A steel importer in Mumbai placed an order with a Japanese mill for hot-rolled plates meeting IS 2062 E350 equivalent — carbon equivalent, yield strength, UTS, and elongation all within IS 2062 limits. The mill provided a comprehensive MTC with full chemistry and mechanical data. The importer was confident the material would clear customs without issue.
At JNPT, the customs clearing agent flagged a problem. The plates were covered under India's Quality Control Order for steel products. IS 2062-equivalent wasn't enough. The material needed BIS certification — specifically, the Foreign Manufacturer Certification Scheme (FMCS) certificate from BIS. The Japanese mill did not hold one. The consignment sat at the port for three weeks while the importer applied for an exemption, paid demurrage, and eventually had to arrange for BIS-recognized third-party sampling and testing as an alternative clearance path.
The cost of the delay exceeded the freight savings that had made the import attractive in the first place.
India's Quality Control Orders for Steel
The Indian government has issued Quality Control Orders (QCOs) under the BIS Act and the Foreign Trade Policy that make BIS certification mandatory for a wide range of steel products — including imports. The Steel QCO, administered through the Ministry of Steel and the Department for Promotion of Industry and Internal Trade (DPIIT), identifies specific IS standards where certification is mandatory.
Covered products include, among others:
- Hot-rolled and cold-rolled flat products under IS 2062
- Structural sections under IS 808
- Pipes and tubes under IS 1161 and IS 3589
- TMT bars under IS 1786
For these product categories, an imported consignment must either:
- Come from a foreign manufacturer that holds FMCS certification from BIS, or
- Meet alternative compliance pathways specified in the QCO (which in some cases permit third-party testing and certification by BIS-recognized agencies at the port of entry — a more expensive and slower route)
"Meets IS 2062 specifications" is not the same as "holds BIS certification." The distinction is legal, not just technical.
What the Foreign Manufacturer Certification Scheme Is
FMCS is BIS's certification mechanism for foreign manufacturers who want to export products to India that fall under mandatory BIS certification categories. Under FMCS:
- The foreign manufacturer applies to BIS for product certification under the applicable IS standard
- BIS assesses the manufacturer's production facility and quality system (often through an overseas BIS officer visit or through a BIS-recognized agency)
- Product samples are tested at BIS-recognized laboratories
- If approved, the manufacturer is issued a BIS licence and a CM/L number, authorizing them to affix the ISI mark to products exported to India
The CM/L number for an FMCS-certified foreign manufacturer looks the same as a domestic BIS licence number. It is searchable on the BIS portal. The MTC from an FMCS-certified mill must carry this CM/L number.
FMCS certification is specific to a product category and standard. A Japanese mill certified under FMCS for IS 2062 E250 plates is not automatically certified for IS 2062 E350 or for IS 808 sections. The importer needs to verify that the mill's FMCS scope covers the specific product and grade being imported.
What the MTC Must Show for BIS-Compliant Imports
An MTC from a foreign manufacturer that satisfies India's BIS compliance requirements must include:
- FMCS certificate number (the CM/L number issued by BIS to the foreign manufacturer)
- BIS licence validity period — confirming the licence was active when the material was produced
- ISI mark — either marked on the material or confirmed in the MTC documentation
- Grade and product form within the certified scope
- Heat-specific chemistry and mechanical properties conforming to the IS standard
- Test report reference from a laboratory that BIS accepts for the FMCS certification — this may be a lab in the country of manufacture that BIS has approved
The MTC structure follows the same requirements as for domestic BIS-certified mills. The key differentiator is the FMCS certificate number in place of, or in addition to, the domestic CM/L number.
Common Customs Scenarios
Scenario 1: Mill holds FMCS, MTC incomplete. The consignment can be cleared, but customs may place a hold until a corrected or supplementary MTC is provided. Delay: days to a week.
Scenario 2: Mill does not hold FMCS, product is QCO-covered. The importer must apply for a BIS exemption, arrange for port-based sampling, or seek testing through a BIS-recognized TPI agency. Outcome varies. Demurrage accumulates. In some cases, re-export is the only viable option.
Scenario 3: Product not covered by QCO. Standard import documentation sufficient. MTC showing conformance to equivalent specifications accepted. This is increasingly narrow as the QCO list has expanded.
Scenario 4: FMCS certificate expired at time of shipment. Similar to an expired domestic BIS licence — material cannot be cleared as BIS-certified. The importer is exposed.
How to Build FMCS Verification into Import Procurement
Before placing an import order for steel products covered by the QCO:
- Confirm whether the specific product (grade, form, IS standard) is covered by India's Steel QCO
- Confirm that the foreign supplier holds FMCS certification for that specific product category
- Request the FMCS certificate from the supplier and verify it on the BIS portal
- Confirm FMCS validity extends past the expected arrival date
- Include in the purchase order: a requirement that the MTC carry the FMCS certificate number and that the ISI mark be applied to the product
For mills that don't hold FMCS certification, work with a customs clearing agent to understand the alternative compliance pathway before placing the order — not after the consignment arrives.