Transition Facilitation Order: Scheme II for ten QCOs

What the order says

The Transition Facilitation (Quality Control) Order, 2026 was notified as S.O. 3417(E) on 25 June 2026 by the Department for Promotion of Industry and Internal Trade, under section 16 read with sub-section (3) of section 25 of the Bureau of Indian Standards Act, 2016. It came into force on publication.

Its mechanism is one sentence in clause 3(1). Notwithstanding anything in the Quality Control Orders named in its Schedule, goods covered by those orders shall conform to the corresponding Indian Standards and “shall be permitted use of a Standard Mark under a license from Bureau of Indian Standards as per Scheme II of the Schedule II” to the Conformity Assessment Regulations of 2018, subject to the rest of the order.

That is the part worth reading twice. The ten orders in the Schedule require the Scheme I licence, which is the ISI mark: a licence for a named product made at a named factory, granted after BIS assesses the factory and drawn samples, with surveillance continuing for the life of the licence. Scheme II is the registration route. The product is tested in a BIS-recognised laboratory and the manufacturer registers a declaration of conformity, with no factory assessment, which is why it is faster. Swapping one for the other is a material change in what a supplier has to do, and BIS certification under the two schemes is not the same obligation wearing a different name.

The Schedule, and the date that matters this week

Ten orders are listed, with the date of issue and date of implementation the Schedule gives for each: toys (01.01.2021), personal protective equipment footwear (01.01.2022), air conditioners and related parts (01.10.2023), footwear made from rubber and polymeric material (01.08.2024), footwear made from leather and other materials (01.08.2024), electrical appliances for domestic water heating (01.03.2025), electrical appliances for domestic clothes washing (01.04.2025), hinges (01.07.2025), furniture (13.02.2026), and at entry 10 the Safety of Household, Commercial and Similar Electrical Appliances (Quality Control) Order, 2026, at 01.10.2026.

Entry 10 is the order that takes effect tomorrow, and this site reported it on 28 September: ninety classes of goods, roughly a fifth of them commercial catering equipment, and small and micro units get January and April rather than October. S.O. 3417(E) does not move that date. It contains no commencement provision for any order but itself, and it amends none of the ten. A reader who found this order while looking for a postponement has found something else.

Who it is for, and who it is not for

The route does not open to whoever wants it. Clause 3(2) says the Scheme II licence “shall be available only to a manufacturer for supplying to the person who has been granted specific permission under clause 4”. So the licence sits with the supplier, and the permission sits with the buyer, and the supplier’s licence is good only for supplying that permitted buyer.

Clause 4(1) then says who can be that buyer. Permission may be granted “to a person that is a company incorporated under the Companies Act, 2013”, and on the basis of a risk assessment by an Implementation Committee. A proprietorship is not a company incorporated under the Companies Act, 2013. Neither is a partnership firm registered under the Indian Partnership Act, 1932, and neither is a limited liability partnership, which is incorporated under the Limited Liability Partnership Act, 2008.

That is most of the western Indian supply base. A machine shop in Rajkot trading as a proprietary concern, a sheet-metal partnership in Ahmedabad building bains-marie for hotel kitchens, an LLP assembling floor scrubbers near Pune: none of them can hold a permission under this order, whatever their turnover and whatever their compliance record. Being classed as a micro or small enterprise does not help here either, because the order’s gate is the form of the legal entity, not its size. The relief in the appliances order that turns on size is the MSMED classification on the Udyam registration certificate, and that is a different provision in a different order.

A firm in that position can still be on the other side of the transaction. A proprietorship holding a Scheme II licence, the registration route the trade calls the Compulsory Registration Scheme, may supply a permitted company under clause 3(2), and the order puts no entity condition on the manufacturer. What it cannot do is use the route for its own compliance.

What the Committee weighs

Clause 4(4) lists what the Implementation Committee assesses: technical capability; demonstrated experience; how quality assurance is maintained across the supply chain, including control over design and manufacturing; the history of conduct and compliance integrity; and a commitment to establish supply chain capabilities in India for the goods concerned by promoting technological adoption or advancement, design capability, or research and development. Alternatively, compliance with the relevant Quality Control Order for a continuous period of three years without default.

The Committee may ask for documents, declarations, certifications, undertakings and independent assessments, and may interact with the applicant. Permission carries conditions, and clause 4(6) lets the Central Government suspend, modify or withdraw it for breach of conditions, misrepresentation of material facts, or a product that fails to conform, after an opportunity to be heard. BIS carries out market surveillance on goods moving under the route, under clause 3(4).

Two clocks run. Applications are accepted within twenty-four months of commencement, which puts the window at 25 June 2028 on the face of clause 5(1). The order itself stays in force for five years from commencement and then stands rescinded unless extended by notification, though a permission already granted survives the rescission for the period it specifies. The application process, documentation and entitlements are to be set out in guidelines DPIIT will publish on its own website; those guidelines were not on dpiit.gov.in when this was written on 30 September 2026, so the practical question of what an application looks like has no answer yet.

What to do with this

If you supply a large customer that is a company, and the product is under one of the ten orders, the customer may be able to take the Scheme II route and may ask you to register under it. That is a conversation to have before the customer has it with somebody else, because the licence has to exist on your side for the permission to be worth anything on theirs.

If you are a proprietorship or a partnership working to a Quality Control Order date of your own, this order changes nothing for you, and the compliance advice circulating about it is worth reading against clause 4(1)(a) before anyone pays for it. The date in your order is still the date.

The Schedule is also a closed list of ten orders, not a general relief. An order notified after it gets no Scheme II route at all: the hand tools order of October 2026 requires the Scheme-I licence outright, and a wrench or pliers maker reading about this transition route will not find its own standard in the Schedule.

EngiNewsIndia reads these notifications at source and will report the DPIIT guidelines when they appear, alongside the rest of the policy, schemes and MSME reporting.