BIS Certification for Toys: Understanding IS 9873 and IS 15644

Toy safety regulation in India has tightened considerably over the past few years, and for good reason. Toys are products children handle directly, often put in their mouths, and use in ways that go beyond their intended design. Recognizing this, the Indian government made BIS certification for toys under the Toys (Quality Control) Order, and two standards sit at the center of this requirement: IS 9873 and IS 15644.

If you manufacture, import, or sell toys in India, understanding what these two standards cover — and how they apply to your specific product — is the starting point for getting certified and staying compliant.

Why Toy Certification Became Mandatory

Before the Toys (Quality Control) Order came into effect, toy safety in India was largely unregulated, which meant products with sharp edges, choking hazards, or toxic materials could reach the market with little oversight. The mandatory BIS certification requirement changed this by requiring every toy sold in India — whether manufactured domestically or imported — to carry the ISI mark, confirming it has been tested and certified against the relevant safety standards.

This isn't a one-time formality. Toys must be tested at BIS-recognized laboratories, manufacturing facilities are subject to factory audits, and certification needs to be maintained through periodic surveillance.

Understanding IS 9873: Safety of Toys

IS 9873 is the primary standard governing the physical, mechanical, and chemical safety of toys in India. It is structured in multiple parts, each addressing a different safety dimension:

Mechanical and physical properties — This covers things like sharp edges, small parts that pose choking hazards, structural integrity, and the strength of toy components under normal use and reasonably foreseeable abuse.
Flammability — Toys are tested to ensure they don't ignite easily or burn in a way that creates a hazard, particularly for soft toys and costumes.
Migration of certain elements — This part addresses the chemical safety of toys, testing for the migration of substances like lead, cadmium, and other heavy metals that could be harmful if a child mouths or ingests parts of the toy.
Other safety aspects — Depending on the toy category, additional parts of IS 9873 may apply, covering things like sound levels for toys with noise-producing components, or specific requirements for toys intended for children under three years old.

Most toys sold in India need to comply with the relevant parts of IS 9873 depending on their material composition, intended age group, and design features.

Understanding IS 15644: Electrical Toys

IS 15644 applies specifically to electric toys — products that operate using batteries or electrical components, such as remote-controlled cars, electronic learning toys, or light-up toys. This standard addresses safety concerns unique to electrical products, including:

Protection against electric shock
Safe operating temperatures during use
Battery compartment safety and prevention of battery leakage or overheating
Mechanical strength of electrical components under normal handling

If your toy includes any electrical or battery-operated component, IS 15644 compliance is typically required in addition to the applicable parts of IS 9873, since the electrical safety requirements are distinct from the general mechanical and chemical safety requirements.

How the Certification Process Works

Getting BIS certification for toys under these5 standards generally follows this sequence:

1. Standard and scope identification The first step is determining exactly which parts of IS 9873 apply to your toy, and whether IS 15644 also applies based on whether the product has electrical components.

2. Sample testing Samples must be sent to a BIS-recognized laboratory for testing against the identified standards. This includes physical testing for sharp edges and small parts, chemical testing for material migration, and electrical testing if applicable.

3. Factory audit BIS conducts an audit of the manufacturing facility to verify that production processes, quality control systems, and material sourcing align with what's needed to consistently produce compliant toys. For overseas manufacturers, this audit applies to the foreign facility as well.

4. Application and license grant Once testing and audit requirements are satisfied, the application is processed through BIS, and upon approval, a license is granted allowing the manufacturer to use the ISI mark on the certified toy.

5. Surveillance and renewal After certification, BIS conducts periodic surveillance audits and may require re-testing of samples to confirm the toy continues to meet the required standards over time.

Common Issues Manufacturers Face

Toy certification has a few recurring pain points. Small parts testing under IS 9873 is stricter than many manufacturers expect, and toys that seem perfectly safe by general design standards sometimes fail due to detachable components that fit within the small parts cylinder used in testing. Chemical migration testing can also be a sticking point, particularly for painted or coated toys where pigment composition wasn't originally selected with Indian heavy metal limits in mind. For electrical toys, battery compartment design is a frequent source of non-conformity, especially when compartments aren't adequately secured against a child accessing the battery directly.

How UMSPCS Helps Toy Manufacturers and Importers

UMSPCS works with toy manufacturers and importers to navigate the IS 9873 and IS 15644 certification process from start to finish. This includes:

Identifying which parts of IS 9873 and whether IS 15644 apply to your specific toy
Coordinating sample testing with BIS-recognized labs and interpreting test results
Preparing technical documentation and quality manuals for the application
Supporting factory audit preparation, including for overseas manufacturing units
Advising on design or material adjustments when test results reveal non-conformities, before resubmission
Managing license renewal and surveillance audit requirements after certification

Because toy designs often involve small parts, coatings, and electronic components together, getting all the applicable standards right from the outset can save significant rework later in the process.

Final Thoughts

Toy certification under IS 9873 and IS 15644 protects children, but it also represents a real compliance hurdle for manufacturers and importers who aren't familiar with how strict and specific Indian testing requirements are. Getting the standard mapping right at the start, preparing for factory audits properly, and understanding common failure points can save months of back-and-forth with BIS. UMSPCS supports toy businesses through this entire process, helping turn a complex regulatory requirement into a manageable, predictable path to market.

Frequently Asked Questions

Q1. Do all toys need BIS certification in India?

Yes, under the Toys (Quality Control) Order, virtually all toys sold in India require BIS certification and must carry the ISI mark, with very limited exceptions for certain categories.

Q2. What's the difference between IS 9873 and IS 15644?

IS 9873 covers general toy safety, including mechanical, physical, flammability, and chemical safety requirements. IS 15644 specifically addresses electrical safety for toys that use batteries or electrical components.

Q3. Does my toy need both standards?

If your toy has any electrical or battery-operated component, it typically needs to comply with both the relevant parts of IS 9873 and IS 15644. Purely mechanical toys without electrical parts generally only need IS 9873.

Q4. What is "small parts testing" and why does it matter?

Small parts testing checks whether detachable components are small enough to pose a choking hazard, particularly for toys intended for children under three. Many toys fail this test due to design elements not originally intended as separable.

Q5. Can imported toys be certified, or only domestically manufactured ones?

Imported toys can be certified, but the foreign manufacturing facility must undergo a factory audit, and an Authorized Indian Representative is typically required to manage the certification on the manufacturer's behalf.

Q6. How long does toy BIS certification take?

Timelines vary based on testing results and audit scheduling, but the process commonly takes a few months from sample submission to license grant.

Q7. What happens if my toy fails chemical migration testing? If a sample exceeds permissible limits for substances like lead or cadmium, the manufacturer needs to identify the source — often paint, coatings, or plastic additives — and reformulate before retesting.

Source- https://medium.com/@cdscoapprovals/bis-certification-for-toys-understanding-is-9873-and-is-15644-umspcs-4564ddad0132

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