Footwear QCO Amendment 2026 Extends BIS Compliance Deadline to July 2027

Background: The Footwear QCO Framework

India's footwear sector is also governed by the two landmark Quality Control Orders (QCOs) notified by the Department for Promotion of Industry and Internal Trade (DPIIT) under the Bureau of Indian Standards (BIS) Act, 2016:

• Footwear Made from Leather and Other Materials (Quality Control) Order, 2024- Covering 12 footwear product categories, including leather shoes, leather boots, school shoes, safety footwear, and sandals made of leather and composite materials.
• Footwear Made from All Rubber and All Polymeric Material and Its Components (Quality Control) Order, 2024 - Covering 8 footwear product categories and 4 categories of outsoles, including rubber Hawaii chappals, rubber slippers, PVC sandals, EVA/TPR/PU sandals, and polymeric outsoles.

On August 1, 2024, both QCOs took effect, requiring all importers and manufacturers to obtain BIS certification (ISI Mark) to sell covered footwear in India.

From formal leather shoes and sports footwear to mass-market rubber chappals and PVC sandals, the listed categories collectively account for the vast bulk of footwear marketed in India. The QCO framework applies to: 

• Domestic manufacturers (must obtain a BIS licence under Scheme I)
• Importers (must obtain BIS Foreign Manufacturer Certification Scheme / FMCS certificate)
• Traders and distributors (bear downstream liability for selling uncertified stock)

What the 2026 Amendment Says and What Changed?

The June 2026 amendment to both footwear QCOs introduced two significant changes:

1. Extension of old stock clearance deadline from 31 July 2026 to 31 July 2027: The original stock clearance provision (introduced by S.O. 3700(E) dated 30 August 2024) allowed manufacturers and importers who had declared old uncertified stock to BIS under Section 18(4) of the BIS Act to sell that stock until 31 July 2026. The 2026 amendment extends this deadline by one full year to 31 July 2027.

2. Special exemption for R&D imports: A new rule from the Ministry of Commerce and Industry permits importers to import shoes without BIS certification only for R&D purposes, subject to:

• Limitations on quantity (just as much as required for R&D)
• Declarations of end use filed with customs and BIS
• No commercial R&D import sales 

Key Dates and Implementation Timeline

Why the Deadline Was Extended: The Core Reasons

The extension of the Footwear Quality Control Order (QCO) compliance deadline was driven by a combination of industry, operational, and regulatory factors. Below are a few key reasons that influenced the government's decision to provide the additional time for compliance:

1. Scale and Complexity of India's Footwear Industry

The breadth and diversity of India's footwear industry are among the main causes of the extension. In addition to a huge network of MSMEs, cottage industries, and unofficial producers dispersed around significant footwear clusters, the sector is made up of thousands of organized manufacturers. It was quite difficult to certify so many units in the initial time frame since BIS certification under Scheme-I required factory inspections, product testing, paperwork review, and license approval. The extension gives BIS and manufacturers more time to successfully finish the certification procedure. 

2. Existing Inventory Across the Supply Chain

At the time the Quality Control Order (QCO) came into force, manufacturers, importers, wholesalers, and retailers were holding substantial inventories of footwear that had been legally produced or imported before the implementation date. Requiring immediate compliance could have resulted in large-scale inventory losses, supply chain disruptions, and shortages of affordable footwear products. The extension allows the businesses to liquidate existing stock while transitioning to BIS-certified products gradually.

3. MSME and Informal Sector Readiness Challenges

Small and medium-sized businesses make up a sizable section of India's footwear manufacturing sector, and they frequently have inadequate infrastructure for regulatory compliance and quality control. To comprehend the BIS standards, modernize production procedures, carry out product testing, and receive certification, many firms need more time. The expansion acknowledges these real-world difficulties and facilitates a more seamless shift to compliance without unduly burdening smaller companies financially.

4. Testing and Certification Capacity Constraints

Another major obstacle has been the availability of testing facilities recognized by BIS. Due to several quality control programs across industries, testing facilities have seen a rise in demand, which has caused manufacturers seeking certification to have to wait longer. For shoe makers nationwide, the extended schedule offers a chance to increase testing capacity, eliminate bottlenecks, and enhance access to certification services. 

5. Industry Feedback and Stakeholder Consultations

The government's participatory approach to implementing the regulations is reflected in the extension. Concerns about certification schedules, inventory control, compliance expenses, and infrastructure constraints were brought up by trade associations and industry associations. The government chose a more realistic implementation schedule that strikes a balance between quality goals and industrial readiness after taking these arguments into account.

6. Encouraging Research, Development, and Innovation

The amendment also includes concerns about research and development efforts in the footwear industry. To create cutting-edge products, manufacturers are depending more and more on imported prototypes, sample materials, and new technology. For such limited-quantity R&D imports, requiring BIS certification resulted in needless compliance obstacles. It is anticipated that the implementation of an exemption for legitimate R&D will promote innovation, quicken product development, and encourage the use of cutting-edge materials and manufacturing techniques. 

Impact on Businesses in India in 2026

The extension of the compliance deadline and the introduction of the R&D exemption will have varying implications across the footwear value chain. While the amendment provides operational relief to businesses holding existing inventory, it also reinforces the need for long-term compliance with BIS certification requirements.

1. Domestic Footwear Manufacturers

The longer time frame for stock clearance will be very advantageous to domestic producers. Companies can sell their uncertified inventory until July 31, 2027, if they reported it to BIS before August 1, 2024. This will help businesses better manage their inventory and prevent financial losses from forced liquidation.

The certification requirements for new production are not, however, lessened by the extension. Before being sold in the Indian market, every footwear produced after August 1, 2024, must continue to adhere to the relevant BIS requirements and have the ISI mark. As a result, manufacturers should keep working toward BIS certification and bolster their quality control procedures. The extra time gives MSMEs the chance to modernize facilities, enhance quality control procedures, and finish the certification process with assistance from government and industry initiatives.

2. Footwear Importers

The longer time frame for selling current stock will help importers with declared pre-August 2024 inventory, lowering the risk of inventory losses and related business difficulties. However, the modification does not change the compliance requirements for new imports, which still need to adhere to the relevant BIS certification standards.

The R&D exemption, which allows the import of product samples, prototype footwear, material swatches, and restricted test quantities for research, development, and product assessment reasons without incurring complete certification requirements, is a significant advantage for importers. It is anticipated that this will encourage product development and innovation throughout the industry. 

3. Retailers and Distributors

Distributors, wholesalers, and retailers with reported inventory have more time to liquidate their current stock without worrying about legal or regulatory ramifications. The expansion offers more freedom in inventory management and assists companies in avoiding aggressive pricing tactics that may have a detrimental impact on profitability.

Also, distribution networks and organized retail chains can now match their transition plans with the updated schedule, guaranteeing a more seamless transition to fully BIS-certified product portfolios while coordinating the certification milestones with their supplier base. 

4. Footwear Exporters

For footwear exporters, the amendment reduces compliance pressures associated with managing both domestic and export-oriented production lines. Manufacturers serving multiple markets can benefit from additional flexibility in inventory management while continuing to align domestic products with BIS requirements.

The R&D exemption is particularly beneficial for exporters developing new products and materials, as it allows access to imported samples and technologies without creating unnecessary certification hurdles during the product development phase.

5. E-Commerce Marketplaces

Online marketplaces are essential for guaranteeing adherence to the Footwear QCO. The extended deadline gives the platforms more time to enhance compliance monitoring systems, fortify seller verification procedures, and enable a seamless transition to BIS-certified footwear listings.

Additionally, the amendment lowers the possibility of enforcement proceedings pertaining to declared heritage stock. In accordance with the updated regulatory timeframe, it allows marketplaces to update seller onboarding, product verification, and compliance frameworks. 

How Businesses Will Achieve Compliance Within the Extended Timeline

For Manufacturers

Phase 1 (Now- December 2026): Certification Priority

1. Apply for BIS Licence immediately under Scheme I- Submit application on BIS online portal (manakaonline.bis.gov.in) which includes Factory layout and quality control plan, Product samples for initial testing, Quality management documentation and Manufacturing process flow charts.
2. Engage a BIS-designated testing lab- Select labs notified by BIS for the specific product category (rubber, leather, polymeric) and submit product samples for testing against relevant IS standards:
   • IS 5557 (Leather shoes)
   • IS 10702 (Rubber Hawaii chappals)
   • IS 11544 (Rubber slippers)
   • IS 6721 (Sandals and slippers)
   • IS 15298 (Safety footwear)
3. Factory Assessment- Prepare for BIS factory inspection covering:
   • Raw material quality controls
   • In-process testing equipment
   • Finished product testing capability
   • Record-keeping and traceability systems
4. Address Non-conformities- Implement corrections for any gaps identified in testing or factory assessment.
5. Receive Licence and Begin Marking
   • Use the ISI mark correctly as per the BIS marking requirements.
   • Maintain the licence through periodic renewal and surveillance testing.

Phase 2 (January- July 2027): Old Stock Liquidation

• Systematically clear all declared old stock
• Maintain separate SKU tracking for certified vs declared old stock
• Ensure sales teams and dealers understand the stock categories and their respective deadlines

For Importers

1. Apply for BIS FMCS (Scheme II) certification- FMCS requires:
   • Foreign manufacturer's factory assessment (either in-country by BIS or through BIS-designated foreign labs)
   • Product testing at BIS-designated labs
   • Appointment of an Authorised Indian Representative (AIR)
2. Designate and brief Authorised Indian Representative (AIR)
   • AIR handles ongoing compliance, labelling, and BIS correspondence from India
   • AIR bears legal responsibility for compliance in India
3. Manage declared old stock within the July 2027 deadline
   • Track declared stock quantities separately
   • Ensure they are fully liquidated before 31 July 2027
4. R&D imports:
   • Document the R&D purpose clearly
   • Prepare end-use declarations for customs and BIS
   • Keep quantities within what is genuinely needed for R&D

Benefits for Businesses After the Extension

• Immediate and Tangible Benefits

• Medium-Term Benefits (FY2027)

Is This the Right Decision or an Unnecessary Extension?

• Why It Is a Necessary and Well-Calibrated Extension

• Where This Could Be Seen as Unnecessary

Balanced verdict: The extension is a correct and pragmatic decision given the ground realities of India's footwear sector. However, it must be the last extension; further deferrals would permanently undermine the QCO's quality assurance objective and unfairly penalise the many manufacturers who have invested in BIS certification on schedule.

How the Extension Improves Quality, Consumer Satisfaction, Environment, and Ethical Practices

1. Quality Improvements Over Extended Timeline

• Genuine Quality Upgrades Take Time- Manufacturers who now have until July 2027 can:
  • Invest in proper testing equipment (durability testers, flex testers, material strength Train QC staff on IS standard requirements Build testing)
  • Sustainable quality systems rather than just chasing a paper certificate
• Higher-Quality New Production Immediately- All footwear manufactured after August 2024 must already be BIS-certified the extension only applies to old stock. This means the market is already seeing a quality improvement in new production.
• Reduction in Substandard Imports- Foreign manufacturers must obtain FMCS certification, which involves factory assessment and product testing in India. This is already eliminating the worst-quality imports.

2. Consumer Satisfaction

• Traceability- ISI-marked footwear has a licence number traceable to the specific manufacturer and product standard, giving consumers recourse in case of quality failure.
• Durability Standard- Relevant IS standards for footwear specify requirements for:
  • Bond strength (sole attachment)
  • Abrasion resistance
  • Flex durability
  • Dimensional accuracy

This means ISI-marked footwear is tested to perform - not just labelled.

• Safety Footwear- Safety footwear (IS 15298) meeting BIS standards protects workers from:
  • Crush injuries (steel toe cap performance)
  • Penetration (anti-puncture midsole)
  • Chemical and electrical hazards (insulation properties)

The QCO ensures these life-critical products actually meet specified protections.

• School Shoes and Children's Footwear- IS 10348 (school shoes) specifies requirements for:
  • Breathability
  • Flex resistance
  • Heel height limits are appropriate for growing feet
  • Mandatory BIS certification for school shoes directly protects children's health.

3. Environmental Improvements

• Material Quality Standards- BIS standards specify that materials used in footwear must meet minimum quality benchmarks indirectly:
  • Reducing use of sub-grade, poorly stabilised PVC (which degrades rapidly and increases plastic waste)
  • Encouraging use of properly compounded rubber (which has better recyclability and longer life)
• Product Longevity Reduced Waste- Footwear that meets durability standards lasts longer, directly reducing:
  • The volume of footwear waste generated annually.
  • The rate of fast-fashion footwear disposal
• Reduction in Illegal Imports- The QCO, once fully enforced, will:
  • Eliminate the entry of poorly manufactured footwear that bypasses environmental controls (e.g., use of heavy metals in dyes, poorly treated leather, toxic adhesives)
  • Ensure that imported footwear meets the same material safety standards as domestic production.

4. Ethical Practices in the Industry

• Level Playing Field- Once fully enforced, no manufacturer can undercut ethical, quality-conscious players by using inferior materials and skipping testing costs
• Worker Safety Improvement- The quality standards for safety footwear protect industrial workers, reducing occupational injuries from inadequate footwear.
• MSMEs Enter Formal Economy- BIS certification pushes informal manufacturers to:
  • Register formally
  • Maintain proper records
  • Pay applicable taxes and dues.

This improves their access to formal credit, government schemes, and export opportunities.

Business Opportunities Created by the QCO and the Extension

1. BIS Certification Services (Highest Priority for Corpseed)- The extended timeline creates a well-defined, time-bound compliance window:

2. Lab Testing Coordination and Sample Management

• For footwear certification, product testing is a mandatory, recurring bottleneck
• Corpseed can also act as a coordination layer:
  • Identifying appropriate BIS-designated labs for each product category.
  • Managing sample logistics
  • Ensuring correct sample quantities and formats are submitted
  • Tracking the test reports and timelines

3. Quality Management and Factory Preparation Services

• Many MSME footwear manufacturers also need:
  • Factory readiness audits before the BIS inspection.
  • Process documentation (quality plan, testing SOPs, batch records).
  • Minor facility upgrades (dedicated testing area, properly calibrated equipment)
• Corpseed can bundle this with the certification application as a "Factory Readiness + BIS Certification Pack"

4. E-Commerce Seller Compliance Packages

• Online footwear sellers on Amazon, Flipkart, and Meesho:
  • Need to verify and upload the BIS certification for all the listed products.
  • Risk account suspension or legal action for selling uncertified products after the stock clearance deadline.
• Package:
  • Verify existing product certifications
  • Apply for BIS for uncertified SKUs
  • Maintain a certification tracker for their catalogue

5. Footwear Brand Consulting and Market Entry

• International footwear brands looking to:
  • Sell directly in India (FMCS route)
  • Set up Indian manufacturing (Scheme I route)
  • Source from Indian manufacturers (verification of supplier certification)
• Full market entry compliance advisory, including:
  • BIS FMCS
  • Trademark registration
  • GST and import compliance
  • Retail trade licensing

Corpseed's Priority Action for Footwear QCO

Given the July 2027 final deadline, the next 12 months represent the peak conversion window for BIS footwear certification services. The urgency is real, but manageable every MSME manufacturer and importer still operating without BIS certification on their new production is in technical violation today and needs help. The right message for Corpseed is:

"The government has given you until July 2027 for old stock, but your new production already needs BIS certification. Don't wait. Start now, complete before the rush."