Few areas of India trade compliance generate as much avoidable cost as steel imports. A consignment held at port for a documentation question accrues demurrage and storage daily, and in the worst cases faces rejection. The framework that governs this — the Bureau of Indian Standards (BIS) Quality Control Order (QCO) regime — is genuinely complex, frequently updated, and easy to fall foul of. It is also, as of late 2025, shifting.

The QCO framework in brief

Under the Steel and Steel Products (Quality Control) Order, issued by the Ministry of Steel under the BIS Act 2016, steel grades that are covered by a QCO may generally only be imported from manufacturers holding a valid BIS licence for the relevant grade, with the appropriate ISI marking and mill test certification. The list of covered grades is expanded periodically, which is part of why importers struggle to keep current.

Where the NOC came in

Not every steel product is covered by a QCO. For grades and products falling outside the mandatory BIS scope, the Ministry of Steel historically issued a No Objection Certificate (NOC) — on a per-grade, per-consignment basis through the TCQCO portal — confirming that the specific product did not require BIS certification. This NOC was what cleared customs for non-covered material.

The recurring problem was customs classification. A product’s tariff code, or its superficial similarity to a covered grade, would lead customs to demand BIS certification for material that did not actually require it. Without an NOC in hand to demonstrate non-applicability, the consignment stalled.

What changed in late 2025

In November 2025 the Ministry of Steel moved to ease this. For steel grades not covered by any QCO, the requirement to obtain a clarification or NOC was removed, and importers were permitted to generate SIMS (Steel Import Monitoring System) numbers directly through the portal without Ministry approval. The exemption was tied to a Bill of Lading shipped-on-board date — extended, at the time of writing, to on or before 31 March 2026 — and certain stainless steel standards (IS 6911, IS 5522, IS 15997) received their own extended exemption windows.

This is a genuine simplification for non-QCO material. But it does not make the regime simple.

Why importers still get caught

Several traps remain, and they are exactly the ones that cost money:

The exemptions are time-limited. A window extended to 31 March 2026 is not permanent, and shipments planned around it must account for the shipped-on-board date, not the arrival date. Misjudge the timing and the exemption does not apply.

QCO-covered grades are unaffected. The easing applies to non-covered material. If your grade is within a QCO, you still need BIS-licensed sourcing and the full documentary chain — and the covered list keeps growing.

Classification disputes persist. Customs can still treat a product as covered based on its code or a similarity judgement. Demonstrating non-applicability — and doing so before the cargo is sitting at port — remains the practical challenge.

The documentation must be right. Commercial invoice, packing list, bill of entry, mill test certificate, country of origin: an inconsistency in any of these can trigger the very query the regime change was meant to avoid.

The practical takeaway

The right approach is to determine applicability before ordering, not after the cargo arrives. Establish whether the specific grade is QCO-covered, whether an exemption window applies and on what date basis, and assemble the documentary chain to match. Where a classification question is likely, address it proactively rather than arguing it at the port under demurrage pressure.

This is precisely the kind of moving-target compliance that benefits from someone tracking the changes. Our Cargo, Chartering & Trade practice assists steel importers in assessing applicability, navigating the QCO and exemption framework, and assembling the documentation to clear cargo without costly delay.