Top 10 Common Mistakes Manufacturers Make During BIS Toy Certification

10-Oct-2025

Ensuring toy safety is vital—not just for children’s health, but also for legal compliance and brand reputation. In India, the Toys (Quality Control) Order, 2020 mandates that all toys—whether manufactured domestically or imported—must comply with certain Indian Standards and carry the ISI (BIS) mark.

Since the full enforcement came into effect on January 1, 2021, manufacturers have had to step up. Recent BIS Certification data show that as of mid-2025, about 91% of approximately 17,860 toy samples tested were found to be compliant with the norms.

Despite that good compliance rate, many manufacturers still stumble during the certification process. Below are ten of the most common mistakes—and tips to avoid them.

1. Misunderstanding Which Indian Standards Apply

There are multiple parts to the toy safety standard suite: IS 9873 (various parts relating to physical/mechanical, chemical, flammability, small parts, etc.), IS 15644 (for electric toys), etc.

Mistake: Applying under the wrong IS standard (or omitting parts). This leads to delays, test failures, or rejection.

Tip: Early in the design/decision phase, determine whether the toy is electric or non-electric, the age group, parts/materials, intended usage, etc. Map each to the relevant parts of IS 9873 or IS 15644.

2. Skipping or Performing Incomplete Material & Chemical Testing

Chemical safety (heavy metals, phthalates, migration of certain elements) is a critical part of the BIS toy standards.

Mistake: Overlooking some chemical tests—for instance, failing to test for certain heavy metals, or using materials whose suppliers don’t provide full test certificates.

Tip: Work with reputable raw material suppliers, procure full test data or Certificates of Analysis. Before the prototype, ensure that samples of each material are tested in a BIS-recognised lab.

3. Inadequate Documentation

One of the biggest hurdles is having all the required documents correctly prepared. BIS demands many documents: test reports, manufacturing process flow, plant layout, machinery list, raw material details, trademark/brand evidence, etc.

Mistake: Submitting incomplete paperwork, missing declarations or failing to properly identify the factory premises or machinery. Sometimes even missing trademark registration or proof of ownership/lease of premises.

Tip: Use a checklist. Engage legal or compliance specialists. Always cross-verify the document list as per the latest BIS manual/product catalogue for toys.

4. Choosing Non-Recognised or Inappropriate Test Labs

Tests must be conducted in “BIS-recognised laboratories.” Labs outside that list, or foreign labs unless specifically accepted, may lead to non-acceptance of results.

Mistake: Using a lab that is cheaper but not BIS-recognised, or whose test report doesn’t meet format or parameter expectations.

Tip: Choose labs accredited by BIS. Before testing, ensure that the lab can test for all required parameters. Confirm the format of the report, signature, report validity, etc.

5. Poor Sample Selection / Prototype Issues

Sometimes the sample or prototype used for testing doesn’t represent the final mass-production version. Differences in paint, finishes, components, adhesives, wires, etc., can cause test failures later.

Mistake: Using an ideal or “best-case” prototype rather than the one that reflects actual production. Overlooking small component suppliers or sub-contracted parts.

Tip: Use actual production components, even for small or low-cost parts. Maintain consistency with what will be used in bulk. If multiple models or variants, ensure representative sampling.

6. Labelling, Marking & Packaging Errors

Once the toy is certified, it must carry proper labelling: age instructions, warnings, BIS licence number, ISI mark, etc. Also, packaging must reflect what was tested.

Mistake: Packaging or label designs not matching the tested version (e.g. wrong warnings, no ISI mark, age grading omitted). Even small typos or wrong model names can cause issues.

Tip: After testing, freeze packaging and labelling. Have the proofs reviewed carefully. Include all legal warnings, instructions, maker/importer info, and BIS licence number exactly as granted.

7. Underestimating Costs & Budgeting Poorly

Many manufacturers budget only for manufacturing, but don’t factor in certification-related costs: lab tests, sample transport, inspections, labelling changes, extra materials, and possible rework.

Mistake: Running out of budget midway, which causes compromises or delays.

Tip: Estimate full cost upfront. Include lab test fees, travel or shipping for samples, internal QC, packaging revisions, and follow-ups. Keep some buffer for retests or non-conformities.

8. Ignoring or Failing Periodic Surveillance & Renewal Requirements

Getting the initial license is not the end. BIS and regulatory bodies conduct market surveillance; licences must be renewed; any change in product model, component, raw materials etc. must be reported.

Mistake: Treating certification as a one-time affair, then changing materials, or introducing new models without re-certification, or missing license renewal dates.

Tip: Maintain internal tracking of validity of licence, models covered. For new variants or raw material changes, check if a fresh test or extension is needed. Stay updated with BIS notifications.

9. Poor Quality Control in Manufacturing After Certification

Even after getting BIS certification, manufacturing should maintain the same quality. If production drift (poor QC) causes defects—sharp edges, chemical residues, loose parts—products in the market may fail and lead to recalls, penalties, or loss of licence or reputation.

Mistake: Letting cost cutting, high volume, or supplier inconsistency degrade the quality vs the tested sample.

Tip: Set up regular internal quality checks. Use incoming raw material inspections. Use statistical sampling. Ensure employees are trained. Keep good records.

10. Overlooking Enforcement & Legal Risks

Manufacturers sometimes underestimate the legal implications of non-compliance. BIS has the power to seize non-certified toys, impose heavy fines, even imprisonment in serious cases. Also legal action can be taken against anyone who manufactures, sells or distributes toys not meeting the Quality Control Order.

For example, in one sweep, BIS seized over 18,600 toys across India from 25 retail outlets for lacking the BIS quality mark.

Mistake: Not taking enforcement seriously; delaying compliance; relying on hope rather than facts.

Tip: Treat compliance as mandatory. Stay in contact with legal/regulatory advisors. If uncertain, consult BIS product manual, or get third-party compliance audits. Better to invest in compliance than face seizure, fines, or even business shutdown.

Why These Mistakes Matter ?

Consumer Safety & Trust: A toy that fails can injure children physically (choking, sharp edges) or chemically (toxic materials), harming both child and brand reputation.
Legal/Financial Consequences: BIS & Indian law empower seizure, fines, and even criminal charges. Because of non-compliance, many items have already been seized from stores and e-commerce warehouses.
Market Access: Both in India and for export, compliance with safety norms is increasingly non-negotiable. BIS standards are also increasingly aligned (or exceeding) with global benchmarks, giving compliant manufacturers an edge.

Key Stats to Keep in Mind

Since January 2021, 91% of toy samples tested by BIS (i.e. 16,240 out of ~17,860) have been compliant.
Tests cover both non-electric (majority) and electric toys (smaller but growing). Out of 1,640 BIS-certified toy industries in India, 1,165 are non-electric, 475 electric.

Enforcement is active: raids, sample testing, search & seizure especially in e-commerce warehouses.

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