1.

BUREAU OF INDIAN STANDARDS CENTRAL MARKS DEPARTMENT-2

FREQUENTLY ASKED QUESTIONS (FAQs) ON QUALITY CONTROL
ORDERS FOR FOOTWEAR PRODUCTS

 Will industry get some time to comply with the QCOs with respect to the
products as per the revised standards?
The manufacturers making the products as per these revised specifications will
be given an additional time of 6 months to comply i.e. up to 31 December
2023. This applies to both domestic and foreign manufacturers making
footwear for consumers in India.
 Can BIS grant any extension or exemption from the QCOs?
Any exemptions like non-applicability of the Order on specific product(s),
product(s) meant for export, extension of the date of commencement of QCO
etc. come under the purview of the Line Ministry (Regulator) who has issued
the QCO i.e. DPIIT in case of footwear. Wherever exemptions are permitted,
these are clearly brought out in respective QCO itself such as exemption for
products meant for export.1

2. CAAT REQUEST TIME FOR IMPLEMENTATION OF QUALITY CONTROL

ORDERS FOR FOOTWEAR TRADERS 2

 The industry is gearing up for readiness of QCO compliance for new manufacturing,
but as of now there has been no clarity for applicability of QCO on the inventory
manufactured / procured prior to 30th June, 2023 (before QCO effective date), for
which large capital has been deployed by pan-India retailers, while incurring huge
amount of taxes, duties & levies.
 the effective date of QCO for the retail traders must account for the lead time in
procurement of inventory and should be suitably extended while ensuring the
sufficient lead time from the date of implementation of QCO by the manufacturers,
i.e. 8-10 months from the effective date for the manufacturers.
 Retail industry to be allowed 8-10 months’ time extension from the date of
implementation of QCO by the manufacturers. Exemption for the existing inventory
manufactured / procured prior to the QCO effective date, on declaration to BIS.

3. Footwear retailers seek 8-10 month extension to implement BIS quality control
order3

 Saurabh Sanyal, CEO and Secretary, PHD Chamber of Commerce and

Industry (PHDCCI), said that the implementation of QCO at this crucial
juncture without much time for transition for the retail industry has created a
precarious situation and will be an impediment to the operation, growth and
sustenance of the footwear retail sector.
1
https://www.bis.gov.in/wp-content/uploads/2023/07/FAQs-on-footwear-merged.pdf [refer to Q.5 & Q.13]
2
https://taxguru.in/corporate-law/caat-request-time-implementation-quality-control-orders-footwear-
traders.html [refer page 2- para 2 and 3]
3
https://www.businessinsider.in/business/news/footwear-retailers-seek-8-10-month-extension-to-implement-
bis-quality-control-order/articleshow/99779814.cms
  While the industry is gearing up for readiness of QCO compliance for new
manufacturing, as of now there has been no clarity for applicability of QCO on
the inventory manufactured or procured prior to June 30, 2023 (before QCO
effective date), for which large capital has been deployed by pan-India
retailers while incurring a huge amount of taxes, duties and levies

 According to the PHDCCI statement, only a miniscule of manufacturers or

suppliers have been able to receive the BIS licences till date with 30 licences
issued across 10 leather footwear categories, and 18 licences for 13 categories
of non-leather footwear.
At the current pace, the certification process for most manufacturers will not
be completed even after the QCO's effective date

BIS had still not come up with product manuals for some standards, testing equipment
required, testing methodologies and procedures

4. Extend implementation of quality control norms by 12 months for footwear;

industry is not ready yet 4

 Global Trade Research Initiative (GTRI) co-founder Ajay Srivastava said

there is a need for the government to provide clarity on the selling of existing
stock.
"OCO provides no guidelines on using existing stock post application of OCO.
Leather is a long-lasting item; many retailers store shoes for 2-3 years. Since it
will be difficult to segregate inventory, the QCO may be applied to retailers
after 12-24 months," he suggested in a report.

 An industry expert too said that the government should exempt footwear
above a certain price band from this quality order. Providing this exemption
will not harm the interest of local manufacturers and at the same time allow
import of hig end products, which are of high quality, he said.

 It added that setting up of testing and certification facilities before applying for
the BIS registration and certification process takes time and money as existing
facilities are insufficient to cater to the current requirements.

 A well-timed and effective QCO, investment in high quality and scale

production facilities for non-leather shoes and a heart to protect small firms
will take the sector to new heights

4
https://retail.economictimes.indiatimes.com/news/apparel-fashion/footwear/extend-implementation-of-
quality-control-norms-by-12-months-for-footwear-industry-not-ready-yet/99897945
 5. Indian footwear industry in dark on QCO compliance, needs more time5

 Rajiv Wasan, general secretary of Agra Footwear Manufacturers and Exporters

Chambers, told Fibre2Fashion, "Government authorities expect in-house testing
facilities in manufacturing units, but cottage and small units cannot maintain
such facilities. They need common facilities nearby. The industry is in the dark,
and small unit owners are even unaware of the developments."
 Wasan mentioned that a conference was recently held to discuss the
implementation of the QCO. However, he believes that it will be very
challenging to enforce it at present. If the government proceeds with the
enforcement, it will result in the destruction of stocks worth crores of rupees,
which will be catastrophic for thousands of shoe manufacturers. He categorically
stated that the industry needs at least two years to comply with the order.
Recently, the government has only given a two-month grace period. Wasan
suggested that the authorities should focus on standardising raw materials first
instead of just finished products.

Therefore, according to my understanding and research what I conclude is that

More time period should be allotted to the footwear industry for following the QCO’s as they
have huge stocks which is manufactured before the order of 2023.
Facilities should be provided to small scale industries for testing and getting ISI mark.
Exemptions to be given for some products which does not harm the interest of the
manufacturer.

5
https://www.fibre2fashion.com/news/apparel-accessory-news/indian-footwear-industry-in-dark-on-qco-
compliance-needs-more-time--287209-newsdetails.htm