Your Screen Guard Is Now a Notified Electronics Good. Unless It Is Plastic.

MeitY added screen protectors for smartphones to the Compulsory Registration Order on 21 September 2026, against IS 19348:2025, effective 1 April 2027. The standard specifies glass. Roughly half of what sells in India as a screen guard is not glass, and the notification does not say what happens to it.

A container of screen protectors lands at Nhava Sheva in May 2027. The importer has done the work. The factory in Dongguan holds a CRS registration against IS 19348:2025. The registration number is on the carton, the nominal thickness is declared, the batch number is printed, the month and year of manufacture are on the packet, and every piece carries fog marking.

Half the consignment clears.

The other half is hydrogel film. Same brand, same buyer, same invoice, same eight digit code. No registration.

What actually changed

The Ministry of Electronics and Information Technology issued S.O. 5190(E) on 21 September 2026, under sub-sections (1) and (2) of section 16 read with sub-section (3) of section 25 of the Bureau of Indian Standards Act, 2016. File number W-47/8/2023-IPHW, signed by Sushil Pal, Joint Secretary.

It inserts a single row, S. No. 66, into the Schedule of the Electronics and Information Technology Goods (Requirement of Compulsory Registration) Order, 2021:

The order applies from 1 April 2027. Column 5 carries nothing, so there are no essential requirements layered on top. Everything that will be tested sits inside IS 19348:2025 and nowhere else.

The standard was published in July 2025 by the Glass, Glassware and Laboratoryware Sectional Committee, CHD 10, drafted by working group CHD 10:WG 3 with ICEA, MeitY, Corning Technologies India, Optiemus Electronics, CEAMA and Asahi India Glass at the table. It draws on IEC 61747-40-1, IEC 61747-40-2 and ASTM C1422.

Three circles, and they are not the same size

This is the first thing to get straight, because three different documents describe three different populations of product.

The standard is available for use across the whole range. The registration obligation is narrower than the standard. A tempered glass protector for an iPad is inside IS 19348:2025 and outside S. No. 66. It can be certified voluntarily. It cannot be required to be, on the text as notified.

The glass question

Now the part that matters most, and the part the notification does not resolve.

Clause 3.3 defines the product:

Read that construction carefully. The glass body is mandatory. Everything after "may have" is optional.

So a PET film guard is not a glass screen protector. Nor is a TPU or hydrogel film. Nor is a PMMA sheet. Nor is the product sold across Indian marketplaces as "flexible ceramic glass" or "nano glass", which is in most cases a coated polymer film with no chemically strengthened glass layer in it at all.

Set that against the CRO entry, which says only "Screen Protectors for smartphones", with no material qualifier.

Two readings are available on the text, and both are defensible:

Reading one, the narrow one. The goods description takes its meaning from the standard it is paired with. Column 2 and column 3 are read together. A film guard is not a glass screen protector, no Indian Standard is notified against it, and it therefore falls outside S. No. 66 entirely. It stays sellable, uncertified, from 1 April 2027.

Reading two, the broad one. The goods description is the operative scope and it is material neutral. Every screen protector for a smartphone needs registration. A film guard cannot obtain one, because the only notified standard specifies glass. It therefore becomes unsellable rather than exempt.

These lead to opposite commercial outcomes for the same product. One makes film the cheapest compliant route in the category. The other makes it contraband.

Nothing in S.O. 5190(E) chooses between them, and the distinction bites at three points: at customs, where classification runs off the goods description; at a marketplace listing, where the platform applies its own reading; and in any purchase order placed now for delivery after the effective date.

There is a tell in the drafting, though it is not conclusive. MeitY wrote the goods description itself, and chose not to write "Glass Screen Protectors for smartphones" when the standard's own title offered that phrasing.

What IS 19348:2025 actually measures

Seven things. That is the whole of clause 4.

Marking is separate and specific. The packet carries source of manufacture, nominal thickness, code or batch number, and month and year of manufacture. Each individual piece carries fog marking with the source and year of manufacture. That last one is a tooling change for most lines, not a print change.

Sampling runs off Annex D. For a lot above one lakh pieces, 68 samples go to visual faults and light transmission, 8 to thickness and dimensions, and 60 to surface compression and mechanical strength, with zero defectives permitted. Both of the last two are destructive. A lot is same quality, same nominal thickness, same batch, in a single consignment, so a consolidated shipment drawn from several production runs is several lots.

What it does not measure

Not as criticism. As a test plan boundary, because it decides what a lab will and will not put on a report.

The standard contains no hardness requirement of any kind, and no scratch resistance test of the finished surface: clause 4.3 counts a scratch as an incoming manufacturing defect, not a performance property. There is no impact test either. Clause 4.6.1 is a four point bend at 5 mm per minute over a 36 mm span, measuring flexural strength under a slowly applied load, not a ball drop or a device level drop.

Also absent: fragment retention, despite "anti-shatter film" being named in clause 3.3. Adhesion in any form. Coating durability, so no contact angle and no wipe cycles. Blue light performance. Privacy viewing angle. Anti-bacterial efficacy. Touch and fingerprint sensor compatibility. Haze. Colour and tint. Environmental ageing.

And one gap that matters more than the rest: there is no limit on depth of layer. Clause 3.1 defines depth of compression, Annex B gives the method, clause B-5 requires the report to state it, and clause 4.5 then sets a limit only on surface compression. The two together determine whether a flaw reaching past the compressed layer will propagate, which is what a drop onto grit does. A short ion exchange buys high surface compression with a shallow layer, cheaply. A product can clear 500 MPa with a very shallow layer and satisfy clause 4.5 exactly as written.

Where the standard leaves latitude

Three places, all on the face of the text.

The declared value sets its own target. Clause 4.1.1 fixes the tolerance at plus or minus 10 percent of the nominal, declared thickness. There is no minimum thickness anywhere in the standard, so a protector declared at 0.15 mm and measured at 0.15 mm passes. The clause also says "only glass thickness shall be measured", which puts the adhesive, the anti-shatter film and the coatings outside the measurement though they are inside the product.

Dimensions and packing are by agreement. Clause 4.1.2.1 sets nominal width and length as agreed between purchaser and supplier, with Table 1 giving a tolerance around that agreed figure. Clause 5.1.1 does the same for packing. Fit to a specific handset is not a requirement of the standard.

There are only two light transmission categories. Clause 4.2 gives "normal" at greater than 89 percent and "privacy films" at not less than 59 percent. Clause 3.3 separately names anti-glare film and a blue light cutting layer as legitimate components, and clause 4.2 gives neither a category. Published specifications for anti-glare glass typically sit between 88 and 90 percent transmittance, and blue light cut glass lower still. Note the asymmetry too: "greater than 89 percent" excludes exactly 89.0, while "not less than 59 percent" includes exactly 59.0.

Claims that need a decision before you book a lab slot

This is the working list. The middle column is the only one that determines what appears on your test report.

A sensible sequence

1. Write to BIS and MeitY on the material question. Ask whether S. No. 66 extends to non-glass protectors for smartphones. Keep the reply. Everything else depends on the answer.
2. Split your catalogue three ways. Glass for smartphones, in scope. Non-glass for smartphones, grey zone. Tablets, laptops and readers, outside S. No. 66 as notified.
3. Fix your declared values now. Nominal glass thickness, nominal length and width. Every test is judged against numbers you choose.
4. Book the destructive tests early. Surface compression and four point bend consume 30 to 60 pieces per lot with zero defectives allowed.
5. Settle the anti-glare and blue light transmission question with the lab in writing before the sample goes in.
6. Redraw the pack. Fog marking on each piece, packet marking with source, nominal thickness, batch code and month and year of manufacture, then every claim reconciled against the table above.
7. Map your supplier factories. CRS registration attaches to the manufacturing location, not to your brand, and a foreign unit needs an Authorised Indian Representative resident in India.

The wider point

A compulsory registration order does two things at once. It sets a floor, and it draws a line around the things the floor applies to.

IS 19348:2025 sets a genuine floor. Five hundred megapascals of surface compression and a 200 MPa tenth percentile bend strength are real numbers, and a great deal of what currently sells at twelve rupees a piece will not meet them. That part is working as intended.

The line is the harder part. It was drawn around glass, by a glass committee, in a glass standard, and then a goods description was written above it that does not say glass. For most of this category the two coincide. For the part of it that is film, they do not.

That gap is not going to be closed by reading the notification again.

This article is regulatory commentary for importers, brands and manufacturers of mobile accessories. It is not legal advice, and positions should be confirmed against the current text of the relevant instruments before a filing decision.