BIS Toy Certification in India: Navigating QCO and the New IS 9873 Standards

The toy sector is entering a new compliance era as updated BIS toy safety standards, stricter QCOs, and revised IS 9873:2025 requirements impose tighter manufacturing, testing, and certification obligations on both domestic and foreign toy companies.

India’s toy industry has undergone a major regulatory transformation in recent years, driven by a push to improve product safety, strengthen domestic manufacturing, and reduce the circulation of substandard imports. Central to this transition is the mandatory certification framework implemented by the Bureau of Indian Standards (BIS) under the Toys (Quality Control) Order (QCO).

The regulatory regime now requires all toys sold in India, whether domestically manufactured or imported, to comply with prescribed Indian safety standards and carry the ISI mark. These measures have reshaped the domestic toy manufacturing ecosystem by increasing compliance obligations while simultaneously improving consumer trust and export competitiveness.

Why toy quality and safety has become a policy priority

Toys play a critical role in children’s cognitive, emotional, and physical development. However, poor-quality products may expose children to choking hazards, sharp edges, toxic materials, strangulation risks, or electrical dangers.

The central government introduced the Toys QCO, 2020, on September 1, 2020. This introduced safety compliance requirements for toys, aligning Indian regulations more closely with international safety frameworks. The objective is the development of a more organized and globally competitive toy manufacturing sector.

Toys QCO: India’s mandatory compliance regime

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Under the toys QCOs, manufacturers, importers, distributors, retailers, and e-commerce platforms are prohibited from selling toys in India unless the products comply with BIS standards and bear the ISI certification mark.

Toy QCOs became compulsory in India from January 1, 2021, and apply to all toys intended for children below the age of 14 years.

Source: Product manual for safety of toys, BIS

The regulation covers:

• Domestic toy manufacturers
• Foreign manufacturers exporting to India
• Importers and distributors
• Online marketplaces and retailers
• Storage, leasing, and exhibition of toys for sale

Non-compliance can result in penalties under the BIS Act, 2016, including product seizure, license suspension, fines, and criminal prosecution.

BIS certification framework for toy quality

The BIS serves as India’s national standards body and administers the certification process for toys through the ISI mark licensing system.

The certification process is intended to verify that toys meet prescribed standards relating to:

• Mechanical safety
• Physical durability
• Chemical composition
• Electrical safety
• Flammability resistance
• Structural integrity

It must be noted that products that successfully complete testing and factory audits are permitted to carry the ISI mark for sale in India.

Key BIS standards governing toy safety

India’s toy safety framework incorporates multiple Indian Standards (IS), many of which are harmonized with internationally recognized International Organization for Standardization (ISO) and International Electrotechnical Commission (IEC) safety benchmarks.

Among these, IS 9873 (Part 1):2025 forms the foundational safety benchmark for non-electric toys sold in India.

IS 9873 (Part 1):2025 — India’s primary toy safety standard

IS 9873 (Part 1):2025 establishes exhaustive physical and mechanical design criteria. This standard applies to toys under normal operating conditions, as well as under conditions of “reasonably foreseeable abuse” such as simulating rough play, heavy drops, and stress impacts.

The 2026-2027 transition framework

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Under the current guidelines issued by the BIS Central Marks Department-2 (CMD-2), IS 9873 (Part 1):2019 and the updated IS 9873 (Part 1):2025 run concurrently to minimize industrial disruption. However, manufacturers and importers must plan around strict cut-off boundaries:

1. New licenses: No new manufacturing or import licenses will be granted under the 2019 standard legacy past March 22, 2027.
2. Existing licensees: All operational factories must completely shift validation protocols to the 2025 revision by the final March 22, 2027, deadline, after which all legacy licenses automatically become invalid.

Major technical and engineering overhauls under the 2025 revision

The harmonized 2025 framework introduces critical, legally binding modifications that directly affect design and production lines:

1. Electrically driven ride-on toys: General velocity assessments have been replaced with strict, mandatory age-based maximum speed classifications:

• Children under 3 years: Speed capped at 8 km/h.
• Children aged 3 to 6 years: Speed capped at 12 km/h.
• Children above 6 years: Speed capped at 16 km/h.

2. Folding mechanisms and stability: Any toy featuring folding structures must now undergo advanced, continuous abuse testing. The integration of verified mechanical safety stops or locking devices is now an explicit requirement to prevent limb or finger entrapment.

3. Acoustic threshold upgrades: Permissible sound pressure ceilings for pull or push toys have been structurally revised from 85 dB up to 94 dB.

Mandatory testing requirements under BIS toy certification

Before receiving the authorization to affix the mandatory ISI mark, manufacturers must dispatch representative model samples to BIS-recognized or ISO/IEC 17025-accredited laboratories to clear comprehensive physical screening.

1. Small parts testing: Toys intended for children below 36 months undergo strict small parts testing to assess choking risks. Components are tested both before and after stress simulations.

2. Sharp edge and sharp point testing: Products are evaluated using calibrated testing instruments to ensure exposed surfaces do not cause cuts or puncture injuries.

3. Mechanical and durability testing: Toys are subjected to drop tests, torque tests, pull-force tests, compression tests, and impact simulations to assess structural stability under rough handling conditions.

4. Cords and straps evaluation: String lengths, loops, and flexible attachments are examined to reduce strangulation risks, particularly for infant and toddler products.

5. Chemical, electrical, and flammability compliance: Beyond physical safety, manufacturers must also comply with supporting standards governing toxic substances, electrical systems, and material flammability.

6. Chemical safety requirements: Testing includes limits on heavy metals and hazardous substances such as lead, cadmium, mercury, arsenic, and phthalates.

7. Electrical safety standards: Electric toys must comply with IS 15644:2006, which regulates insulation, heating, wiring integrity, and mechanical durability for battery-operated or powered toys.

8. Flammability testing: Materials used in toys are assessed under IS 9873 (Part 2) to minimize fire-related hazards.

ISI marking and labeling obligations

Every certified toy sold in India must prominently display the ISI mark along with specific product identification details.

Some of the mandatory labeling requirements include the following:

• Manufacturer’s name and address
• Brand or trademark
• Product model or type
• BIS CM/L license number
• ISI certification mark

The marking must remain visible, durable, and legible on either the toy itself or its primary packaging.

BIS certification process for toy manufacturers

Toy manufacturers seeking BIS approval under Scheme-I certification must complete a multi-stage compliance process.

Step 1: Factory readiness and quality system preparation

Manufacturers must establish internal quality-control systems, testing capabilities, inspection procedures, and trained compliance personnel.

Step 2: Application submission

The applicant files product and factory details through the BIS online portal, including documentation relating to testing readiness and manufacturing processes.

Step 3: BIS factory inspection

BIS officials conduct on-site audits to verify production systems, testing infrastructure, quality management practices, and sample selection procedures.

Step 4: Laboratory testing

Samples are tested at BIS-approved laboratories against applicable standards such as IS 9873 Parts 1, 2, and 3.

Step 5: Grant of BIS license

Following successful compliance verification, BIS issues a license authorizing the manufacturer to use the ISI mark.

Step 6: Ongoing surveillance and compliance monitoring

Certified manufacturers remain subject to periodic audits, factory inspections, and market surveillance to ensure continuous compliance.

Impact of BIS regulations on India’s toy industry

The introduction of mandatory BIS certification and QCOs has altered India’s toy manufacturing landscape. Stricter quality standards have accelerated the shift from unorganized manufacturing toward organized, compliance-driven production systems.

Reduction in low-quality imports

The regulatory framework has reduced the inflow of non-compliant imported toys, particularly low-cost products lacking safety certification.

Export competitiveness

Compliance with internationally aligned standards is also helping domestic manufacturers strengthen export capabilities and integrate into global supply chains.

CLICK HERE: India’s Toys Story: Riding the US$186 Million Export Wave to 153 Countries

Compliance challenges for manufacturers

While BIS certification improves market credibility, it also introduces operational and financial challenges, particularly for smaller manufacturers.

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Key concerns include the following:

• High compliance and testing costs
• Need for upgraded machinery and testing facilities
• Limited awareness among MSMEs
• Delays in certification and approvals
• Requirement for continuous surveillance compliance

For foreign manufacturers, obtaining certification through the Foreign Manufacturers Certification Scheme (FMCS) is mandatory before exporting toys to India.

Regulatory compliance as a long-term business strategy

For toy manufacturers and importers, BIS certification is a critical market-access requirement and a competitive differentiator.

As India positions itself as a global toy manufacturing hub, adherence to BIS standards and QCO requirements is expected to remain central to industry growth, consumer protection, and export expansion.

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