BIS Scheme X is Gone — What Does It Mean for Your Advance Licence?

In a move that caught many importers and manufacturers off guard, the Ministry of Heavy Industries on January 14, 2026 officially repealed the Machinery and Electrical Equipment Safety (Omnibus Technical Regulation) Order, 2024 — effectively scrapping BIS Scheme X altogether. Launched in August 2024, postponed, suspended, and now fully repealed, it has been a turbulent journey.
But businesses are now asking: What does the end of BIS Scheme X mean for Advance Licences? The answer is nuanced — and getting it wrong could cost you.

What Was BIS Scheme X?
BIS Scheme X was a mandatory certification framework under the BIS Act, 2016, designed to ensure machinery and electrical equipment — primarily under HS Chapters 84 and 85 — met Indian safety and quality standards before being sold or imported. It would have required manufacturers and importers to obtain a BIS licence or Certificate of Conformity before customs clearance.

Why Was It Scrapped?
The repeal was driven by practical realities. Industry stakeholders flagged three persistent problems: a shortage of BIS-recognised testing laboratories, incomplete product-specific Indian standards for many machinery categories, and ambiguity around how sub-assemblies and components would be treated. Invoking public interest under Section 16 of the BIS Act, 2016, the government chose to withdraw a regulation that wasn’t operationally ready.

The Advance Licence Connection: What Changes?
The Advance Authorisation scheme under DGFT allows exporters to import inputs duty-free, provided they are physically incorporated in export products. The scrapping of BIS Scheme X has direct and indirect implications for Advance Licence holders importing machinery, capital goods components, or electrical equipment under Chapters 84/85.

1. Immediate Relief on OTR-Covered Imports
Goods previously earmarked for Scheme X compliance can now be imported without the OTR certification requirement. For Advance Licence holders who were unsure whether their machinery inputs would clear customs post-September 2026, that hurdle has been removed.

⚠️ Critical Caveat
BIS Schemes I (ISI Mark) and II (CRS/Registration) remain fully in force. Components, spare parts, or product variants within your Bill of Materials may still attract mandatory BIS certification. Audit every line item — Scheme X’s removal does not grant a blanket exemption across HS 84/85.

2. DGFT Notification 71/2023 Remains Operative
DGFT Notification No. 71/2023 eliminated the blanket exemption that previously allowed BIS-regulated goods to be freely imported under Advance Authorisations. Pre-import conditions, specific endorsements, and end-use monitoring continue to apply to QCO-covered items. The scrapping of Scheme X removes the OTR-based QCO, but QCOs issued by DPIIT, Ministry of Steel, and Ministry of Textiles remain fully active.

3. Export Obligation Deadline Relief
✅ Good News for EO Holders
On March 6, 2026, DGFT automatically extended Export Obligation periods for Advance Authorisations expiring between March 1 and May 31, 2026 — pushing them to August 31, 2026, with no application or composition fee required. A timely buffer for businesses managing compliance disruptions.

4. SION and Bill of Materials Review Now Warranted
Companies that structured their Standard Input-Output Norms (SION) applications or ad-hoc norms around anticipated Scheme X compliance requirements should revisit their filings. If product specifications or input descriptions were adjusted for Scheme X-compliant variants, those changes may no longer be necessary — updating norms now simplifies future licences.

5. Watch for a Revised OTR Framework
The government has not permanently abandoned safety regulation for machinery. A restructured OTR framework is widely expected. Advance Licence holders should monitor MHI and CBIC notifications closely, as future conditions on import clearances could be updated when a revised regulation is introduced.

What Should You Do Right Now?
• — identify items still covered under BIS Schemes I or II; do not assume full clearance.Audit your Bill of Materials
• — check if adjustments were made in anticipation of Scheme X requirements.Review your SION or ad-hoc norms
• — if they fall between March–May 2026, the automatic extension to August 31, 2026 applies.Check your EO deadlines
• — a revised OTR may reinstate obligations for some product categories.Do not restructure imports prematurely
• — confirm the current status of all QCOs applicable to your specific HS codes.Consult your customs broker or trade counsel

Bottom Line
The scrapping of BIS Scheme X is good news in the short term — it removes a compliance layer that wasn’t ready to be enforced. But it is not a free pass. The existing BIS architecture, DGFT notification conditions, and QCO obligations continue in full force. Treat this as a moment to clean up your compliance posture, not to relax it.

Have questions about how BIS Scheme X’s repeal affects your specific Advance Licence? Reach out to us — we’re happy to help you navigate it.