In pursuit of stronger quality control and traceability within India’s steel sector, regulatory authorities have introduced a directive compelling steel product manufacturers to ensure that their input/base steel materials themselves conform to the Indian Standards (IS) corresponding to the final product standard claimed. In effect, when you manufacture a steel product that is certified under a particular IS (and by extension under BIS/ISI certification), the raw steel or intermediate substrate feeding into that product must itself adhere to a mapped IS standard. This builds a direct linkage between the upstream inputs and downstream product certifications.
This article explores the rationale behind this directive, its scope, practical implications, challenges, and recommended approaches for compliance.
Why This Mandate Matters
Strengthening Quality Assurance Across the Value Chain
One of the persistent risks in steel manufacturing (and in many materials-driven industries) is that defects or nonconformities in raw or intermediary materials propagate downstream — sometimes invisibly — and only manifest later in service or under stress. By mandating input conformity, regulators aim to intercept potential lapses early in the chain, thereby strengthening the integrity of engineered products in critical sectors like construction, pressure vessels, automotive, energy, and infrastructure.
Simplified Certification & Audit Process
When BIS or ISI auditors and reviewers see a documented chain that directly ties certified input materials to certified final products, it reduces ambiguities, minimizes audit queries, and speeds up certification or surveillance processes.
Traceability & Supply Chain Discipline
The requirement pushes manufacturers to demand proper test certificates, heat number tracking, suppliers’ declarations, and inspection logs from upstream mills or intermediaries. This elevates discipline and standardizes documentation across the supply chain.
Market Credibility & Risk Mitigation
In sectors where safety, durability, and performance margins matter, clients, EPC players, and government agencies may demand stricter compliance. Adhering to this order not only reduces risk of product failures but also bolsters brand reputation and acceptance in demanding tenders.
Scope & Applicability
Who Must Comply?
- Primary steel producers (e.g. slab, billet, bloom makers), intermediate and secondary steel processors supplying substrate materials (cold/hot rolled, wire rod, etc.).
- Downstream manufacturers producing bars, sheets, coils, tubes, wires, coated products, electrical steels, specialty grades under various IS product standards.
What Is Covered?
- The directive includes a mapping table that links over 140 product-to-input combinations — e.g. flat products, long products, coated steels, wires, strips, specialty steels, etc.
Examples (illustrative):
- For IS 1786:2008 (high-strength deformed bars), the upstream input must comply with IS 14650:2023 (carbon steel billets/ingots) in applicable sizes.
- For IS 277:2018 (galvanized sheets), the input substrate must adhere to one of IS 513, IS 1079, IS 2062, IS 5986, or corresponding parts.
- For IS 2002:2024 (steel plates for pressure vessels), input must comply with IS 14650:2023.
- For IS 14246:2024 (pre-painted galvanized sheets), the galvanized substrate must itself be under IS 277:2018.
Exceptions / “Not Applicable” Clauses
- In some cases, the order explicitly states “Input: Not Applicable” (for example, grain-oriented electrical steel in IS 3024:2015).
- Certain small sizes or specific subcategories (e.g. < 8 mm bars) may have caveats.
Practical Implications & Compliance Strategy
1. Input Sourcing & Supplier Qualification
- Choose mills or stockists capable of providing valid test certificates or mill test reports (MTRs) that explicitly state compliance to the mapped input IS standard.
- Suppliers must declare chemical composition, mechanical properties, heat numbers, and manufacturing route (if relevant).
- For multi-stage processes (e.g. hot-rolled → cold-rolled → coated), each intermediate substrate must comply with its designated IS in the chain.
2. Document & Traceability Controls
- Maintain traceability from input → processing → final product via heat numbers or batch codes.
- Store and cross-reference all test reports, conversion logs, inspection records, and purchase orders that reference both the final IS spec and the input IS standard.
- Update internal drawings, bill of materials, purchase specifications, and RFQs to require both standards.
3. Quality Management & Inspection Scheduling
- Update your incoming inspection checklists to require verification of input materials per their IS standard: chemical tests, mechanical tests, dimensional tolerances, etc.
- Calibrate and audit internal labs or partner labs to conduct tests to the input IS specification.
- During BIS audits or surveillance, be ready to show a clear, unbroken chain from input to final.
4. Audit Preparedness & Risk Mitigation
- Preemptively conduct internal audits or mock BIS audits that verify input-to-product traceability.
- Identify weak links or gaps in documentation, supplier credentials, or inspection practices, and build a corrective action plan.
- For borderline or ambiguous material routes, seek clarifications or rulings from BIS or relevant standardization bodies.
5. Contractual & Legal Alignment
- Ensure purchase orders to your suppliers explicitly mention both the final product standard and the required input IS standard.
- Incorporate warranty, material acceptance, rejection criteria, and liability clauses tied to compliance with both levels of IS standards.
- Regularly review and update supplier contracts, especially when standards get revised.
Challenges & Mitigations
| Challenge | Potential Risk | Mitigation Strategy |
|---|---|---|
| Suppliers not accustomed to being asked for input IS compliance | Resistance, additional cost | Educate suppliers; offer shared audit or certification support; build preferred supplier list |
| Documentation gaps or mismatches | Audit exclusions or non-conformity flags | Retrospective fill-in, supplier certificate alignment, pre-shipment checks |
| Multi-step processing requiring multiple IS links | Complex audit trail, potential confusion | Build a clear “chain” mapping in your QMS; internal cross-verification |
| Standard revisions or conflicting versions | Uncertainty regarding which version to follow | Monitor BIS/IS updates; freeze to applicable version at order level; seek clarifications |
| Small lot sizes or niche grades | Difficulty in finding compatible input suppliers | Consolidate procurement, explore collaborations, incentivize compliance |
Steps to Implementation: A Road Map
Gap Assessment
Map your current product range against the directive’s product–input table. Identify which products you manufacture and which inputs need compliance.
Supplier Audit & Onboarding
Audit existing suppliers for their ability to furnish MTRs or TCs certifying input IS standards. Onboard or replace as needed.
Update QMS & Documentation
Revise quality procedures, incoming inspection checklists, document templates, and training programs to embed the compliance requirement.
Mock Audits & Pilot Runs
Perform pilot projects or mock BIS inspections for selected products to validate the traceability and documentation in practice.
Full Rollout & Surveillance Readiness
Extend compliance across all product lines. Maintain continuous surveillance, periodic audits, and corrective feedback loops.
Feedback & Continuous Improvement
Closely monitor BIS audit findings and queries, refine your processes, and update internal best practices accordingly.
