BIS Scheme X Scrapped: Impact on EPR Compliance in India

https://avigroup.in/epr-registration/On 14 January 2026, the Indian government officially announced that BIS Scheme X — the certification framework introduced under the Machinery and Electrical Equipment Safety (Omnibus Technical Regulation) Order, 2024 — is no longer required. This follows two earlier postponements (August 2025, then September 2026) before the deadline was ultimately suspended and then scrapped entirely.
After nearly two years of regulatory uncertainty — successive delays, an indefinite suspension in November 2025, and finally a full withdrawal — India’s BIS Scheme X is officially gone. For manufacturers and importers of heavy machinery and electrical equipment, the immediate reaction is relief. But the story doesn’t end there. The scrapping of Scheme X has meaningful and underappreciated consequences for Extended Producer Responsibility (EPR) compliance, product lifecycle governance, and India’s broader sustainability agenda.

Let’s unpack what happened, why it matters, and what businesses operating in India’s regulatory environment need to do next.

A Quick Recap: What Was BIS Scheme X?
Introduced through the Machinery and Electrical Equipment Safety (Omnibus Technical Regulation) Order published in August 2024, Scheme X was designed as a unified certification framework under the Bureau of Indian Standards (BIS) Act, 2016. It required manufacturers — both domestic and foreign — to obtain a BIS licence or Certificate of Conformity (CoC) for a wide range of machinery and electrical products falling under HS code chapters 84 and 85 before they could be sold or imported into India.

The intent was sound: consolidate fragmented safety standards, bring machinery and electrical equipment under a single compliance roof, and give Indian consumers assurance about product quality. Implementation, however, proved far more complex. Testing infrastructure was inadequate, product-specific Indian Standards were still being finalised, and the application process lacked clarity. After industry pushback and two formal deadline extensions, the government suspended the implementation date in November 2025 “to a date as may be notified” — and then scrapped it altogether in January 2026.

The EPR Connection: Why This Matters Beyond Certification
Extended Producer Responsibility in India is now a multi-sector mandate governed by the Central Pollution Control Board (CPCB) under the Environment (Protection) Act, 1986. It covers plastics, e-waste, batteries, tyres, and used oil — with further expansion into construction waste and non-ferrous metals underway in 2026. EPR is fundamentally about making producers accountable for the entire lifecycle of their products, including post-consumer collection, recycling, and safe disposal.

Here’s where the Scheme X withdrawal intersects directly with EPR obligations:

1
E-Waste EPR Faces a Product Traceability Gap
Scheme X was intended to serve as a quality and identity checkpoint for electrical and electronic machinery entering India. With it gone, there is no longer a BIS-mandated product registration layer for large swaths of machinery under chapters 84 and 85. This creates a traceability gap: without standardised product identifiers or conformity records at the point of import or manufacture, tracking these products through their lifecycle — which is central to e-waste EPR compliance — becomes significantly harder. Producers registered on the CPCB’s EPR portal for e-waste must now rely more heavily on their own internal systems to establish product lineage.

2
EPR Targets Remain Unchanged — and Deadlines Are Tightening
The scrapping of Scheme X does not alter EPR obligations one bit. Penalties under the Environment (Protection) Act remain steep: up to ₹1 lakh initially, escalating to ₹1 crore in environmental compensation for major breaches, alongside the risk of operational shutdowns and exclusion from government tenders. The MoEFCC’s expanded EPR Rules 2024, effective April 1, 2026, are rolling out on schedule — covering household packaging recycling and introducing EPR for non-ferrous metals, paper, and glass. Businesses that were counting on BIS compliance as a surrogate for EPR readiness are now exposed.

3
Importers Lose a Quality Assurance Buffer
For importers — particularly those dealing in electrical machinery with significant end-of-life waste implications — Scheme X had a silver lining: it would have ensured that products entering India met Indian safety standards, indirectly supporting EPR by ensuring products were designed and documented to a known standard. Without it, there is less certainty about product composition, materials used, and recyclability — all of which are material to EPR fulfilment and the accuracy of CPCB portal reporting.

4
The Regulatory Signal: Deregulation with Sustainability Strings Attached
The Scheme X withdrawal is part of a broader government posture of easing Quality Control Orders (QCOs) and certification burdens to support industrial growth and import facilitation. Several other BIS QCOs were also withdrawn or deferred through late 2025. The government is clearly signalling pro-industry flexibility. However, EPR is moving in the exact opposite direction — expanding in scope, tightening enforcement, and increasing digital scrutiny via the CPCB portal. Companies should not conflate the easing of BIS certification with a relaxation of sustainability obligations. The two regulatory tracks are moving at different speeds, in different directions.

5
Voluntary BIS Compliance Can Strengthen EPR Positioning
Here’s the strategic upside. While Scheme X is no longer mandatory, BIS certification for machinery and electrical equipment remains available on a voluntary basis. Companies that proactively seek BIS conformity — even without a legal mandate — gain documented product-level data that is invaluable for EPR reporting, ESG disclosures, and supply chain due diligence. In a market where global investors are increasingly assessing EPR performance as part of ESG due diligence, voluntary certification is a competitive differentiator, not just a compliance checkbox.

6
Scheme X May Return — Possibly Stronger
It is critical to understand that the January 2026 announcement is a withdrawal of the mandatory requirement, not an abolition of the regulatory vision. The government has signalled it needs more time to finalise product-specific Indian Standards, build testing infrastructure, and develop proper SOPs. Industry observers widely expect a revised version of the OTR framework to be notified — possibly in 2027 — with tighter product categorisation and clearer compliance pathways. Companies with robust EPR systems and product documentation in place will be far better positioned to absorb a future re-introduction of mandatory BIS certification for this category.

What Should Businesses Do Now?
The BIS Scheme X withdrawal is not a free pass. It is a window — use it strategically.

For EPR-Registered Producers
Audit your CPCB portal registrations to ensure product categories are accurately reflected without relying on BIS data. Strengthen your internal product identification and waste volume estimation processes. Do not let the absence of Scheme X become a gap in your lifecycle documentation.

For Importers of Electrical Machinery
Consider voluntary BIS alignment for key product lines, especially those with significant end-of-life waste footprint. This not only prepares you for a future re-notification of OTR but also strengthens your EPR compliance evidence trail and ESG reporting.

For Compliance Teams Broadly
Track the expanded EPR Rules 2024 implementation, which is on track for April 2026. Ensure your CPCB registrations are current, your annual EPR returns are filed, and your recycling targets are being met. The ₹1 crore penalty risk is real — and courts have been consistent in enforcement.

Bottom line: The scrapping of BIS Scheme X removes one compliance obligation but does nothing to reduce EPR exposure. If anything, it widens the product traceability gap at a time when India’s EPR enforcement is becoming more rigorous, more digitised, and more consequential. The companies that will navigate this landscape best are those that treat EPR not as a checkbox but as a core part of their India market strategy.