India: Standalone Hard Disk Drives Need BIS Registration

India MeitY Brings Standalone Hard Disk Drives Under BIS Compulsory Registration (CRS)

India has closed a long-standing definitional gap in its product-safety regime. On 5 May 2026, the Ministry of Electronics and Information Technology (MeitY) published Gazette notification S.O. 2204(E), amending the Electronics and Information Technology Goods (Requirements for Compulsory Registration) Order, 2021 (the "CRO") so that standalone hard disk drives are explicitly captured under the Bureau of Indian Standards (BIS) Compulsory Registration Scheme (CRS), administered under Scheme-II of the BIS conformity-assessment framework.

This is an enacted amendment, not a draft or a proposal open for comment. It is already on the legal record. What is still in the future is enforcement: the requirement for the newly clarified standalone HDD category becomes applicable on 5 November 2026, giving the supply chain a six-month transition window.

Regulatory background

The CRO 2021 is issued under the Bureau of Indian Standards Act, 2016, and mandates that specified electronics and IT goods be registered with BIS and bear a valid registration number before they can be manufactured, imported, stored for sale, sold, or distributed in India. Hard disk drives have sat within the Schedule for years, but the wording at Entry No. 50 left ambiguity about which physical form factors were captured.

The amendment resolves that ambiguity by substituting Entry No. 50 so it explicitly reads "Standalone Hard Disk Drives." MeitY's intent, echoed in subsequent customs guidance, is to bring internal and bare-drive units distinct from USB-connected external drives firmly inside the BIS CRS perimeter, and to make scope unambiguous for manufacturers, importers, and enforcement officers alike.

Downstream implementation has followed quickly. The Central Board of Indirect Taxes and Customs (CBIC) issued Instruction No. 09/2026-Customs dated 12 June 2026 directing customs field formations to apply the amended scope uniformly at the border.

Technical scope: what is (and isn't) covered

The amendment draws a clear line between two categories of drive:

• Standalone Hard Disk Drives: internal or bare-drive units not connected to a host device via USB. These are now explicitly captured under Entry No. 50 and become subject to mandatory BIS CRS registration, with the requirement applicable from 5 November 2026.

• USB-Type External Hard Disk Drives: these continue to be governed under the existing notified provisions of the CRO, with no change to their regulatory treatment. (External USB HDDs have been within BIS CRS since the earlier notified phase.)

  
  

Applicable safety standard for standalone hard disk drives BIS registration

All covered standalone HDDs must be tested and registered against IS 13252 (Part 1): 2010, titled Information Technology Equipment — Safety — Part 1: General Requirements — the Indian adoption of the international IT-equipment safety standard. Testing must be carried out at a BIS-recognised laboratory in India, followed by registration through the BIS CRS portal.

What this means for manufacturers

For manufacturers, importers, and distributors of storage products, this amendment converts a previously grey area into a hard compliance obligation with a fixed deadline. Key implications:

• Portfolio segmentation is now decisive. Each SKU must be classified as a standalone HDD or a USB-type external HDD, because the compliance pathway and timing differ. Misclassification risks either over-certifying or — more dangerously — shipping non-compliant standalone drives after the enforcement date.

• Foreign manufacturers cannot hold the registration directly. A registration must be held through an Authorised Indian Representative (AIR), who must be appointed before the application is filed.

• Lead time is real. BIS CRS registration involves document preparation, sample testing at a BIS-recognised lab, and portal submission. Industry practice points to several weeks of testing and processing, plus buffer for any clarification or resubmission — so the practical start date is well before November.

• Ongoing obligations continue after registration, including factory/market surveillance and the obligation to keep registrations current for each model.

• Border enforcement is coordinated. With CBIC having instructed uniform application, non-compliant standalone HDDs risk being held or refused clearance at Indian ports once the requirement is live.

  
  

The strategic takeaway: treat mid-2026 as the action window, not the deadline. Companies that wait until autumn to begin testing risk supply-chain disruption from November onward.

Certification impact summary

Item	Detail
Regulator	MeitY (policy) / BIS (administration)
Instrument	Gazette notification S.O. 2204(E), amending CRO 2021
Notified date	5 May 2026
Status	Enacted; enforcement pending
Enforcement date	5 November 2026
Newly covered product	Standalone Hard Disk Drives (internal / bare-drive units, non-USB)
Unchanged	USB-Type External HDDs — existing provisions continue
Applicable standard	IS 13252 (Part 1): 2010 — IT Equipment Safety, General Requirements
Scheme	BIS Compulsory Registration Scheme (CRS / Scheme-II)
Testing	Mandatory, at a BIS-recognised laboratory in India
Foreign manufacturers	Must appoint an Authorised Indian Representative (AIR)
Customs implementation	CBIC Instruction No. 09/2026-Customs, 12 June 2026

Timeline and required actions

Date / window	Milestone	Required action
5 May 2026	S.O. 2204(E) published in the Gazette	Amendment enters the legal record — note in compliance register
May–June 2026	Scope assessment	Audit the product portfolio; classify each SKU as standalone vs. USB-type external HDD
June–Aug 2026	Testing	Initiate sample testing against IS 13252 (Part 1): 2010 at a BIS-recognised lab; foreign makers confirm/appoint the AIR
Aug–Oct 2026	Application	Submit BIS CRS registration with complete documentation and test reports; allow buffer for clarifications
5 November 2026	Enforcement begins	All in-scope standalone HDDs sold or imported into India must carry a valid BIS CRS registration; non-compliant units cannot be manufactured, imported, stored for sale, or distributed

Conclusion

The substitution at Entry No. 50 is short in text but significant in effect: standalone hard disk drives now sit unambiguously inside India's mandatory certification regime, with a fixed enforcement date of 5 November 2026 and a single governing standard, IS 13252 (Part 1): 2010. The transition window is generous on paper but tight in practice once lab lead times, AIR appointment, and portal processing are factored in. Manufacturers and importers who segment their portfolios now and begin testing in the summer will reach the deadline comfortably; those who wait risk losing Indian market access at the border.