Indian Compliance
When Is BIS CRS Not Required? Exemption Scenarios Including the New Highly Specialized Equipment (HSE) Rule
BIS CRS registration is mandatory for every electronic and IT product notified under the Electronics and Information Technology Goods (Requirements for Compulsory Registration) Order, 2021. Without it, customs will not clear the goods. But the rules do recognise a few situations where a product can be imported or made without CRS registration.
The most important of these was updated recently. Under S.O. 1246(E) dated 10 March 2026, the Ministry of Electronics and Information Technology (MeitY) rewrote the exemption for Highly Specialized Equipment (HSE), effective 15 June 2026. It matters most to businesses that import small quantities of large, high-value equipment. This guide explains the new HSE rule in detail, the other exemption scenarios and the cases that are often mistaken for exemptions.
Scenario 1: Highly Specialized Equipment (HSE)
What the order says
S.O. 1246(E) replaces the wording of Paragraph 8 of the Order, which was first inserted by S.O. 2844(E) dated 1 July 2021. Paragraph 8 now reads:
Exemption for Highly Specialized Equipment (HSE): HSE as per the criteria given below shall stand exempted from application of this Order based on specific exemption issued by Ministry of Electronics and Information Technology under Para 2 of Gazette notification S.O. No 1248(E) dated the 18th March, 2021, as amended by S.O. 1929 (E) dated 26th April 2023, provided they are manufactured/ imported in less than 100 units per model per year-
a. Equipment Powered by three phase power supply or
b. Equipment Powered by single phase power supply with current rating exceeding 16 Ampere or
c. Equipment with dimensions exceeding 1.5 m x 0.8 m or
d. Equipment with weight exceeding 80 Kg
Read the Gazette notification S.O. 1246(E).
The two conditions you must meet
Your equipment qualifies only if both of these are true:
- Low volume: fewer than 100 units of the model are made or imported in a year.
- At least one technical criterion from the table below.
| Criterion | Qualifies if the equipment |
|---|---|
| Power supply | runs on a three-phase supply |
| Current rating | runs on single phase with a current rating above 16 A |
| Size | measures more than 1.5 m x 0.8 m |
| Weight | weighs more than 80 kg |
Any one technical criterion is enough; you do not need all four.
How the 100-unit limit is counted
- Per model: the count is by regulatory model number.
- Per calendar year: MeitY's FAQ clarifies that "year" means the calendar year (January to December), following the General Clauses Act, 1897.
- Across all locations: units of the same regulatory model imported at different ports or by different locations all count towards the same limit.
- When the limit is reached: MeitY stops issuing exemptions for that model for the rest of the calendar year, and further units need BIS registration.
How to apply for an HSE exemption
MeitY set out the procedure in its circular W-47/21/2022-IPHW dated 12 March 2026:
- Apply online in the HSE section of the online exemption portal at ICEGATE.
- Upload the brand's authorisation letter, digitally signed by the brand owner or its authorised signatory, listing the regulatory model number and quantity for import under HSE.
- Upload the proforma invoice or customs packing list, together with the technical datasheet or product specification showing that the equipment meets the HSE criteria.
- Upload a safety test certificate or report. If you do not have one, the manufacturer can submit a declaration on OEM letterhead confirming that the product meets international safety standards.
- Receive the exemption letter through the portal, which MeitY issues within 5 working days of filing.
The letter is valid until the end of the calendar year. Customs allows HSE imports only on the basis of this letter, and other applicable laws still apply. The brand owner must keep a list of the model numbers and quantities it has authorised, and MeitY may verify the authorisation letters.
Worked examples
| Example | Volume | Technical criterion | Outcome |
|---|---|---|---|
| A three-phase server system for a data centre | 12 units a year | Three-phase supply | Can apply for HSE exemption |
| A large-format printer measuring 1.8 m x 0.9 m | 40 units a year | Size above 1.5 m x 0.8 m | Can apply for HSE exemption |
| A single-phase unit rated 32 A | 25 units a year | Single phase above 16 A | Can apply for HSE exemption |
| A 95 kg equipment cabinet | 150 units a year | Weight above 80 kg | Exemption stops once the limit is reached; BIS registration is needed for the rest |
| A high-priced desktop-size device, single phase 10 A, 25 kg | 20 units a year | None | Not HSE; BIS registration needed |
The last example is the most common misunderstanding: a low quantity or a high price alone does not exempt a product. The equipment must also be large, heavy or high-powered as defined above.
Scenario 2: Demonstration, R&D and Testing
MeitY has clarified, in its circular W-47/4/2020-IPHW dated 26 April 2022, that the Order does not apply to goods imported for demonstration, research and development or testing in India, provided they are later exported or destroyed. This covers:
- samples imported for testing at a BIS-recognised lab as part of CRS registration
- prototypes and units for R&D work
- units for demonstration
These goods cannot be sold in India. Our sample import service handles the paperwork for clearing test samples.
Scenario 3: Spare Parts and Components
The Order applies to finished goods. According to MeitY's FAQ, it does not apply to spare parts or components used to make the finished product, unless a part is separately notified as a product under the Order. A part that is itself a notified product, such as a power adapter or a keyboard sold as a finished product, still needs registration.
Scenario 4: CKD and SKD Kits for Manufacturing in India
Notified products can be imported in CKD (completely knocked down) condition. Imports in SKD (semi knocked down) condition are allowed only for the manufacturer of the finished product, and customs checks that the importer is authorised by the brand owner to assemble or make it. The finished product made in India still needs CRS registration before it is sold; this route changes where assembly happens, not whether the product is registered.
Scenario 5: Products Outside the Notified List
CRS applies only to products notified by MeitY. If a product is not on the list, CRS does not apply, though other rules may. The boundaries can be narrow: for example, desktop computers are specifically excluded from the automatic data processing machines category, but all-in-one computers, workstations, thin clients and mini PCs are covered. Check the notified list and standard for your exact product in our guide to the BIS Compulsory Registration Scheme.
Scenario 6: Case-Specific Exemption Letters
Under Para 2 of the Order, MeitY can issue a specific exemption letter for a particular consignment, applied for on the online exemption portal at ICEGATE. MeitY has said that it receives many such requests, for reasons such as spares for medical devices, goods for export, CSR projects, personal use and government projects, and has reminded businesses that these exemptions are only for exceptional cases. Do not build a business plan around them; register the product instead.
What Is Not an Exemption
- Low quantity or high value alone, unless the product also meets an HSE technical criterion.
- Second-hand, refurbished or repaired goods: the import policy covers notified goods whether new or used.
- Selling only online or only to businesses.
- A foreign certificate such as CE or UL. These can support the HSE safety document, but they do not replace CRS registration.
Without a registration or a valid exemption, notified goods arriving at customs must be re-exported; otherwise customs can deform them beyond use and dispose of them as scrap.
Exemption or Registration: Which Is Right for You?
If your volume will stay well under 100 units per model each year and the equipment clearly meets an HSE criterion, the exemption can save you the cost and time of testing and registration. If your volumes may grow, or the product is borderline, BIS CRS registration is usually the safer long-term choice, because the exemption has to be renewed every calendar year and stops at the 100-unit limit. See our guide to how long CRS registration takes to compare.
How Instacertify Helps
- We check whether your product is notified and whether it meets the HSE criteria.
- We prepare the authorisation letter, the technical justification and the safety documents, and file the HSE application on ICEGATE.
- We track your annual quantity per model, so you know when to move to registration.
- When registration is the better route, we handle testing and the full BIS CRS registration.
Importing for the first time? Also read our guides to BIS certification for imports and AD code and ICEGATE registration, or talk to our team about your equipment.
Frequently asked questions
What is the HSE exemption under BIS CRS?
From 15 June 2026, under S.O. 1246(E) dated 10 March 2026, Highly Specialized Equipment can be exempted from the Electronics and IT Goods (Requirements for Compulsory Registration) Order, 2021 if fewer than 100 units per model are made or imported in a calendar year and the equipment is three-phase, single-phase above 16 A, larger than 1.5 m x 0.8 m, or heavier than 80 kg. A specific exemption letter from MeitY is required.
Does my equipment need to meet all four HSE criteria?
No. It needs to meet any one of the four technical criteria, and also stay under 100 units per model per calendar year.
Is the HSE exemption automatic?
No. You must apply on the online exemption portal at ICEGATE and receive a MeitY exemption letter. Customs allows HSE imports only on the basis of that letter.
How long does MeitY take to issue an HSE exemption letter?
MeitY's procedure says the letter is issued through the portal within 5 working days of filing the application.
How is the 100-unit limit counted?
Per regulatory model number, per calendar year, across all locations. Once the quantity reaches the limit, MeitY stops issuing exemptions for that model for the rest of the year and further units need BIS registration.
I import only a few units of an expensive product. Am I exempt from CRS?
Not on quantity or price alone. Low volume helps only if the product also meets one of the HSE technical criteria and you hold a MeitY exemption letter. Otherwise, the product needs BIS registration or another valid exemption.
Can I import samples for BIS testing or R&D without registration?
Yes. MeitY has clarified that the Order does not apply to goods imported for demonstration, research and development or testing, provided they are later exported or destroyed. They cannot be sold.
Do spare parts need BIS CRS registration?
The Order applies to finished goods, not spare parts or components used to make them, unless a part is separately notified as a product under the Order.