The QCO imperative Navigating opportunities and challenges in India
The Indian government has increasingly implemented Quality Control Orders (QCOs) to strengthen product safety, boost consumer confidence and improve manufacturing standards. Issued under the BIS Act, QCOs mandate compulsory certification for specified products before market sale. As of March 2025, 1,871 QCOs covering 769 products have been notified, with BIS managing technical enforcement and DPIIT leading policy oversight. While QCOs initially focused on industrial products, they are now expanding to the fast-growing FMCG sector, valued at ~USD 245 billion in 2024 and projected to grow at ~17% CAGR till 2033. Although QCOs aim to align with global standards and support national manufacturing initiatives, implementation challenges exist. FMCG companies face concerns regarding legacy inventory, frequent recertification due to packaging or formulation changes, supply chain disruptions from import regulations, testing infrastructure gaps and inconsistent regulatory interpretation across stakeholders. Specific issues include unequal marking fees for sanitary napkins versus diapers, uncertainty around disposal of unsold pre-QCO stock, overlaps with global IEC standards for shavers/trimmers, delays in BIS certification for imported raw materials, and regulatory overlap in sectors already following strong standards. Industries suggest allowing sale of pre-QCO stock for its full shelf life, universal simplified labelling for multi-site manufacturing, industry self-declaration for compliance, increased BIS lab capacity, and strict SoPs for testing labs. Effective execution will require regulatory clarity, coordination and phased implementation to ensure consumer protection without disrupting supply chains for essential FMCG goods.