Lithium-Ion Battery Import Licence

Importing lithium-ion batteries into India is not a single-window clearance. Before your first consignment clears Customs, your manufacturer needs a BIS Certificate of Registration under IS 16893. Before you sell a single unit, you need to be registered as a Producer on the CPCB's EPR portal under Battery Waste Management Rules 2022. And if your storage crosses certain quantity thresholds, a PESO licence is mandatory. Miss any one of these and your shipment sits at port while demurrage charges accumulate.

The encouraging reality is that every layer follows a defined process with fixed timelines. BIS certification is the longest critical path — three to six months for a new foreign manufacturer or new model. Once that is in place, EPR registration, PESO approval, and customs filing all run in parallel or complete quickly. This page maps every compliance layer for FY 2026-27 and explains the exact sequence.

At a Glance

• Who must comply: Any person importing Li-ion cells, modules, packs, or battery systems into India — whether for resale, OEM supply, or own use.
• Governing laws: BIS Quality Control Order (IS 16893-1 / -2 / -3 / -4); Battery Waste Management Rules 2022; MSIHC Rules 1989; Explosives Act / PESO Rules.
• End-to-end timeline: 4–8 months. BIS CRS for a new foreign manufacturer takes 3–6 months; EPR registration runs in parallel and takes 4–6 weeks.
• Import volume threshold: No minimum — BIS certification is mandatory for every commercial import regardless of quantity or value.
• EPR obligation: Escalating annual collection target on imported weight; certificates purchased from CPCB-authorised recyclers to fulfil each year's quota.
• PESO applicability: Storage above threshold quantities — typically around 10 kg of cells in industry practice — requires a PESO facility approval and inspection.
• HS classification: Primarily 8507.60 for Li-ion batteries; verify the specific sub-heading at import to compute the correct Basic Customs Duty and check anti-dumping notifications.

What's New for FY 2026-27

Regulatory enforcement around Li-ion battery imports has tightened considerably since FY 2024-25. Here is what changed and what it means for your import plan.

• Stricter QCO enforcement at ports: DPIIT has directed Customs to reject BIS-QCO-covered goods at entry without a current CRS. Consignments lacking a valid BIS certificate are detained and may be re-exported at the importer's cost — there is no grace period.
• EPR targets escalated under Battery Waste Management Rules 2022: Annual collection targets rise each financial year. FY 2026-27 targets are materially higher than the FY 2024-25 baseline; importers who deferred CPCB registration are now receiving penalty notices under Rule 22.
• Quarterly EPR certificate reconciliation mandatory: Producers importing more than 1,000 kg per year must submit quarterly certificate transaction reports from FY 2026-27 onward. Annual filing alone is no longer sufficient.
• IMS live on ICEGATE: The Invoice Management System for GST-on-import is active. Mismatches between Bill of Entry values and supplier invoices are flagged automatically, causing assessment delays — verify BoE data against the commercial invoice before submission.
• Anti-dumping reviews — verify before contracting: DGTR has reviewed Li-ion cell imports from multiple origins. Before signing any FY 2026-27 supply agreement, confirm whether a provisional or final anti-dumping or safeguard duty applies to your specific HS sub-heading and country of origin.
• DPDP Act cross-border data obligations: Importer onboarding workflows that collect personal data from overseas manufacturers or logistics partners must now account for cross-border data transfer obligations under the Digital Personal Data Protection Act 2023.

Who Needs This Service

• EV manufacturers and Tier-1 suppliers: Importing cells or packs from China, South Korea, or Japan for integration into electric two-wheelers, three-wheelers, or passenger vehicles where the battery requires its own separate BIS certification.
• Consumer electronics importers: Phones, laptops, tablets, and power banks where the battery is a standalone product or part of an unassembled kit — each distinct cell model requires its own IS 16893 certificate.
• Energy storage system companies: Battery modules for solar-plus-storage or grid-scale projects where large-format Li-ion packs are imported as equipment requiring both BIS coverage and MSIHC compliance.
• Industrial equipment importers: Forklifts, Automated Guided Vehicles (AGVs), and UPS systems using Li-ion packs that need separate BIS certification independent of the parent machine's certification.
• E-mobility startups: Importing prototype or pre-production battery systems for testing or pilot deployment — noting that commercial BIS exemptions for R&D are narrow and routinely scrutinised by Customs.
• Trading companies and distributors: Acting as the declared importer-of-record and therefore the responsible Producer under Battery Waste Management Rules 2022, regardless of whether you manufacture anything.
• NRI-owned import businesses: Setting up battery import and distribution operations from outside India, where the full compliance setup — BIS, EPR, PESO — must be in place before the first commercial shipment.

How It Actually Works

End-to-end Li-ion battery import compliance runs in six stages. The stages overlap where possible to reduce total elapsed time — EPR registration and PESO preparation run while BIS testing is under way.

Step 1: Compliance Mapping (Weeks 1–2)

Your import profile — chemistry (LFP, NMC, NCA, LTO), form factor (cell, module, pack, or system), planned annual volume, and end-use sector — determines exactly which compliance layers apply. We produce a written compliance map covering BIS, EPR, PESO, MSIHC, HS classification, and any applicable trade-remedy duties. This document becomes the master reference for every step that follows.

Step 2: BIS CRS Certification (Months 1–6)

The foreign manufacturer applies through the BIS online portal, often through an Authorised Indian Representative. Sample units are submitted to a BIS-recognised test laboratory for testing under IS 16893 — covering abuse testing, thermal runaway assessment, cycle life, and electrical safety. Testing alone typically takes eight to twelve weeks.

On successful test results, BIS reviews the application and issues the Certificate of Registration. The CRS covers specific models and must be renewed periodically. Each additional model or cell chemistry requires a separate certification, though manufacturers with prior BIS certificates can apply for new models in parallel to compress the timeline.

Step 3: EPR Registration on CPCB Portal (Weeks 4–10, parallel with BIS)

Under Battery Waste Management Rules 2022, any entity that imports batteries is a 'Producer' and must register on the CPCB EPR portal before beginning commercial imports. Registration requires company documents, IEC code, battery type details, estimated annual quantities, and a proposed recycler network.

Once registered, CPCB assigns an annual collection target. You then purchase EPR certificates from authorised battery recyclers or refurbishers equal to your target obligation — these certificates are the proof that you funded the required end-of-life management for the batteries you placed on the market.

Step 4: PESO Licence and MSIHC Setup (60–120 Days, where applicable)

If your facility will store Li-ion batteries above applicable threshold quantities, a PESO storage licence is required under the Explosives Act and related rules. The facility design must meet fire separation distances, construction standards, ventilation specifications, and emergency-response requirements. PESO inspects the facility before granting the licence, which is then renewed every two to three years.

For large-volume operations, MSIHC Rules 1989 may classify your site as a Major Accident Hazard (MAH) facility. This triggers requirements for on-site and off-site emergency response plans and periodic safety reports submitted to the district authority.

Step 5: First Import — Customs Clearance

Once BIS CRS is confirmed and EPR registration is in hand, your first consignment can be filed on ICEGATE. The Bill of Entry must carry the correct HS sub-heading, the BIS certificate number, EPR registration proof, and — where applicable — a PESO licence reference for bonded storage. Basic Customs Duty, IGST, and any anti-dumping or safeguard duty are computed on the assessable value.

Each document is reviewed before filing to prevent first-attempt errors. Cleared cargo then moves from the port to your facility under transit insurance.

Step 6: Ongoing Annual Compliance

After first import, compliance runs as a repeating annual cycle. BIS CRS must be kept current and renewed before expiry; new models added to your product range require fresh applications. Any change in the manufacturer's production site or cell specification triggers an amendment or a new application — early planning prevents coverage gaps.

CPCB EPR annual returns are filed each year by the prescribed deadline; quarterly transaction reports are mandatory for importers above 1,000 kg per year. PESO licences renew every two to three years, and MAH-classified facilities must submit updated safety reports annually.

A Real Example: Electronics Distributor Importing 18650 Cells

Consider a Delhi-based electronics distributor planning to import cylindrical 18650 NMC cells from a South Korean manufacturer at ₹45 per cell, in consignments of 50,000 cells — approximately 130 kg per shipment, four shipments per year. Here is how each compliance layer plays out in actual numbers.

• BIS CRS timeline: The South Korean manufacturer had no prior BIS certification for the Indian market. Sample testing under IS 16893-3 took eleven weeks; the full certification elapsed five months. The first shipment was scheduled once the CRS was confirmed — no consignment was sent on speculation.
• EPR annual obligation: Total annual import: 130 kg × 4 shipments = 520 kg. Year 1 EPR target at 30% = 156 kg recycled equivalent. EPR certificates purchased from an authorised recycler at ₹10 per kg = ₹1,560 for the year — a minor operational cost at this scale, though the target percentage rises each year.
• PESO storage: Warehouse holds up to 200 kg at any one time. PESO inspection completed and licence granted. Annual compliance cost: inspection fee plus licence renewal once every three years.
• Customs duty at first import: Assessed value ₹22,50,000 (50,000 cells × ₹45). BCD at applicable rate plus IGST 18%. Anti-dumping duty for this specific HS sub-heading and South Korean origin: nil as of the date of contracting — confirmed by written DGTR notification check before the supply contract was signed.
• Overall landed cost impact: Full compliance setup added approximately 0.8% to landed cost per unit in Year 1, including professional fees. For a product with this value density, that is well within a normal margin assumption.

The distributor's first consignment cleared Customs in four working days after BIS CRS was in hand — standard processing for a compliant, fully-documented import.

Annual Compliance After Your First Import

Your obligations under the Battery Waste Management Rules 2022 and BIS conditions do not stop at Customs clearance. Each of the following runs as a recurring duty on every importing company.

• BIS CRS renewal: Certificates carry a defined validity period and must be renewed before they lapse. Any change in the manufacturer's production location, cell chemistry, or pack design specification triggers a fresh application or amendment.
• EPR annual return: Filed on the CPCB EPR portal by the prescribed annual deadline. Declares total quantity imported, EPR certificates purchased, and recycler details. Late filing attracts penalties under Rule 22.
• Quarterly EPR certificate transactions: For Producers importing above 1,000 kg per year, transaction reports must be submitted quarterly — not just annually — from FY 2026-27 onward. CPCB has begun matching these against portal data.
• PESO licence renewal: Required every two to three years. A facility re-inspection may be required if the storage layout has changed since the original licence was granted.
• MSIHC annual safety report: MAH-classified facilities must submit updated annual safety reports and maintain current on-site and off-site emergency plans accepted by the district authority.
• GST IMS reconciliation: IGST paid at import is available as input tax credit. IMS-flagged mismatches between Bill of Entry values and supplier invoices must be resolved before the credit is consumed in GSTR-3B.

A single missed EPR annual return can result in suspension of your Producer registration — blocking all future imports until the registration is reinstated and past obligations are discharged.

Where It Goes Wrong

Most Li-ion import compliance failures follow predictable patterns. These are the ones that result in port holds, penalty notices, or blocked registrations.

• Importing before BIS CRS is issued: Customs detains the consignment under the QCO. Demurrage accumulates by the day. In repeat cases, DPIIT can initiate action against the importer and blacklist the foreign manufacturer's products.
• Wrong HS sub-heading: Li-ion batteries span multiple 8507 sub-headings with different duty rates and different anti-dumping notification coverage. A single digit error changes your landed cost and your legal exposure.
• Treating EPR as post-import paperwork: CPCB treats EPR registration as a pre-condition for importing, not a formality after the fact. Importers without registration are classified as Producers-in-default from their very first unregistered import date, and obligations are assessed retrospectively.
• Underestimating escalating EPR targets: The year-on-year target schedule under Battery Waste Management Rules 2022 means Year 3 and Year 4 quotas can be three to four times the Year 1 baseline. Budget only for the current year and you face a certificate shortfall in later years.
• Overlooking PESO for warehouse storage: A logistics or manufacturing facility that accumulates Li-ion stock above threshold quantities without a PESO licence is operating an unlicensed hazardous storage site. Inspections result in stoppage notices and can halt all operations at the location.
• Assuming one BIS certificate covers all models: A certificate for one cell type or pack configuration does not extend to other chemistries or form factors, even from the same manufacturer. Each distinct product needs its own IS 16893 certification before it can be imported.
• Misusing the R&D exemption: Commercial quantities cannot be imported under the narrow prototype or R&D exemption. Customs regularly challenges consignments that cite this route for anything above small, clearly experimental quantities — and penalties apply to the full import value.
• Not checking anti-dumping duty before signing supply contracts: Suppliers quote ex-works prices; the importer carries the anti-dumping duty. Discovering a provisional duty applies after the contract is signed can eliminate the entire import margin.

What You Receive at the End

• BIS Certificate of Registration (CRS) under IS 16893 for all covered models, ready for Customs presentation on every import
• CPCB EPR Producer Registration Certificate with annual target schedule and certificate procurement strategy
• PESO Storage Licence with facility inspection clearance (where applicable to your storage quantities)
• MSIHC compliance documentation and on-site/off-site emergency response plan (for MAH-classified facilities)
• HS classification opinion and written customs duty computation memo covering BCD, IGST, and applicable anti-dumping or safeguard duties
• Bill of Entry filing support and Customs clearance coordination for your first import consignment
• Annual compliance calendar covering BIS renewal windows, EPR annual return deadlines, quarterly transaction report schedules, and PESO renewal dates
• Written anti-dumping duty verification report for your specific HS sub-heading and country of origin, updated before contracting

How to Get Started

Share your importer profile — PAN, GST registration, IEC code, planned battery chemistry (LFP, NMC, NCA, or LTO), form factor (cell, module, or pack), expected annual import volume in kilograms, and your storage arrangement. With this information, our team produces a written compliance map within two working days, identifying exactly which of the six layers apply to your specific product and volume.

BIS CRS is the clock that starts the countdown — the right time to begin the application is before you finalise your supply contract with the foreign manufacturer, not after. Every week of delay in starting BIS pushes your first cleared shipment further out. Fill in your details on this page and a compliance specialist will follow up within one working day.