CIB&RC · Maintenance
Registration certificates go stale quietly. A company renames, an office moves, a business is acquired — and the paperwork stops matching reality.
What is an endorsement application?
An endorsement application asks CIB&RC to record a change in the particulars of an existing registration — company name, address, factory location, source of import, supplier, label or leaflet. Under Rule 6B of the Insecticides Rules, 1971 a fee of Rs. 100 applies to addition, deletion or alteration on the certificate of registration, including labels and leaflets.
Why stale particulars cause real problems
A registration certificate is checked against other documents at exactly the moments when you cannot afford a discrepancy: at customs clearance, at inspection, during due diligence on a transaction, and when a State authority processes a licence.
If the name on the certificate no longer matches the name on your invoices, or the factory address is one you left two years ago, the mismatch has to be explained at the worst possible time. The endorsement that would have prevented it is a modest application.
Changes that require endorsement
| Change | Why it matters |
|---|---|
| Company name | Certificate must match invoices, licences and shipping documents |
| Registered office address | Correspondence and legal service; appears on the certificate |
| Factory or manufacturing address | Ties to State manufacturing licence and inspection |
| Source of import | Customs is directed to allow import only from the named source |
| Supplier | Where named, material must route through that supplier |
| Transfer following acquisition or merger | The registration is an asset; it must follow the business lawfully |
| Label or leaflet | Rule 6B covers alteration including labels and leaflets |
| Shelf life, packaging or formulation details | Certificate particulars must reflect the approved product |
The timing rule that strands consignments
For anything touching import, this is the point to internalise. CIB&RC's checklist for customs directs that where there is any variation in the name or address of either the source of import or the supplier, and the registrant has not obtained endorsement of that change from the Secretary, CIB&RC before the import, such import should not be allowed.
The endorsement must pre-date the shipment. Not the arrival, not the filing of the bill of entry — the import. A supplier renamed after a corporate restructuring, or a group affiliate shipping in place of the named entity, is enough to hold a container while demurrage accrues, and the position cannot be regularised retrospectively as a matter of routine.
Transfers on acquisition
When a business changes hands, its registrations are among the assets that determine whether the acquirer can actually operate. Two failures recur:
- Diligence that checks existence but not currency. A certificate exists, so it is ticked off. Nobody checks whether the particulars on it still match the entity, the factory and the supply chain.
- Transfer left until after completion. The seller's cooperation is readily available before completion and markedly less so afterwards. Sequence the transfer applications into the transaction timetable.
Documents typically required
- Application for endorsement referencing the registration certificate number
- Copy of the existing certificate of registration
- Evidence of the change — certificate of incorporation on name change, board resolution, merger or scheme order, lease or property documents for an address change
- Updated GST registration and other statutory registrations reflecting the change
- Revised labels and leaflets where the change affects them
- Prescribed fee under Rule 6B
Keeping a portfolio current
Companies holding more than a handful of registrations benefit from treating maintenance as a scheduled activity rather than an exception. We maintain registers for clients covering certificate numbers, particulars as recorded, source and supplier details, and validity, and raise endorsements when a corporate change occurs rather than when a consignment is held.
Most endorsement emergencies are record-keeping failures rather than regulatory problems, and they are almost entirely avoidable.
Frequently Asked Questions
What does an endorsement cost?
Under Rule 6B of the Insecticides Rules, 1971 a fee of Rs. 100 applies to addition, deletion or alteration on the certificate of registration, including labels and leaflets. Under Rule 6A the same fee applies to a duplicate certificate where the original is defaced, damaged or lost. Confirm current amounts before filing, as fees are amended from time to time.
We changed our company name six months ago. Is that a problem?
It should be corrected promptly. Until the certificate is endorsed, your registration is in a name that no longer matches your invoices and licences, which creates difficulty at customs, at inspection and in any transaction diligence.
Can I import while an endorsement is pending?
Not where the endorsement concerns the source of import or supplier. Customs is directed to disallow import where the name or address has varied and endorsement was not obtained before the import. Plan inventory to bridge the period.
Do registration certificates need renewal?
Certificates are checked against any validity date shown on them. CIB&RC's customs checklist directs that where no validity date is mentioned, the certificate be treated as a permanent document. What does require attention is keeping the particulars on it current.
What happens to registrations when a company is acquired?
They need to be transferred or endorsed to reflect the new holder. Sequence this into the transaction timetable, because the seller's cooperation is much easier to obtain before completion than after.
Reviewed: 22 September 2026 · Reflects the Insecticides Act, 1968 and Insecticides Rules, 1971 as amended, including the Insecticides Third (Amendment) Rules, 2026 (G.S.R. 597(E) dated 8 July 2026). General guidance only — confirm current requirements before acting.
Corporate change affecting your registrations?
Send us your certificate list and what has changed. We will tell you which endorsements are needed and in what order.
Talk to Our Regulatory Team