidence, and product testing are separate considerations; the exact requirements are case-specific and subject to BIS assessment.

2. BIS Critical Component Change Guidelines: How to Assess Whether a Replacement Affects Product Compliance

Not every component has the same importance in determining product conformity. Some parts have a direct influence on safety, performance, durability, or the product's ability to meet specific requirements of an Indian Standard. These are often the components that deserve the closest review before substitution.

For instance, in an electrical product, a change involving insulation, protective devices, wiring, or a safety-related circuit may affect the product's electrical safety characteristics. In another product category, a change in material composition, mechanical construction, or pressure-bearing parts may be more significant.

The BIS testing requirements for modified products should therefore be assessed against the actual function of the changed component.

Which component changes should manufacturers review carefully?

These are assessment considerations, not a universal BIS list of components requiring retesting. The relevant Indian Standard and product manual determine which characteristics must be evaluated.

Does replacing a component always require retesting?

No. The technical effect of the replacement matters.

The official BIS CRS FAQ addresses the question of alternate sources for approved specifications. It states that valid, pre-certified safety-critical components with the same ratings may be sourced from different suppliers under intimation to BIS along with a copy of the certificate. However, it also states that changes to the circuit, design, or components require product retesting under the CRS guidance.

This distinction is particularly important. A manufacturer should not interpret permission to use an alternate source for an identical approved component as permission to introduce a component with different technical characteristics.

Before making a substitution, compare the original and replacement component specifications. Check the ratings, applicable certifications, model identification, technical documents, and intended function. If the replacement changes the product's safety or performance characteristics, additional evaluation or testing may be necessary.

For this reason, BIS retesting requirements after component changes should be determined through the relevant certification scheme rather than through a blanket rule applied to every product.

3. Does Changing a Supplier Affect BIS Certification? Evidence Required for Alternate Component Sources

Supplier changes are common in manufacturing. A component may become unavailable, a manufacturer may identify a new vendor, or an alternative source may offer a different supply arrangement. However, changing a supplier and changing a component are two different situations.

If the replacement supplier provides the same component with matching specifications, ratings, and applicable certifications, the change may have a different compliance impact from introducing a technically different component.

This distinction is particularly relevant to BIS certification change in supplier decisions.

What should manufacturers verify before changing suppliers?

Start by comparing the existing and proposed components using technical evidence rather than relying only on a supplier's statement that both products are equivalent.

The review should include:

• Component model and identification details.

• Electrical, mechanical, or material specifications, as applicable.

• Ratings and operating conditions.

• Relevant certificates and test reports.

• Manufacturer and supplier traceability.

• Whether the component is identified as critical in the applicable product documentation.

• Whether the relevant BIS scheme requires intimation, documentation, approval, or further testing.

For CRS products, the official FAQ provides specific guidance for valid, pre-certified safety-critical components of the same ratings from different sources. The manufacturer should follow the stated intimation requirement and submit the relevant certificate copy. This should not be generalised to other BIS schemes without checking their individual requirements.

What if the new supplier provides a different component?

This is where a more detailed technical assessment becomes necessary. Two components may perform a similar function but still have different ratings, construction, materials, or operating characteristics.

For example, imagine a manufacturer replacing a protective electrical component with another model that has a different temperature rating. Even if the replacement fits the same position on the circuit board, its behaviour under operating or abnormal conditions may differ. The manufacturer should establish whether the change affects conformity before using it in the certified product.

Supplier declarations alone may not be sufficient evidence. Depending on the product and certification route, the manufacturer may need component certificates, updated technical documentation, additional test reports, or confirmation from the relevant authority.

Maintaining a supplier-change register is a useful practical measure. Record the original supplier, replacement supplier, component identification, technical comparison, supporting certificates, and the compliance decision. This creates traceability if questions arise during a factory inspection or certification review.

4. BIS Certification Change in Raw Materials: When Are Additional Test Reports or Supporting Documents Needed?

A change in raw material can affect product conformity even when the finished product looks unchanged. Material composition, grade, thickness, strength, insulation characteristics, and other properties may influence whether a product meets the applicable Indian Standard.

For this reason, BIS certification change in raw materials should be evaluated according to the material's function and the requirements of the product standard.

Consider a manufacturer who changes the material grade used in an electrical enclosure. The new material may have similar appearance and dimensions, but its heat resistance, mechanical characteristics, or other relevant properties may differ. If those characteristics are covered by the applicable standard, the manufacturer should not assume that the original test evidence remains sufficient.

Which material changes need technical assessment?

Some common examples include:

• Changing the grade or composition of a metal.

• Replacing a specified polymer or insulation material.

• Changing the thickness or construction of a material.

• Introducing a new coating, adhesive, or protective treatment.

• Using a different raw-material source with different technical specifications.

• Changing a material that contributes to fire, thermal, mechanical, or electrical performance.

The exact significance of each change depends on the product category. A material modification that is critical for one product may have a different impact on another.

What documents should manufacturers maintain?

Depending on the applicable product manual and certification procedure, relevant evidence may include:

1. Updated raw-material specifications.

2. Material grade and composition details.

3. Manufacturer or supplier declarations.

4. Certificates or test reports for the new material.

5. Incoming material inspection records.

6. Updated product drawings or bills of materials.

7. Additional product test reports, where required.

BIS product-specific manuals can identify raw-material requirements, sample quantities, testing arrangements, and information relevant to grant of licence, change in scope, or factory surveillance. One example is the BIS product manual for IS 9360:2024, which includes product-specific information concerning raw-material compliance and change-in-scope assessment. Its requirements should not be assumed to apply to unrelated products.

Manufacturers should also review whether the proposed material change affects the declared product configuration or existing licence scope. Where additional evidence is required, it should be prepared before the changed material is introduced into regular production.

The objective is not to generate unnecessary testing paperwork. It is to establish, with appropriate technical evidence, that the modified material continues to support conformity with the applicable standard.

5. BIS Testing Rules for New Product Models: When Is Retesting or a Scope Extension Required?

Manufacturers often introduce new models to respond to customer requirements, improve product performance, or expand their product range. A new model may have a different rating, size, design, construction, or component arrangement. The key question is whether the existing BIS certification covers the proposed configuration.

BIS product testing requirements after design changes depend on the applicable Indian Standard, model grouping provisions, and the approved licence or registration scope.

A model number change alone does not establish that a product requires complete retesting. Similarly, using a familiar product name does not establish that a modified model is covered by an existing certificate.

How should manufacturers evaluate a new model?

Before introducing a new model, compare it with the model already covered by the certification.

Consider the following:

• Does the new model have the same essential construction?

• Are the electrical or mechanical ratings different?

• Have any safety-critical components changed?

• Are the raw materials and relevant specifications unchanged?

• Does the applicable product standard permit the proposed grouping?

• Is the new model already included in the licence or registration scope?

• Does the product manual require separate sampling or testing?

BIS publishes product-specific technical manuals and grouping guidelines to help manufacturers understand which varieties may be covered together and what evidence is required. These should be consulted rather than assuming that similar models can automatically share one test report.

What is the difference between retesting and a scope extension?

These are related but separate compliance actions.

• Retesting: Additional product testing may be necessary when a change affects characteristics that must be verified against the relevant Indian Standard.

• Scope extension: A formal application may be required when a manufacturer wants to add varieties or configurations that are not already included in the existing licence scope.

• Technical documentation update: Revised drawings, component details, material specifications, or other supporting documents may be required depending on the change and certification route.

A scope extension does not automatically mean that every test must be repeated. Likewise, a passing test report does not automatically authorise a manufacturer to use the Standard Mark on a product outside the approved scope.

For Scheme I, BIS provides separate guidelines for change in scope of licence and retesting of samples. The manufacturer should identify which procedure applies and follow the relevant product-specific instructions.

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A practical pre-production checklist

Before releasing a modified model, manufacturers should:

1. Record the original and proposed product configurations.

2. Identify all changed components, suppliers, materials, and design features.

3. Compare the changes against the applicable Indian Standard.

4. Review the current BIS product manual and grouping guidelines.

5. Identify any required test reports, declarations, or certificates.

6. Confirm whether intimation, approval, retesting, or a licence-scope amendment is applicable.

7. Retain the supporting technical and compliance records.

This approach helps manufacturers make informed decisions before a change affects production, certification records, or market supply.

4. What Is the BIS License Modification Process for a Changed Product or Manufacturing Configuration?

Not every modification requires a new certification. In some situations, the manufacturer may need to apply for a change in the scope of an existing licence. In others, additional technical evidence, testing, or documentation may be sufficient under the applicable procedure.

Under Scheme I of the BIS Conformity Assessment Regulations, the scope of a licence covers the product types, sizes, grades, and varieties for which the manufacturer has been permitted to use the Standard Mark.

BIS publishes a separate procedure for changes in the scope of a licence. The application is made through the online portal, with the relevant fee and supporting documents. BIS also directs manufacturers to consult the product-specific technical manual and grouping guidelines.

When might a scope change application be necessary?

A manufacturer should review the scope-change procedure when planning to:

• Add a new product variety, grade, size, or rating.

• Introduce an additional model not covered by the existing scope.

• Include a configuration that requires separate assessment under product grouping guidelines.

• Add raw materials or components for which the applicable procedure requires additional evidence.

• Make relevant changes to manufacturing infrastructure or testing arrangements.

The exact requirement depends on the product manual and the nature of the modification.

Does every scope change require a new laboratory test report?

No. This is an important distinction that can help manufacturers avoid unnecessary testing assumptions.

The BIS Scheme I change-in-scope guidelines provide for certain cases where third-party laboratory test reports are not required. Specifically, where there is no change in infrastructure, including manufacturing machinery and test equipment, and the proposed scope change falls within the same group of sampling guidelines, third-party laboratory reports are not required under that specified provision. In-house test reports are still required as described in the guidelines, subject to their stated conditions.

For other situations, the applicable options under the grant-of-licence guidelines may require declarations, additional raw-material or component reports, and third-party laboratory testing. Product-specific requirements must also be followed.

The manufacturer's application and supporting evidence are evaluated before the change in scope is endorsed. If information is incomplete, BIS may communicate deficiencies for clarification.

Manufacturers should also distinguish between changing the product scope and updating declared manufacturing information. Where machinery, test equipment, or manufacturing arrangements are affected, the relevant declarations and requirements should be reviewed rather than assuming the licence record updates automatically.

One more distinction deserves attention: BIS's separate retesting guidelines dated 14 July 2025 concern the coding and retesting of samples drawn by certification officers or their agents, including counter-samples. They should not be interpreted as a general permission for manufacturers to replace a modified product and obtain an unrestricted repeat test.

5. How Does BIS CRS Registration Modification Work for New Models and Critical Component Changes?

The Compulsory Registration Scheme follows a registration framework that should be distinguished from the product certification licence process under Scheme I. Manufacturers should identify whether their product is covered under CRS before deciding which modification procedure applies.

For CRS products, the BIS CRS registration modification process may involve changes to model details, the Critical Component List (CCL), or other registration information. The required action depends on the nature of the change and the instructions applicable to the product.

The official CRS portal provides separate facilities for model withdrawal, standard revision, testing and sample submission, and Critical Component List updates.

How is the Critical Component List updated?

The CRS portal's published instructions describe the following CCL update procedure:

1. Sign in to the CRS portal using the existing credentials.

2. Select the CCL Update facility.

3. Upload the relevant test report after verification.

4. Submit the undertaking regarding the declaration of conformity.

5. The updated Critical Component List is placed on record.

6. An acknowledgement is sent by email.

This is the published portal process; the technical test and documentation requirements depend on the relevant product and applicable BIS instructions.

For example, a BIS Registration Department circular dated 11 June 2024 introduced online CCL updation for Solar PV Modules. It addressed changes in the Bill of Materials for registered modules without a change in model number and specified submission of test reports through the online feature. This is a product-specific example, not a universal procedure for every CRS product.

What should manufacturers check before introducing a new model?

The BIS testing rules for new product models depend on model grouping, design similarity, ratings, materials, and the relevant Indian Standard.

Before introducing a new model, manufacturers should check:

• Whether the model is already covered by the existing registration or licence.

• Whether its design and technical characteristics fall within the applicable grouping provisions.

• Whether the critical component configuration has changed.

• Whether a new test report or CCL update is required.

• Whether model inclusion, withdrawal, or another portal request is applicable.

For Scheme I products, BIS product manuals contain sampling information, testing equipment requirements, the Scheme of Inspection and Testing, scope details, and grouping guidelines. These manuals should be checked before finalising the modification plan.

A manufacturer should not rely solely on a similar model name or appearance to establish that a new variant is covered. The approved scope and technical requirements matter.

A practical recommendation: Maintain one controlled record for each proposed modification, showing the original product configuration, revised specifications, affected components, supporting certificates, test evidence, and the compliance action taken. This makes internal reviews more reliable and helps the manufacturer respond to questions during certification assessment or surveillance.

SAMCC assists businesses with certification planning, documentation alignment, testing coordination, and regulatory approval processes. Manufacturers who are unsure about the effect of a proposed component, supplier, or design change can discuss their product configuration and applicable certification route with Samridhi Compliance Certification before implementing the change.