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Private Label and White Label Brands on Marketplaces: Whose Name Goes on the BIS Licence?

A BIS licence or CRS registration is granted to the factory, not the brand. How private label sellers get their brand covered, and which approvals (EPR, LMPC, FSSAI, WPC) sit with the brand owner.

A BIS licence belongs to the factory, not to the brand. Under both the ISI scheme and the Compulsory Registration Scheme (CRS), BIS grants the licence or registration to the manufacturer for a specific factory, and records the brands that factory may put the Standard Mark on. A private label seller on Amazon, Flipkart or Meesho does not get “its own” BIS certificate. It gets its brand added to each contract manufacturer’s licence, and it carries the approvals that the law puts on brand owners: usually EPR, and sometimes Legal Metrology and FSSAI.

How BIS treats brands

ISI licence (Scheme-I)CRS registration (Scheme-II)
Granted toThe manufacturing unitThe manufacturer, for a specific factory
BrandBrands are part of the licence scope; new brands need an inclusion requestThe brand is recorded against the registration; each factory–brand combination must be covered
Brand documentsTrademark registration or brand authorisationTrademark or brand authorisation where the brand owner is not the manufacturer
Shown on public recordsLicensee, factory address, IS number, scopeManufacturer, product, IS number, validity, scope and brand on crsbis.in

So when a buyer or a marketplace looks up the CM/L or R-number printed on your product, the record shows your contract manufacturer’s name and factory, with your brand in the scope. That is normal. What matters is that your brand and the model are in the scope and the licence is valid. See how to check a CM/L number and how to check a BIS R-number.

Getting your brand onto a manufacturer’s licence

  1. Confirm the product is notified and which scheme applies: ISI, CRS or none. See does my product need BIS?
  2. Check the manufacturer’s licence is valid for the product and the Indian Standard.
  3. Give the manufacturer brand documents: your trademark certificate or application, and an authorisation letter for the product and brand.
  4. The manufacturer files the request with BIS: a brand inclusion on Manak Online for an ISI licence, or on crsbis.in for CRS. CRS inclusions may need a fresh test report for new models; an ISI inclusion may need samples tested.
  5. Wait for BIS approval before your branded goods are marked and sold.
  6. Repeat for each factory. A second source needs its own licence covering your brand.

Risks that catch private label sellers

  • Switching factories. A cheaper factory without a licence, or without your brand in its scope, makes your stock unsellable.
  • New models. A CRS registration lists models. A new model needs an inclusion, not just a new box.
  • Expired or suspended licences. The manufacturer’s licence can lapse between orders. Check it every time.
  • Label mismatch. The brand, model, IS number and licence number on the product must match BIS’s record.
  • Importing your own brand. If an overseas factory makes your brand, the factory registers with BIS through an Authorised Indian Representative, which can be you. See BIS for foreign manufacturers.

What stays with the brand owner

BIS sits with the factory, but other laws put duties on the brand owner directly:

LawBrand owner’s role
E-waste EPRA producer includes anyone who sells, under its own brand, equipment assembled or produced by others
Battery EPRA producer includes anyone who sells batteries, or equipment with batteries, under its own brand
Plastic packaging EPRBrand owners are obligated for their packaging, unless they are micro or small enterprises
Legal Metrology (LMPC)The packer or importer registers under Rule 27, and the package must declare the maker, packer or importer
FSSAIUnder Regulation 5(7) of the Labelling and Display Regulations, 2020, the brand owner’s FSSAI logo and licence number must be on the pack, with the manufacturer’s or packer’s if different
WPC ETAThe importer or manufacturer of radio products applies; a brand importing its own products takes it

Checklist for a private label seller

  1. List every product and its factory.
  2. For each notified product, get the CM/L or R-number, and check that your brand and model are in the scope.
  3. Keep your trademark and authorisation letters with each manufacturer’s licence copy.
  4. Register as producer for e-waste, battery and plastic EPR where you are the brand owner.
  5. Make sure the label carries the Legal Metrology declarations, and FSSAI details for food.
  6. Recheck licences before each purchase order.

How Aaditech can help

Aaditech adds brands and models to ISI licences and CRS registrations, licenses new factories, and acts as Authorised Indian Representative for overseas factories making Indian brands. We also handle EPR, LMPC and WPC filings for brand owners. Our team includes former BIS officers. See our BIS CRS registration and ISI mark certification services, or our guide to selling regulated products online.

Frequently asked questions

Can a brand owner get a BIS licence in its own name?

Only if it owns the factory. Both ISI licences and CRS registrations are granted to the manufacturer for a specific factory. A brand that outsources production gets its brand added to the contract manufacturer's licence or registration, with its trademark or brand authorisation.

Is one BIS registration enough if I use two factories?

No. Each factory needs its own licence or registration with your brand included. If you move production to a new factory, the new factory must be licensed for your brand before its goods are sold.

What documents does a brand owner need to give the manufacturer?

Usually the trademark registration certificate or application, and an authorisation letter allowing the manufacturer to use the brand on the certified product. BIS checks the brand documents when the brand is added.

Who is the producer for EPR, the brand owner or the factory?

Under the E-Waste (Management) Rules, 2022, anyone who sells equipment under its own brand that was made by others is a producer. Under the plastic packaging EPR guidelines, the brand owner carries the obligation for its packaging unless it is a micro or small enterprise. So the brand owner usually registers.

If my contract manufacturer loses its licence, can I keep selling?

No. Goods made after the licence is suspended or cancelled, or outside its validity, cannot carry the Standard Mark. Ask for the licence status before every production order and check it on Manak Online or crsbis.in.

This article is general guidance based on official sources at the time of writing. Regulations, fees and timelines change. Check the latest notification or speak to our team before acting.

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