India launched an ambitious standardisation drive, bringing products from toys and chemicals to steel, aluminium, and electronics under mandatory QCOs. As of March 2025, BIS notified 187 QCOs covering 769 products to ensure domestic and imported goods meet minimum safety, quality, and performance standards. As with any major regulatory effort, pace and sequencing are crucial. Though essential for a maturing economy, their rapid expansion has caused sectoral frictions, highlighting the need for a calibrated, predictable, and capacity-aligned approach.
As India advances Make in India, quality is no longer optional. In critical sectors such as electrical equipment, building materials, and industrial inputs, mandatory standards reduce accidents, curb substandard imports, and strengthen trust in domestic manufacturing. Globally as countries industrialise, they move from minimal standards to mandatory regimes as industrialisation deepens, and later to effectively enforced voluntary systems. Even technically voluntary standards in developed countries (EU, US, Japan) become de facto mandatory when strictly enforced through construction codes, machinery regulations, or safety laws, ensuring compliance through legal mechanisms. In Japan, many standards are formally voluntary, but in practice they are treated mandatory due to a strongly embedded “compliance culture”.
Globally, the intent behind mandatory standards has always been sound, however implementation experience in India has revealed several challenges. Rapid QCO expansion has outpaced testing capacity, causing BIS inspection delays, import bottlenecks, and confusion from ambiguous HS codes at ports. Shipments are occasionally held up due to uncertainty over whether a product is covered by a QCO. These issues do not signal industry resistance to quality but reflect strain on an overstretched system. While larger firms adapt, MSMEs reliant on imports face disruptions. Recent QCO rollbacks highlight challenges, but abrupt changes risk regulatory uncertainty. The focus should stay on maintaining quality through a measured, capacity-aligned approach.
As India develops a mature quality ecosystem, mandatory quality tools can be redesigned as part of a phased, integrated system rather than isolated compliance.
- Prioritising sectors for QCOs – concept to criteria: If a QCO’s goal is to 'bring quality to India,' a clear methodology is needed to prioritise which sectors/products require mandatory certification, moving beyond a simple final goods vs. intermediates distinction considering: (a) consumer safety and public health risks; (b) environmental and systemic supply‑chain criticality (including to infrastructure and strategic sectors); (c) national security relevance and import dependence; and (d) technological and capital intensity of the industry compared with the existing quality culture in that sector. Such a framework would also make it easier for industry to anticipate future coverage and invest ahead of time in compliance capabilities.
- Timing a QCO – balancing demand, supply & capacity: A second‑generation approach to QCOs should be aware of industries’ market realities. This requires an assessment of (a) domestic and export demand trajectories; (b) current and near‑term testing and certification capacity (public and private) (c) realistic likelihood that a QCO will catalyse fresh domestic manufacturing, not just re‑route existing supply chains. This helps identify QCOs that are unlikely to drive investment, allowing alternative policy tools and avoiding excessive compliance burdens.
- Consultation, review & impact assessment: Industry consultation before implementing QCOs is essential to align standards with practical realities. Challenges often arise when standards impose construction, material, or packaging requirements unrelated to product quality, or when clauses are ambiguous. A structured review should align product variants with standards, identify gaps, assess testing capacity, and flag infeasible testing requirements, ensuring QCO timelines reflect real-world capabilities. Clear processes for clarifications, timely no-objection certificates, along with geopolitical supply analysis assessing concentration risk, can further reduce sudden disruptions in critical value chains. To strengthen domestic manufacturing, QCOs should target industries where quality improvements drive economic gains, drive incremental investments and import substitution, and undergo regular reviews for adjustment.
- International harmonisation, mutual recognition, and differentiated commitments: A forward‑looking QCO regime should align with India’s trade/FTA architecture applying equally to domestic and foreign products. QCO 2.0 should address current bottlenecks, including inspection constraints and certification challenges for high-quality products that use materials or specifications differing from Indian standards. Mutual recognition and equivalence frameworks offer a middle path between quality considerations and compliance burdens. Products or manufacturers with credible foreign certifications could, under defined safeguards, be treated as equivalent to BIS licensing, following global practices in telecom and electrical sectors. Examples include the APEC Electrical and Electronic Equipment Mutual Recognition Arrangement, which allows acceptance of test reports and certifications from designated foreign bodies with top‑up testing for local deviations, and the US–EU/US–EFTA mutual recognition arrangements. For higher‑risk products, mutual recognition can be supplemented with targeted Indian testing without requiring factory audits.
As India develops a mature quality ecosystem, mandatory quality tools can be redesigned as part of a phased, integrated system rather than isolated compliance.
- Prioritising sectors for QCOs – concept to criteria: If a QCO’s goal is to 'bring quality to India,' a clear methodology is needed to prioritise which sectors/products require mandatory certification, moving beyond a simple final goods vs. intermediates distinction considering: (a) consumer safety and public health risks; (b) environmental and systemic supply‑chain criticality (including to infrastructure and strategic sectors); (c) national security relevance and import dependence; and (d) technological and capital intensity of the industry compared with the existing quality culture in that sector. Such a framework would also make it easier for industry to anticipate future coverage and invest ahead of time in compliance capabilities.
- Timing a QCO – balancing demand, supply & capacity: A second‑generation approach to QCOs should be aware of industries’ market realities. This requires an assessment of (a) domestic and export demand trajectories; (b) current and near‑term testing and certification capacity (public and private) (c) realistic likelihood that a QCO will catalyse fresh domestic manufacturing, not just re‑route existing supply chains. This helps identify QCOs that are unlikely to drive investment, allowing alternative policy tools and avoiding excessive compliance burdens.
- Consultation, review & impact assessment: Industry consultation before implementing QCOs is essential to align standards with practical realities. Challenges often arise when standards impose construction, material, or packaging requirements unrelated to product quality, or when clauses are ambiguous. A structured review should align product variants with standards, identify gaps, assess testing capacity, and flag infeasible testing requirements, ensuring QCO timelines reflect real-world capabilities. Clear processes for clarifications, timely no-objection certificates, along with geopolitical supply analysis assessing concentration risk, can further reduce sudden disruptions in critical value chains. To strengthen domestic manufacturing, QCOs should target industries where quality improvements drive economic gains, drive incremental investments and import substitution, and undergo regular reviews for adjustment.
- International harmonisation, mutual recognition, and differentiated commitments: A forward‑looking QCO regime should align with India’s trade/FTA architecture applying equally to domestic and foreign products. QCO 2.0 should address current bottlenecks, including inspection constraints and certification challenges for high-quality products that use materials or specifications differing from Indian standards. Mutual recognition and equivalence frameworks offer a middle path between quality considerations and compliance burdens. Products or manufacturers with credible foreign certifications could, under defined safeguards, be treated as equivalent to BIS licensing, following global practices in telecom and electrical sectors. Examples include the APEC Electrical and Electronic Equipment Mutual Recognition Arrangement, which allows acceptance of test reports and certifications from designated foreign bodies with top‑up testing for local deviations, and the US–EU/US–EFTA mutual recognition arrangements. For higher‑risk products, mutual recognition can be supplemented with targeted Indian testing without requiring factory audits.
India’s push for stronger product standards is timely and necessary, but implementation must be careful and consistent. The issue isn’t whether India needs strong mandatory standards or not. It clearly does. QCO2.0 should be designed to support industry, protect consumers, and ensure policy certainty, strengthening--not constraining manufacturing competitiveness.
This article is authored by Sanjay Notani, senior partner, Economic Laws Practice and Prachi Priya, economist, Mumbai.