India offers major opportunities for international skincare, makeup, fragrance and personal-care brands. However, every imported product that falls within the legal definition of a cosmetic must comply with India’s regulatory framework before entering the market.
The Central Drugs Standard Control Organization (CDSCO) regulates imported cosmetics under the Drugs and Cosmetics Act, 1940 and the Cosmetics Rules, 2020. Registration should be planned well before manufacturing launch stock, printing local packaging or confirming commercial delivery dates.
Confirm That the Product Is a Cosmetic
Classification depends on the product’s intended purpose, composition, presentation and claims. Products intended for cleansing, beautifying, promoting attractiveness or altering appearance generally fall within the cosmetic category.
Claims suggesting that a product treats, prevents or mitigates a disease, or affects the structure or function of the body, may move it outside the cosmetic framework. CDSCO has identified drug-like claims as a common source of non-compliance.
Brands should therefore review labels, websites, marketplace listings and campaign materials before submitting an application.
Choose an Eligible Indian Applicant
An application may be submitted by the foreign manufacturer, its authorised Indian agent, an importer or an Indian subsidiary authorised by the manufacturer.
Where an Indian representative files the application, formal authorisation is required. The document must accurately identify the manufacturer, production site, authorised party, products and variants. It may also require authentication, apostille or consular formalities, depending on how and where it is executed.
Commercial responsibilities should be agreed in advance, including control of the registration, renewals, regulatory correspondence and post-approval changes.
Define the Registration Scope Carefully
CDSCO requires the cosmetic product and its manufacturing site to be registered before import. The application must also identify relevant variants, pack sizes and sourcing locations.
A shade, fragrance or other variation may be treated as a separate variant. Errors at this stage can create difficulties when the commercial portfolio expands.
Before filing, prepare a structured list covering:
- product category;
- exact product name;
- formula and variants;
- available pack sizes;
- manufacturing site;
- proposed importer;
- country of origin;
- intended claims.
The same descriptions should appear consistently throughout the application, authorisation, Free Sale Certificate, labels and supporting records.
Apply Through Form COS-1
The application for imported cosmetic registration is submitted online through CDSCO’s SUGAM portal in Form COS-1. It is filed with the applicable government fees and supporting documents.
CDSCO reviews the application and may issue questions if records are missing or inconsistent. A clear dossier with logical file names, document references and correlation tables can make the assessment easier.
Where the submission is accepted, the Import Registration Certificate is issued in Form COS-2.
Understand How Form COS-2 Remains Valid
The original article described Form COS-2 as valid for five years. CDSCO’s current FAQ is more precise: the certificate remains valid in perpetuity unless suspended or cancelled, subject to payment of the prescribed retention fee before the end of each five-year period.
Brands should maintain a compliance calendar for retention payments and other obligations. Missing a required deadline can disrupt imports even when the product itself has not changed.
Build a Complete Supporting Dossier
The required documents depend on the application, but a cosmetics import dossier commonly includes:
- covering letter and application details;
- authenticated manufacturer authorisation;
- manufacturing-site information;
- Free Sale Certificate or equivalent evidence;
- complete product composition;
- product specifications and testing methods;
- labels and package inserts;
- manufacturing licence or market authorisation;
- declarations and supporting safety records;
- fee-payment documentation.
CDSCO’s published non-compliance examples show that mismatched product names, addresses, variants, pack sizes and manufacturing sites frequently generate problems.
Review Ingredients Against Indian Requirements
Products already sold in another market should still undergo an India-specific formula review. Imported cosmetics must comply with the standards referenced by the Cosmetics Rules, including relevant Bureau of Indian Standards requirements.
The assessment should cover prohibited and restricted substances, colours, pigments, preservatives and applicable heavy-metal limits. CDSCO documentation also refers to requirements concerning substances such as mercury, lead, arsenic and hexachlorophene.
Formula information and test specifications should be signed or approved by an appropriately authorised person from the manufacturer.
Address India’s Animal-Testing Restriction
CDSCO’s official cosmetics FAQ states that cosmetics tested on animals in the country of origin are not allowed for import into India.
Brands should confirm their testing history and obtain appropriate declarations before filing. This review should extend beyond the finished product where the requested documentation or supply-chain circumstances require further clarification.
Unsupported “cruelty-free” marketing statements should also be avoided unless the brand can substantiate them across the relevant product and supply chain.
Prepare India-Compliant Labels
Packaging must satisfy the labelling requirements of the Cosmetics Rules and any other applicable Indian legislation. Depending on the product, required information may include:
- product name;
- manufacturer’s name and address;
- batch identification;
- manufacturing or registration details;
- expiry or use-before information;
- net contents;
- directions and warnings;
- importer information.
Labels must be legible and consistent with the registered product. Certain ingredients require specific cautions or instructions. Artwork should be reviewed before mass printing, while any over-labelling approach should be confirmed as legally acceptable for the product and import route.
Build the Regulatory Timeline Into the Launch Plan
CDSCO’s 2025 Citizen’s Charter lists a target internal timeline of 180 working days for fresh COS-1/COS-2 registrations, endorsements and re-registration. Queries or additional assessments can extend the practical schedule.
Registration should therefore begin before finalising launch campaigns, retailer commitments or shipment bookings. Time should also be reserved for document authentication, laboratory work, label corrections and responses to CDSCO questions.
Maintain Compliance After Registration
Approval is not the end of the process. Changes to the formula, manufacturer, production site, pack size, variant, label or sourcing location may require notification, endorsement or prior approval.
Brands should keep technical records current, monitor retention deadlines and ensure that imported batches match the registered specifications. Companies seeking support with these steps can consult specialists familiar with cosmetic regulations in India.
