What Happens When a BIS Test Report and Product Sample Do Not Match?

3. BIS Test Report Model Number Mismatch: Is It a Testing Failure?

No. A BIS test report model number mismatch does not automatically establish that the product has failed the relevant standard. It means that the manufacturer must clarify whether the report identifies the correct sample and whether the tested configuration represents the product under assessment.

There are two different issues to understand.

Identification discrepancy: The product may have been tested correctly, but a model number, brand name or address may have been recorded incorrectly in the report or accompanying documents.

Technical non-conformity: The sample has been tested and found not to meet one or more requirements of the applicable Indian Standard.

A mismatch can exist without a failed test. Equally, a report may contain perfectly consistent identification details but record a technical failure.

When might a model difference be significant?

Consider two models of a power adapter. They share the same external casing, but one has a different rated output or internal design. A report for the first model cannot automatically be assumed to cover the second.

The manufacturer must check the technical differences, the applicable product grouping or series guidelines, and the scope of the testing performed. A laboratory's report should clearly support the models being claimed.

A similar issue can arise where one brand appears in the report while another is mentioned in the application. The official CRS deficiency document identifies brand differences between the brand-registration certificate and the product label reflected in the test report as an application deficiency.

Can one report cover multiple brands or models?

This depends on the applicable scheme and product-specific rules. Certain CRS arrangements may permit a representative model and common test report to support multiple brands or models when the relevant conditions are met. However, the brands and model numbers must be properly declared and supported by the laboratory's report and applicable guidelines.

Manufacturers should not assume that a report for one model automatically covers every variant. For electronics and other regulated products, the relevant BIS CRS Registration requirements should be checked before relying on a common report.

For products covered under the ISI Mark scheme, the relevant route may instead be BIS ISI Certification for Domestic Manufacturers, BIS ISI Certification for Foreign Manufacturers or BIS Scheme X Certification, depending on the product and applicable conformity assessment requirements.

4. BIS Test Report Correction Procedure: How Should Manufacturers Resolve a Mismatch?

When a discrepancy is found, the manufacturer should first identify its cause. Immediately arranging another test may create unnecessary expense if the actual issue is a clerical error. On the other hand, asking for a correction when the wrong product was tested will not establish conformity for the intended model.

There is no single correction route that can be assumed to apply to every BIS report. The appropriate action depends on the issuing laboratory, the nature of the discrepancy and the relevant certification scheme.

Step 1: Compare the original documents

Review the report alongside the sample submission form, laboratory acknowledgement, sample label, photographs, application details and product specifications. Record each difference rather than making informal assumptions about it.

Step 2: Contact the issuing laboratory

For a possible clerical error, write to the laboratory that issued the report. Provide the original sample details and supporting records, and request a written review.

The laboratory must determine whether its records support a formal correction or clarification. Manufacturers should never edit a test report themselves or change an identification detail to make the document appear applicable to another product.

Step 3: Check the applicable BIS procedure

The next step is to identify the relevant certification route. BIS publishes separate Scheme I guidance for grant of licence, change in scope, retesting, factory surveillance, market surveillance and product non-conformity. These are separate procedures, not interchangeable solutions to every discrepancy.

Manufacturers can review the BIS Certification Process, BIS Certification Requirements and BIS Certification Documents Required to understand the supporting information relevant to their application.

Step 4: Decide whether fresh testing is necessary

Further testing may be required if the original sample cannot be reliably linked to the product under assessment, the technical configuration is different, or the applicable BIS procedure calls for additional testing.

The decision should be based on the product-specific requirements and the nature of the discrepancy. A corrected report cannot replace testing of a materially different product that was not covered by the original test.

Manufacturers can also review the BIS Certification Testing service and relevant NABL Testing support when evaluating their testing requirements.

Step 5: Maintain a complete record

Keep the original report, written laboratory clarification, any revised report, sample records and correspondence together. Make sure that the version submitted for certification is consistent with the application and product details.

This record becomes especially useful when a clarification is raised during application scrutiny or a later compliance review.

5. BIS Testing Non-Conformity Procedure: What If the Sample Actually Fails?

A report/sample mismatch and product non-conformity are different matters. If the sample genuinely fails a requirement of the applicable standard, the manufacturer must follow the relevant BIS non-conformity procedure rather than treat the matter as a report-correction exercise.

For Scheme I, manufacturers should refer to the BIS guidelines dated 13 December 2024 for dealing with product non-conformity and unsatisfactory performance during operation of a licence. These guidelines superseded the earlier guidelines dated 13 May 2024.

What happens after a non-conforming sample is reported?

BIS examines test reports from factory testing and third-party laboratory testing as part of its surveillance and licence-operation processes. The guidelines provide for recording the requirements and clause numbers in which a sample is found non-conforming. They also provide for reviewing the licensee's performance and assessing the risk associated with the observed non-conformity.

Depending on the case, the manufacturer may be asked to:

• Investigate the reason for the non-conformity.

• Submit corrective actions and supporting evidence, including root-cause analysis.

• Provide an in-house or qualifying outside-laboratory test report to demonstrate the effectiveness of corrective actions.

• Make improved material available for verification.

• Retest available stock where required under the communication and applicable guidelines.

• Respond to product-recall instructions, where issued.

The December 2024 guidelines describe corrective-action submissions, supporting test evidence and subsequent verification. They also provide for product-recall decisions based on the circumstances and risk assessment; recall should not be presented as an automatic outcome of every failed test.

When is BIS retesting required?

BIS retesting requirements for non-conforming samples depend on the applicable procedure and the circumstances of the case. BIS maintains a separate set of guidelines for retesting samples under Scheme I, in addition to its non-conformity guidelines.

A manufacturer should follow the instructions issued by BIS instead of assuming that submitting a new sample or arranging an independent test will automatically close the matter.

Choosing the correct compliance pathway

A product may also require regulatory approvals beyond BIS, depending on its nature and intended use. For example, wireless or telecom products may have separate requirements under WPC ETA Approval or TEC MTCTE Approval. Certain appliances may also fall within the scope of BEE Star Rating Approval. These approvals address different regulatory requirements and should not be confused with the acceptance of a BIS test report.

For manufacturers dealing with report discrepancies, sample identity questions or testing documentation, Samridhi Compliance Certification (SAMCC) can assist with reviewing the available records and understanding the relevant certification pathway. The final decision on report acceptance, testing and certification remains with the applicable laboratory and regulatory authority.

Before submitting a test report, verify that the sample, technical details, manufacturer information and application all describe the same product and manufacturing arrangement. A careful review at this stage can help prevent avoidable clarification and testing difficulties.

For product-specific guidance, visit SAMCC or contact the team to discuss the discrepancy and the applicable compliance requirements.