A BIS licence is not issued only against a company or brand name. It is associated with the specific manufacturing premises, product, applicable Indian Standard and approved manufacturing/testing arrangements.
During the BIS certification process, the manufacturing facility is evaluated to verify whether it has the required:
- Manufacturing infrastructure
- Production facilities
- Testing facilities
- Quality control arrangements
- Qualified technical personnel
- Raw material controls
- Inspection and testing procedures
Therefore, if production moves to a completely different factory, the new premises may not automatically be covered by the existing licence.
When Does Factory Relocation Require a Fresh BIS Licence?
A fresh BIS licence may generally be required when the manufacturer shifts manufacturing from the licensed premises to another independent manufacturing location.
For example, assume a manufacturer has a BIS licence for its Delhi factory:
Factory A → BIS Licence → Product X
The company later closes Factory A and starts manufacturing Product X at a new factory in Haryana.
In this situation, the new facility is a different manufacturing premises. The existing licence for Factory A should not simply be assumed to cover Factory B.
The new premises may need to undergo the applicable BIS evaluation and certification process.
What If Only the Factory Address Has Changed?
This is where manufacturers often get confused.
There is an important difference between:
Administrative/address modification
and
Actual relocation of manufacturing activities.
If the manufacturing premises themselves have changed, updating the address on company documents does not automatically mean that the BIS licence can continue unchanged.
BIS needs to establish whether the new premises have the same or acceptable manufacturing and testing capabilities required for the licensed product.
The manufacturer should therefore approach BIS before shifting production rather than moving production first and trying to regularise the licence afterward.
What If the New Factory Is in the Same Industrial Area?
The distance between the old and new factory does not necessarily determine whether a fresh licence is required.
For example, moving production from one building to another building within the same industrial area may still involve a different manufacturing premises.
BIS certification is concerned with the actual location and facilities where the certified product is manufactured.
So, even if the new factory is only a few kilometres away, the manufacturer should not assume that the existing licence automatically remains valid for the new location.
What Happens If the Manufacturer Has Two Factories?
A manufacturer may operate multiple manufacturing facilities producing the same product.
However, having multiple factories does not necessarily mean that one BIS licence automatically covers all of them.
Each manufacturing location needs to be considered in accordance with the applicable BIS certification scheme and Indian Standard.
For example:
| Manufacturing Setup | BIS Consideration |
|---|---|
| One product manufactured at one licensed factory | Existing licence may cover the approved premises |
| Same product manufactured at a second factory | Additional BIS approval/licensing may be required |
| Production completely shifted to another factory | Fresh certification/appropriate BIS action may be required |
| Only office address changed | Different from manufacturing-premises relocation |
| Factory expanded within the same premises | May be handled differently, depending on the change |
The exact treatment depends on the applicable product certification scheme and BIS requirements.
Can Production Continue During the Relocation?
Manufacturers should be particularly careful here.
If the existing BIS licence is linked to Factory A, shifting production to Factory B before obtaining the necessary BIS approval can create a compliance issue.
The manufacturer should first determine:
- Whether the new premises require a fresh licence.
- Whether BIS inspection of the new premises is required.
- Whether the existing licence needs modification or other action.
- Whether production and marking can continue during the transition.
- How existing certified stock should be handled.
The safest approach is to clarify the position with BIS before production is shifted.
What About the BIS Mark on Existing Stock?
Factory relocation can also create questions regarding products already manufactured at the old premises.
For example, if products were manufactured while the original BIS licence was valid, those products should not automatically be treated in the same way as products manufactured at the new premises.
Manufacturers should maintain proper records showing:
- Production dates
- Manufacturing location
- Batch or lot details
- Test records
- BIS marking details
- Dispatch records
- Stock remaining at the old facility
This documentation can become important when demonstrating that products were manufactured under the appropriate certification conditions
.
Documents You May Need for the New Premises
Depending on the applicable BIS scheme and product, the manufacturer may need documents relating to the new manufacturing facility, such as:
- Factory address and ownership/occupancy documents
- Manufacturing process details
- Machinery and equipment details
- In-house laboratory/testing facility details
- Calibration records
- Quality control documentation
- Raw material details
- Test equipment information
- Factory layout
- Competent technical personnel details
- Previous BIS licence information
Additional documents may be required depending on the product and Indian Standard.
A Common Mistake Manufacturers Should Avoid
One of the biggest mistakes is treating a factory relocation as a simple address update.
A BIS licence is connected to the conformity assessment of the manufacturing premises. Therefore, changing the place where the certified product is actually manufactured can affect the validity and scope of the certification.
Manufacturers should not wait until an inspection, renewal or market surveillance activity to disclose that production has already shifted.
Final Takeaway
Factory relocation does not automatically mean that the existing BIS licence can be transferred to the new premises.
If the actual manufacturing location changes, the manufacturer should first determine the BIS requirements applicable to the new premises. Depending on the circumstances, the manufacturer may need a licence modification, additional approval, inspection or a fresh BIS licence.
Before moving production, manufacturers should review the change with respect to the applicable Indian Standard, BIS certification scheme and existing licence conditions.
For manufacturers, the key rule is simple: do not shift certified production to a new factory assuming the old BIS licence will automatically follow the product. Verify the certification requirement before production starts at the new premises.
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