Expert SpeakDigital Frontiers
Published on Jun 30, 2026
As India makes e-commerce platforms the enforcers of its quality-control standards, the challenge is to protect consumers without shutting smaller sellers out of the marketplace
In February 2026, the Central Consumer Protection Authority (CCPA) of India issued an order against Snapdeal concerning the sale of toys that were non-compliant with the Toys Quality Control Order, 2020 and the mandatory standards issued by the Bureau of Indian Standards (BIS). The CCPA observed that e-commerce platforms are required to ensure that prohibited or regulated products are not made available on their marketplaces.
The order is significant because the CCPA treated the listing and promotion of toys non-compliant with BIS standards as more than a technical lapse. It held that concealing material information, such as BIS certification and Indian Standards Institute (ISI) marks, violated consumers’ right to be informed about product quality and to be protected against hazardous goods.
The CCPA found that Snapdeal’s conduct amounted to an unfair trade practice and misleading advertisement, directed the platform to prevent future listings of non-compliant toys, required clearer display of grievance redressal details, and imposed a penalty of INR 5 lakh.
The Snapdeal order points to a broader shift in digital commerce regulation. Quality control is no longer only a question of whether a manufacturer complies with a product standard. It is also becoming a question of whether marketplaces have adequate systems to identify regulated products, verify compliance claims, prevent unsafe listings, and respond to consumer complaints. In effect, platforms are being pushed into the role of quality-control intermediaries.
The CCPA found that Snapdeal’s conduct amounted to an unfair trade practice and misleading advertisement, directed the platform to prevent future listings of non-compliant toys, required clearer display of grievance redressal details, and imposed a penalty of INR 5 lakh.
This role is necessary for consumer trust but also raises difficult questions about competition, Micro, Small and Medium Enterprises (MSMEs) participation, and platform fairness. This piece examines the role of Quality Control Orders (QCOs) in e-commerce and the wider market implications of making marketplaces custodians of quality.
Understanding QCOs and Their Implications for E-Commerce
QCOs are regulatory instruments through which the Central Government makes compliance with specific Indian standards mandatory for identified products. While BIS certification is generally voluntary, QCOs require covered products to conform to the relevant standard and carry the BIS Standard Mark. They are issued in the public interest for objectives such as safety, environmental protection, prevention of unfair trade practices, and national security. Once a QCO comes into force, no person can manufacture, import, distribute, sell, lease, store or exhibit the covered product for sale without the required BIS certification.
QCOs are important in brick-and-mortar commerce, but their relevance increases in digital markets. In traditional markets, trust can be built through seller familiarity and physical inspection of goods. In online marketplaces, consumers often have limited visibility into the seller, product quality, and supply chain. Trust, therefore, has to be institutionalised through standards, traceability, product authenticity, and compliance systems. This makes QCOs an important trust-building tool for online commerce. They can reduce the circulation of unsafe or sub-standard goods, strengthen consumer confidence, and create a more reliable market environment – especially important for high-volume, multi-seller marketplaces, where even small compliance gaps can affect consumers at scale.
When Marketplaces Become Custodians
Requiring marketplaces to ensure QCO compliance presents significant practical challenges. Unlike offline commerce, platform compliance is not limited to a single manufacturer or seller. It has to be managed across thousands of sellers, product categories, listings, warehouses, and fulfilment channels. Platforms are therefore expected to ensure compliance at scale, even when their seller base has uneven awareness, resources, and compliance capacity. This creates three governance concerns.
Platforms can require seller declarations and documents, but verifying genuine compliance across thousands of listings is difficult, especially when standards vary across product categories.
First, verification at scale. As BIS continues to update the list of products under compulsory certification and upcoming QCOs, compliance becomes a continuous monitoring obligation rather than a one-time listing check. Between 2019 and 2024, the number of QCOs reportedly surged from 88 to 765, turning standards compliance from a limited product-specific requirement into a broader market-wide obligation. Platforms can require seller declarations and documents, but verifying genuine compliance across thousands of listings is difficult, especially when standards vary across product categories.
Second, entry barriers for smaller sellers. BIS certification is not cost-free. It can involve testing, documentation, assessment of manufacturing and quality-control systems, and, in some cases, factory visits. Larger firms may be able to absorb these costs, but smaller manufacturers, importers, and MSMEs may struggle. Platforms may also become more selective while onboarding sellers or listing regulated products. This can turn standards into a market-structuring tool, not by design, but because larger firms are better placed to comply.
Third, platform compliance becomes private regulation. Marketplaces may delist products, demand additional documents, restrict onboarding, or prioritise sellers with stronger compliance records. This can support consumer safety, but it also means that public regulation is increasingly being enforced through private platform rules. As platforms gain wider discretion over seller access, listing approvals, and delisting decisions, there is also a risk of inconsistent or arbitrary treatment.
As platforms gain wider discretion over seller access, listing approvals, and delisting decisions, there is also a risk of inconsistent or arbitrary treatment.
This is especially difficult for smaller vendors who may lack the capacity to contest platform decisions. If a seller is delisted or prevented from onboarding, there should be a clear process to challenge the decision, correct documentation gaps, and seek reinstatement. Otherwise, quality control can become a one-sided compliance filter.
The Way Forward
Despite these challenges, QCOs remain legitimate and often necessary. The real question is how they are implemented. Standards must be proportionate, coordinated, and digitally manageable.
A practical middle ground would require better coordination between various stakeholders, phased implementation timelines, transition windows for affected sectors, targeted support for MSMEs, and a digital compliance infrastructure that allows platforms to verify BIS status more easily. BIS already provides tools such as Manak Online and the BIS Care App for checking licence and certification details. These could be strengthened into a more interoperable, platform-facing verification layer that allows marketplaces to check BIS licence numbers, product coverage, certification status, and validity in real time. This would reduce dependence on seller self-declarations and make compliance easier to operationalise at scale.
Enforcement should also be risk-based rather than one-size-fits-all. The objective should be to raise trust, not raise the cost of participation to a point where only the largest firms can comply comfortably. This is ultimately a marketplace governance question. Platforms now mediate compliance in practice. The issue is whether they have systems to identify regulated products, verify standards claims, respond to notices, remove non-compliant listings, and do so without arbitrary treatment of sellers.
Enforcement should also be risk-based rather than one-size-fits-all. The objective should be to raise trust, not raise the cost of participation to a point where only the largest firms can comply comfortably.
As platforms become the de facto enforcement layer, standards policy begins to overlap with competition, due process, and platform fairness. Several safeguards are essential: compliance rules must be transparent to sellers, takedowns must be appealable, and similar sellers must be treated consistently. Larger vendors should not receive preferential treatment merely because they are easier to verify. E-commerce policy must therefore balance consumer protection with market access, MSME participation, and fair platform governance.
Standards are necessary in digital marketplaces because trust must be institutionalised rather than assumed. But as QCOs expand, platforms are becoming the operational layer of quality-control enforcement — a role that must be designed with care. Systems to identify regulated products, verify compliance, and remove unsafe listings are essential, but they must be equally transparent, reviewable, and proportionate. Otherwise, QCOs risk raising consumer trust while simultaneously raising the cost of market participation for smaller sellers.
Basu Chandolais an Associate Fellow at the Observer Research Foundation.
AI disclaimer:
The Author acknowledges the use of ChatGPT 5.5 for language refinements prior to the submission.
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Basu Chandola
Basu Chandola is an Associate Fellow at the Observer Research Foundation, where his work focuses on the governance of the digital economy, including artificial intelligence, …
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