Role and Responsibilities of the AIR in BIS FMCS Certification

Role and Responsibilities of the AIR in BIS FMCS Certification. The Foreign Manufacturers Certification Scheme (FMCS) is administered by the Bureau of Indian Standards (BIS), India’s national standards body. It enables foreign manufacturers to obtain the ISI Mark certification for products exported to India, affirming that those products conform to Indian Standards. To bridge geographical, regulatory, and operational gaps, BIS mandates the appointment of an Authorized Indian Representative (AIR) by the foreign applicant.
Who is an Authorized Indian Representative (AIR)?
An Authorized Indian Representative (AIR) is a resident Indian entity or individual who acts as the official liaison between a foreign manufacturer and the BIS. The AIR is not merely a communication channel—it assumes significant responsibilities on behalf of the manufacturer, including legal and regulatory accountability in India.
This requirement is grounded in the BIS Act, 2016 and FMCS guidelines, and serves to ensure enforceability of Indian regulatory provisions in case of non-compliance by the overseas applicant.
Eligibility Criteria for becoming an AIR (Authorized Indian Representative)
To be appointed as an AIR (Authorized Indian Representative) under FMCS:

The individual or entity must be legally established in India.

They must have a registered office or physical address in India.

They must submit a written undertaking assuming responsibility for compliance, including enforcement actions and penalties if necessary.

In many cases, importers, Indian subsidiaries, or third-party compliance service providers act as AIRs.
Key Roles and Responsibilities of the AIR (Authorized Indian Representative) under FMCS Scheme

Legal Accountability in India- The AIR is legally accountable for ensuring that the certified products continue to comply with Indian Standards and BIS regulations. In case of non-compliance or enforcement action, the AIR represents the foreign manufacturer before Indian authorities.

Liaison with BIS- The AIR facilitates communication between BIS and the foreign manufacturer. This includes responding to queries, submitting documentation, and arranging factory inspections when required.

Application Submission and Documentation- The AIR is responsible for compiling and submitting the application for certification, along with required technical documentation, test reports, declarations, and other compliance documents.

Coordination for Factory Audit- BIS typically mandates an on-site inspection of the foreign manufacturing facility. The AIR coordinates between BIS officials and the foreign entity to arrange the audit.

Labeling and Marking Compliance- The AIR must ensure that the product and packaging bear the correct ISI mark and labeling as prescribed under the applicable Indian Standard.

Fee Payment and Financial Liabilities- The AIR often handles the payment of BIS application fees, renewal fees, and any penalties or charges. They may also be financially liable in case of certain compliance failures.

Renewal and Surveillance Coordination- Certifications under FMCS are valid for a limited period and require periodic renewal. The AIR ensures timely submissions and ongoing compliance for re-certification and surveillance audits.

Product Recall and Consumer Grievance Redressal- In cases where a product recall is mandated, or if consumers lodge complaints, the AIR coordinates the recall or resolution process in India on behalf of the manufacturer.

Conclusion
The Authorized Indian Representative is not just a procedural requirement under the BIS FMCS—it is an important role that carries both operational responsibility and legal liability. For foreign manufacturers, understanding and leveraging this role effectively can streamline entry into the Indian market and ensure sustained regulatory compliance.
If you need any support in BIS FMCS Certification then you can book a consultation with the experts through email info@ccoffice.in or Call/Whatsapp at +91 9988424211.
FAQs
Q1. What is the role of an Authorized Indian Representative (AIR) under the BIS FMCS?
Ans. The Authorized Indian Representative (AIR) acts as the official liaison and assumes significant responsibilities on behalf of a foreign manufacturer seeking BIS certification for their products in India. This includes legal and regulatory accountability, facilitating communication with BIS, handling application submissions and documentation, coordinating factory audits, ensuring labeling compliance, managing fee payments, coordinating renewals and surveillance, and overseeing product recalls and consumer grievance redressal in India.  
Q2. Who can be appointed as an Authorized Indian Representative (AIR)?
Ans. An AIR must be a resident Indian entity or individual legally established in India with a registered office or physical address. They are required to submit a written undertaking assuming responsibility for compliance with BIS regulations, including potential enforcement actions and penalties. Importers, Indian subsidiaries, or third-party compliance service providers often serve as AIRs.  
Q3. Why is it mandatory for foreign manufacturers to appoint an AIR under the BIS FMCS?
Ans. The requirement for an AIR is mandated by the BIS Act, 2016, and FMCS guidelines to bridge geographical, regulatory, and operational gaps between foreign manufacturers and the Indian regulatory framework. It ensures the enforceability of Indian regulatory provisions in case of non-compliance by the overseas applicant and provides a local point of contact for BIS.  
Q4. What are some key responsibilities of the AIR concerning BIS certification?
Ans. Key responsibilities include being legally accountable for ongoing product compliance, acting as the primary point of contact with BIS for all communications, managing the application process and necessary documentation, coordinating BIS factory audits, ensuring correct ISI marking and labeling, handling financial aspects like fee payments, and managing the renewal and surveillance processes.
Q5. What should foreign manufacturers consider when choosing an AIR?
Ans. Foreign manufacturers should carefully choose an AIR with experience in Indian compliance and regulatory processes due to the legal and regulatory responsibilities associated with the role. It is also crucial to establish a detailed contract outlining roles, responsibilities, indemnity clauses, and limits of authority to ensure a clear and effective working relationship.

The Foreign Manufacturers Certification Scheme (FMCS) is administered by the Bureau of Indian Standards (BIS), India’s national standards body. It enables foreign manufacturers to obtain the ISI Mark certification for products exported to India, affirming that those products conform to Indian Standards. To bridge geographical, regulatory, and operational gaps, BIS mandates the appointment of an Authorized Indian Representative (AIR) by the foreign applicant.

Who is an Authorized Indian Representative (AIR)?

An Authorized Indian Representative (AIR) is a resident Indian entity or individual who acts as the official liaison between a foreign manufacturer and the BIS. The AIR is not merely a communication channel—it assumes significant responsibilities on behalf of the manufacturer, including legal and regulatory accountability in India.

This requirement is grounded in the BIS Act, 2016 and FMCS guidelines, and serves to ensure enforceability of Indian regulatory provisions in case of non-compliance by the overseas applicant.

Eligibility Criteria for becoming an AIR (Authorized Indian Representative)

To be appointed as an AIR (Authorized Indian Representative) under FMCS:

The individual or entity must be legally established in India.
They must have a registered office or physical address in India.
They must submit a written undertaking assuming responsibility for compliance, including enforcement actions and penalties if necessary.

In many cases, importers, Indian subsidiaries, or third-party compliance service providers act as AIRs.

Key Roles and Responsibilities of the AIR (Authorized Indian Representative) under FMCS Scheme

Legal Accountability in India- The AIR is legally accountable for ensuring that the certified products continue to comply with Indian Standards and BIS regulations. In case of non-compliance or enforcement action, the AIR represents the foreign manufacturer before Indian authorities.
Liaison with BIS- The AIR facilitates communication between BIS and the foreign manufacturer. This includes responding to queries, submitting documentation, and arranging factory inspections when required.
Application Submission and Documentation- The AIR is responsible for compiling and submitting the application for certification, along with required technical documentation, test reports, declarations, and other compliance documents.
Coordination for Factory Audit- BIS typically mandates an on-site inspection of the foreign manufacturing facility. The AIR coordinates between BIS officials and the foreign entity to arrange the audit.
Labeling and Marking Compliance- The AIR must ensure that the product and packaging bear the correct ISI mark and labeling as prescribed under the applicable Indian Standard.
Fee Payment and Financial Liabilities- The AIR often handles the payment of BIS application fees, renewal fees, and any penalties or charges. They may also be financially liable in case of certain compliance failures.
Renewal and Surveillance Coordination- Certifications under FMCS are valid for a limited period and require periodic renewal. The AIR ensures timely submissions and ongoing compliance for re-certification and surveillance audits.
Product Recall and Consumer Grievance Redressal- In cases where a product recall is mandated, or if consumers lodge complaints, the AIR coordinates the recall or resolution process in India on behalf of the manufacturer.

Conclusion

The Authorized Indian Representative is not just a procedural requirement under the BIS FMCS—it is an important role that carries both operational responsibility and legal liability. For foreign manufacturers, understanding and leveraging this role effectively can streamline entry into the Indian market and ensure sustained regulatory compliance.

If you need any support in BIS FMCS Certification then you can book a consultation with the experts through email info@ccoffice.in or Call/Whatsapp at +91 9988424211.

FAQs

Q1. What is the role of an Authorized Indian Representative (AIR) under the BIS FMCS?

Ans. The Authorized Indian Representative (AIR) acts as the official liaison and assumes significant responsibilities on behalf of a foreign manufacturer seeking BIS certification for their products in India. This includes legal and regulatory accountability, facilitating communication with BIS, handling application submissions and documentation, coordinating factory audits, ensuring labeling compliance, managing fee payments, coordinating renewals and surveillance, and overseeing product recalls and consumer grievance redressal in India.

Q2. Who can be appointed as an Authorized Indian Representative (AIR)?

Ans. An AIR must be a resident Indian entity or individual legally established in India with a registered office or physical address. They are required to submit a written undertaking assuming responsibility for compliance with BIS regulations, including potential enforcement actions and penalties. Importers, Indian subsidiaries, or third-party compliance service providers often serve as AIRs.

Q3. Why is it mandatory for foreign manufacturers to appoint an AIR under the BIS FMCS?

Ans. The requirement for an AIR is mandated by the BIS Act, 2016, and FMCS guidelines to bridge geographical, regulatory, and operational gaps between foreign manufacturers and the Indian regulatory framework. It ensures the enforceability of Indian regulatory provisions in case of non-compliance by the overseas applicant and provides a local point of contact for BIS.

Q4. What are some key responsibilities of the AIR concerning BIS certification?

Ans. Key responsibilities include being legally accountable for ongoing product compliance, acting as the primary point of contact with BIS for all communications, managing the application process and necessary documentation, coordinating BIS factory audits, ensuring correct ISI marking and labeling, handling financial aspects like fee payments, and managing the renewal and surveillance processes.

Q5. What should foreign manufacturers consider when choosing an AIR?

Ans. Foreign manufacturers should carefully choose an AIR with experience in Indian compliance and regulatory processes due to the legal and regulatory responsibilities associated with the role. It is also crucial to establish a detailed contract outlining roles, responsibilities, indemnity clauses, and limits of authority to ensure a clear and effective working relationship.