I’ve spent the last decade navigating the labyrinth of industrial compliance in India. I remember the days when getting an ISI mark was often just a matter of sending a “golden sample” to a lab, crossing your fingers, and waiting for a test report. If the sample passed, you were set for a year.
Those days are gone.
With the introduction of Scheme X under the BIS (Conformity Assessment) Regulations, 2018, the Bureau of Indian Standards has fundamentally rewritten the playbook for capital goods and heavy machinery. If you are still treating this like the old Scheme I (Standard Mark) or Scheme II (CRS), you are walking into a compliance minefield.
Here is what I’ve learned from the front lines of this transition, and what you need to know to keep your machinery moving.
It’s No Longer Just About the Product; It’s About the Process
For years, the Indian regulatory mindset was “product-centric.” Does this switchgear break at the right current? Does this motor spin at the right RPM?
Scheme X shifts the focus to Safety Management. It’s the enforcement arm of the new Omnibus Technical Regulation (OTR), and it mirrors global frameworks like the EU’s Machinery Directive. The regulator isn’t just asking if your machine works; they are asking how you ensured it is safe to operate.
This means you can’t just rely on a final test report. You need to prove you have built safety into the design phase itself, primarily through compliance with Type A Standards like IS 16819 / ISO 12100.
Technical File is Your New Boss
If there is one piece of advice I can give you from my experience, it is this: Do not underestimate the Technical File.
In the past, documentation was often an afterthought. Under Scheme X, the Technical File is the core of your application. If it’s incomplete, your application gets rejected before a BIS officer even steps foot in your factory.
Your Technical File needs to be a “living document” that includes:
- Risk Assessments: A formal document mapping hazards to mitigation strategies.
- Design Drawings: General arrangement, electrical schematics, and hydraulic circuit diagrams.
- Critical Components List (CCL): Proof that your sub-assemblies (motors, contactors) are also certified.
I’ve seen applications stall for months simply because the manufacturer couldn’t trace the certification status of a sub-component.
One Size Does Not Fit All (Finally!)
One of the biggest headaches for heavy industry used to be the “continuous production” assumption. How do you maintain a “continuous” license for a custom-built hydraulic press that takes six months to manufacture?
Scheme X finally addresses this by offering two pathways:
- Grant of Licence (GoL): For those churning out serial products like motors or switchgear. This is valid for 3 to 6 years.
- Certificate of Conformity (CoC): This is a game-changer for batch production or custom machinery. It’s a one-time certification for a specific lot or prototype.
Strategically, this allows manufacturers of bespoke equipment to bid for Indian projects without committing to a perpetual license they don’t need.
Foreign Manufacturer Challenge (FMCS)
For my international peers looking at the Indian market, the barrier to entry has just gotten higher. Scheme X applies equally to foreign OEMs, but the logistics are tougher.
You cannot just ship and forget. You must appoint an Authorized Indian Representative (AIR) who is legally liable for your compliance. Furthermore, you are now required to submit a Performance Bank Guarantee (PBG) of USD 10,000 to ensure you play by the rules.
Plan for a timeline of 5–6 months for certification due to the complexities of international site audits.
The Bottom Line
Scheme X is not just a regulatory hurdle; it’s a maturity test for the Indian industrial sector. It filters out the “fly-by-night” operators who can’t support their products with engineering data.
If you are an OEM, start your Risk Assessments now. Audit your supply chain for compliant components. The shift from “testing” to “assurance” is here, and in my experience, the early movers are the ones who will dominate the market.
