For any foreign manufacturer seeking to sell certified products in India, the Authorised Indian Representative (AIR) is one of the most important and least understood requirements in the entire BIS certification process. The AIR is not simply an administrative contact or a courier for documents — the AIR is the legally responsible party in India for your BIS certification, your factory audit scheduling, and ultimately, for compliance under the BIS Act, 2016. Choosing the wrong AIR — or failing to understand the AIR’s obligations — can delay your certification, invalidate your BIS licence, or expose your AIR (and by extension, your market access) to liability. This guide explains everything a foreign manufacturer needs to know before appointing an AIR. 1. What Is an Authorised Indian Representative (AIR)? An Authorised Indian Representative (AIR) is a legal entity registered in India that is formally appointed by a foreign manufacturer to represent them in all dealings with the Bureau of Indian Standards (BIS) for the purpose of obtaining and maintaining a BIS licence under the Foreign Manufacturers Certification Scheme (FMCS). BIS does not interact directly with foreign manufacturers on product certification matters — all communication, document submission, fee payment, and compliance obligations are handled through the AIR. The AIR is, from BIS’s perspective, the responsible party in India. Key rule: The AIR must be an Indian legal entity — a company, partnership, or individual with a registered Indian business address. An individual foreign national cannot be an AIR. A foreign company’s Indian branch office may qualify. 2. When Is an AIR Required? Indian importers importing goods manufactured overseas under a foreign brand do not act as AIR — the AIR is appointed by the foreign manufacturer and holds the BIS licence, with the Indian importer as a separate commercial entity. 3. AIR’s Legal Role and Responsibilities Responsibility Detail Liaison with BIS All correspondence, submissions, queries, and responses to BIS on behalf of the foreign manufacturer Application filing Submitting the FMCS application on the manakonline.in portal and paying BIS fees Factory audit coordination Arranging logistics for BIS auditor(s) to visit the overseas factory, including visa support, travel, accommodation Sample submission Coordinating lab sample submission to BIS-approved laboratories Document accuracy Ensuring all technical and company documents submitted to BIS are accurate, current, and complete Compliance maintenance Maintaining licence conditions — surveillance visits, market sample compliance, annual fees Legal liability The AIR can be held liable under the BIS Act, 2016 for non-compliance or misrepresentation in India 4. Who Can Be an AIR? BIS does not specify a minimum qualification for AIRs beyond the requirement to be a legally registered Indian entity. However, in practice, an effective AIR should have: Consultancy firms, compliance professionals, Indian importers/distributors with deep BIS experience, and specialised regulatory bodies all commonly serve as AIRs. The foreign manufacturer must exercise due diligence in AIR selection — using an unqualified or inactive AIR is a common cause of FMCS application failure. 5. The AIR Agreement: What It Must Contain The AIR relationship must be formalised through a written agreement between the foreign manufacturer and the AIR, which BIS requires as part of the FMCS application. This agreement must include: 6. Risks of Appointing the Wrong AIR Changing AIR after licence grant requires a formal BIS application for AIR substitution. This process takes time and can leave a compliance gap if not managed proactively. 7. PCN India Global as Your Authorised Indian Representative PCN India Global functions as Authorised Indian Representative for foreign manufacturers across a wide range of product categories — from consumer electronics and electrical appliances to industrial equipment, toys, steel products, and more. As AIR, we: 8. BIS FMCS Process Overview with AIR Involvement FMCS Stage AIR’s Role Application preparation Compiles documents, checks IS Standard applicability, files on portal BIS fee payment Pays BIS application fee on behalf of foreign manufacturer Lab sample submission Ships product samples to BIS-approved lab; provides product technical documentation Factory audit scheduling Coordinates BIS auditor travel, hotel, visa letters, factory readiness Factory audit support May accompany BIS auditors and support documentation queries on-site Post-audit follow-up Responds to any BIS observations or additional information requests Licence issuance Receives BIS licence; provides copy to foreign manufacturer Annual surveillance Schedules and manages annual BIS factory visit; ensures market samples are compliant Licence renewal Initiates renewal application before expiry; manages transition Need Expert Assistance? Contact PCN India Global India’s regulatory compliance landscape is complex, multi-agency, and constantly evolving. Missing a certification, filing deadline, or document requirement can result in customs holds, product seizures, and significant financial loss. PCN India Global provides complete end-to-end support — from first-mile regulatory mapping through to certificate issuance, with experienced consultants managing every government touchpoint on your behalf. We specialise in: 📞 Phone: 08010905029   |   ✉ Email: bdm@pcnindiaglobal.com   |   🌐 pcnindiaglobal.com Your first compliance consultation is free. Reach out today. Frequently Asked Questions Q1: Can the Indian importer/distributor of our products serve as our AIR? Yes — the Indian importer or distributor is one of the most common choices for AIR, provided they are willing to accept the legal responsibilities. However, if the commercial relationship changes (they stop distributing your products), you will need to appoint a new AIR and notify BIS. A neutral professional consultancy like PCN India Global as AIR avoids this dependency. Q2: Can a foreign company with an Indian branch office act as its own AIR? Yes, a branch office of a foreign company registered in India can serve as the AIR for the parent company’s BIS applications, provided the branch is validly registered under the Companies Act or FEMA. This is a common arrangement for multinational companies with established Indian operations. Q3: What happens if our AIR becomes unresponsive or exits the market? You should immediately initiate the BIS AIR substitution process by appointing a new AIR and filing the substitution application with BIS. The new AIR assumes all compliance obligations for the licence. During the transition, you should ensure no compliance deadlines are missed.