SankalpBIS certification for packaged drinking water is voluntary in India today. FSSAI notified the omission of the clauses that made it compulsory on 17 October 2024, and a mandatory Scheme of Testing took its place from 1 January 2026. What a water brand must hold is an FSSAI licence. For the ISI mark as well, you apply under Scheme-I of Schedule-II of the BIS (Conformity Assessment) Regulations, 2018, against IS 14543 or IS 13428.
Key takeaways
- An FSSAI licence is mandatory. A BIS licence is optional, and has been since 17 October 2024.
- IS 14543 covers packaged drinking water, IS 13428 natural mineral water. A licence names one of them.
- The BIS route is Scheme-I of Schedule-II, applied for in Form-V through the BIS online portal.
- Every BIS licence involves a factory visit, with conformity proved by testing in a laboratory recognised by the Bureau.
- FSSAI licences are issued within 60 days of the application ID number and run for 1 to 5 years.
- The closure sits inside the same food-contact boundary as the bottle, so the cap supplier’s documents end up in your file.
What is mandatory in 2026, and what is not
Two regimes run in parallel, and they get confused.
| Requirement | Status | Governing instrument |
|---|---|---|
| FSSAI licence | Mandatory | Licensing and Registration of Food Businesses Regulations, 2011 |
| Scheme of Testing | Mandatory from 1 January 2026 | FSSAI order dated 17 December 2025 |
| BIS licence and ISI mark | Voluntary | BIS (Conformity Assessment) Regulations, 2018, Scheme-I of Schedule-II |
| IS 14543 or IS 13428 | The standard the water is judged against either way | Bureau of Indian Standards |
The order of 17 December 2025 brought in monthly microbiological testing and record keeping, so the regulator swapped a one-time mark for a continuous obligation. Many brands keep a BIS licence anyway, because the ISI mark is a shelf-level signal a testing file cannot deliver.
Which licence route applies to you
The route depends on what you bottle, where you operate and whether you already hold a BIS licence. Read across to find the licences and the standard that apply.
| Your situation | FSSAI licence | BIS licence, if you want the ISI mark | Standard named |
|---|---|---|---|
| New packaged drinking water plant in one state, within State licensing limits | State licence, Form B | Scheme-I, Option 1 or Option 2 | IS 14543 |
| Plant with installed capacity above 2 MT per day, or operating in two or more states | Central licence, Form B | Scheme-I, Option 1 or Option 2 | IS 14543 |
| Natural mineral water bottled from a recognised natural source | State or Central, on the same tests as above | Scheme-I, against the mineral water standard | IS 13428 |
| Brand adding a second product type, such as mineral water alongside drinking water | Licence modified to add the new product category | A separate licence, because each licence names one standard | IS 14543 and IS 13428 |
| Foreign manufacturer supplying the Indian market | The importer holds an FSSAI Central licence covering import | Scheme-I, Option 1 only | The standard for the product |
| Existing BIS licensee | Unchanged, plus the Scheme of Testing | Renew in Form-XII to keep the mark, or stop using the mark when it lapses | As licensed |
Use the table to pick the route, then check the detail below and the current forms on each portal before filing. Licensing thresholds and forms are amended from time to time.
Step 1: the FSSAI licence
The part you cannot skip. Applications are made in Form B of Schedule 2.
Which authority. Schedule 1 lists the businesses that fall to the Central Licensing Authority. For a water bottler the two clauses that usually bite are food processing units with an installed capacity above 2 MT per day, and any operator running in two or more states. Below that, inside one state, it is a State licence.
What water bottlers file that others do not. Alongside a chemical and bacteriological analysis of the water to be used, units making packaged drinking water, packaged mineral water or carbonated water must submit a pesticide residues report from a recognised or public health laboratory, naming who collected the sample and when, with the source of raw water and the treatment plan. A no-objection certificate from the local body and the State Pollution Control Board is listed too.
Timelines. Scrutiny happens within 15 days, and you get 30 days to supply anything missing. The licence is issued within 60 days of the application ID number, runs for 1 to 5 years, and is renewed no later than 30 days before expiry.
Step 2: the BIS licence, if you want the ISI mark
BIS grants a licence after assessing your manufacturing infrastructure, production process, quality control and testing arrangements through a visit to your premises, and after establishing conformity through third-party laboratory testing, testing during the visit, or both.
| Stage | What happens |
|---|---|
| Application | Form-V, filed online, with the listed documents and a self-evaluation cum verification report |
| Route | Option 1: BIS visits, draws samples, sends them for third-party testing. Option 2: you submit conforming third-party reports up front, then BIS visits and draws a verification sample |
| Factory visit | Assessment of infrastructure, process, quality control and testing capability |
| Testing | Reports accepted from laboratories established, maintained or recognised by the Bureau |
| Fees | Half the annual minimum marking fee at application, the balance at grant. Inspection fee in advance |
| Grant | Licence to use the Standard Mark against the named Indian Standard |
| Surveillance | Factory and market surveillance samples drawn during operation |
| Renewal | Form-XII, minimum one year and up to five, preferably filed two months before the validity date |
Under Option 1, samples not offered for testing within 30 days of the application being recorded count against you, so book the lab slot before you file. Foreign manufacturers go through Option 1 only. Fees sit in the Regulations and are amended, so confirm the current schedule.
What this means for your packaging
A BIS or FSSAI file covers the finished pack, not the water in isolation. The container and everything sealing it are food-contact materials, which is where a closure supplier becomes part of your compliance story rather than a line item.
The Food Safety and Standards (Packaging) Regulations, 2018 require any material in direct contact with food to be of food-grade quality, and organise materials into schedules covering paper and board, metal and metal alloys, plastics, and suggested packaging by product. Plastic food-contact materials must meet an overall migration limit of 60 mg/kg or 10 mg/dm2 when tested by the method in IS 9845, with no visible colour migration. On a cap, the liner is what touches the water, so that is what the limit is about. Food-grade aluminium and liner standards covers how the limits apply to a closure.
IS 14543 also expects the water to be packed in clean, food-grade, tamperproof containers and sealed so the product is protected and interference is evident. That means a food-grade liner, a seal that survives transport, and tamper evidence a buyer can read at a glance, which is why aluminium ROPP dominates closures for packaged drinking water. The wider picture is in FSSAI packaging rules for bottled beverages and choosing caps for a water brand. R Vision’s Aqua Cap is a 28/15 mm aluminium ROPP closure with a TPE liner, rated to 8 bar, adhering to USFDA and EU standards.
What a water brand needs from its closure supplier to pass
A cap is not certified as a separate article, but a licence inspection, a surveillance sample or a customer audit will still reach it. These are the things to have from your closure supplier before the inspector asks.
| What you need | Why it comes up | What to get from the supplier |
|---|---|---|
| A food-grade liner and internal coating | The packaging regulations and the IS 14543 packing clause require food-grade contact materials | A written food-contact declaration naming the framework, and an overall migration test report for the liner stating simulant, time and temperature |
| A tamper band that shows opening | IS 14543 asks for a tamperproof pack, and a buyer judges it at the shelf | A closure with a band that breaks visibly on first opening, and the band included in incoming inspection |
| A seal that holds through storage and transport | A leaking or contaminated pack fails the water tests regardless of the water | Leak, secure-seal and drop results on your own bottle, run as set out in testing a ROPP closure |
| A cap that fits your neck finish | A cap made for a different finish seals badly on every bottle | A dimensional report against your finish drawing and an agreed sampling plan, as covered in cap dimension tolerances and QC sampling. The finishes in use are set out in neck formats on Indian packaged water bottles |
| Batch traceability | Surveillance or a complaint has to trace a pack back to a closure batch | A batch code on every carton and a certificate of analysis or conformity per delivery |
| A document set you can hand an auditor | The FSSAI file and any export customer ask for evidence, not claims | The checklist in quality certificates to ask your cap supplier for |
| Supply that does not stall the line | A plant under a monthly testing regime cannot change closures at short notice | Written minimum order quantities and lead time, planned against your production |
R Vision’s position on record is that its closures adhere to USFDA and EU standards; that is adherence, not a third-party certificate. Aqua Cap minimums are 50,000 caps plain silver, 200,000 plain colours and 300,000 litho printed, on a lead time of 4 to 6 weeks, and bulk ROPP cap orders covers how a volume order is placed.
Frequently asked questions
Is BIS certification mandatory for packaged drinking water in India?
No. FSSAI notified the omission of the clauses that made BIS certification compulsory for packaged drinking water and packaged mineral water on 17 October 2024, and a Scheme of Testing took effect on 1 January 2026 in its place. An FSSAI licence remains mandatory. A BIS licence and the ISI mark are voluntary, and many brands keep one as a trust signal.
Which standard applies to my water, IS 14543 or IS 13428?
IS 14543 is the Indian Standard for packaged drinking water, meaning water treated and sealed for sale. IS 13428 covers packaged natural mineral water from a recognised natural source. A BIS licence names one standard, so decide which product you are making before applying, because the choice changes the specification, the testing and the labelling.
How do I apply for a BIS licence for bottled water?
You apply online in Form-V under Scheme-I of Schedule-II of the BIS (Conformity Assessment) Regulations, 2018, with the listed documents and a self-evaluation report. BIS then visits your factory to assess infrastructure, process, quality control and testing capability, and conformity is established by testing in a laboratory recognised by the Bureau. On success the Bureau grants a licence to use the Standard Mark, followed by surveillance.
Does the bottle cap need its own BIS certification?
No. The licence covers the water and the pack it is sold in, not the closure as a separate certified article. What matters is that the cap and its liner are food-grade, and that the seal protects the product and makes interference visible. Ask a closure supplier for material declarations and migration evidence instead.
How long does FSSAI licensing take for a water plant?
The regulation sets a 60-day window from the application ID number, with scrutiny inside 15 days and 30 days for you to supply anything missing. The gating item is usually laboratory work, because the application needs a chemical and bacteriological water analysis and a pesticide residues report from a recognised or public health laboratory.
What should a water brand ask its cap supplier for?
A written food-contact declaration, an overall migration test report for the liner, a batch code and certificate with each delivery, a dimensional report against your neck finish drawing, and leak and seal test results on your own bottle. Also get minimum order quantities and lead time in writing, so closure supply does not hold up a plant working under a monthly testing regime.
Sources
- Bureau of Indian Standards: Conformity Assessment Regulations, 2018, with the Guidelines for Grant of Licence and Renewal of Licence under Scheme-I of Schedule-II
- FSSAI: Licensing and Registration of Food Businesses Regulations, 2011, and the Packaging Regulations, 2018
- IS 9845, overall migration from plastics in contact with foodstuffs, Bureau of Indian Standards
- IS 14543: 2016, packaged drinking water, with amendments, Bureau of Indian Standards, for the packing clause
Standards and orders are revised, so confirm the current position first. To discuss closures for a water line, contact R Vision.