Ask a brand what went wrong with their first Indian launch and you rarely hear a story about the formula. You hear about artwork.
Two separate legal frameworks govern what appears on an Indian pack. CDSCO enforces cosmetic labelling under the Drugs and Cosmetics Act and the Cosmetics Rules, 2020. Legal Metrology enforces a second, overlapping set of declarations applying to all pre-packaged commodities. Satisfying one does not satisfy the other.
Here is an Indian cosmetic label, element by element, with the difference from an EU pack at each point.
Product name and function
Familiar territory, with one caveat that dominates everything else: the claim decides the category.
Products claiming to treat acne, dandruff, fungal or bacterial infection, hair regrowth, eczema, psoriasis or pigmentation disorders, or to prevent skin cancer, are not cosmetics under Indian law. Neither are pain relief balms or medicated shampoos sold on a treatment promise.
An EU pack often carries claims that sit comfortably under Regulation 1223/2009 and push a product straight out of the cosmetic category in India. Review claims first, because reclassification invalidates the entire file.
Ingredient declaration
Required in descending order of quantity, recognisably similar to the EU approach, with thresholds by pack size.
Two differences catch European brands. Ingredients banned or restricted in India do not map exactly onto the EU annexes, so verify against Indian restrictions rather than assuming equivalence. And the list printed on the pack must match the formulation in the dossier exactly — a supplier substitution that never reached the regulatory file shows up here.
Net quantity
Legal Metrology territory. The declaration must appear in prescribed units, format and position. It reads as trivial and produces objections anyway, because the rules specify not just the number but how it is presented.
Maximum Retail Price
There is no EU equivalent, and it surprises brands every time.
Pre-packaged goods sold in India must carry the maximum retail price, inclusive of all taxes. It is printed on the pack, and retailers cannot lawfully sell above it.
The commercial consequence is that pricing becomes a printing decision. Repricing means new artwork, over-stickering or new stock. Brands used to markets where the retailer sets the shelf price discover this after the first print run.
Manufacturer, importer and country of origin
An EU pack names the Responsible Person. An Indian pack must identify the importer, and imported products must state the country of origin.
Behind the label sits a structural requirement: a foreign manufacturer cannot register anything directly. You must appoint an Authorized Indian Agent — a local agent or Indian subsidiary — who files the application, communicates with CDSCO and handles post-market obligations including withdrawals and recalls. That authorization must be authenticated, either before a magistrate in India or in the country of origin.
The authentication step takes time and belongs at the start of the project. And because registration is held through that agent, the terms of the relationship deserve scrutiny as a market-access asset.
Dates and batch
Batch number, date of manufacture and expiry or best-before date are all required. The EU’s period-after-opening symbol does not substitute for a date declaration.
Consumer care details
A contact point for consumer complaints must appear on the pack. Straightforward to satisfy, easy to omit, and it means the Indian importer’s contact details need to be settled before artwork is finalised.
Why this sequencing matters
Standard CDSCO registration runs approximately 60 working days with complete documentation, plus 20 working days if laboratory testing is required. It is submitted through the CDSCO SUGAM portal using the COS-1 and COS-2 applications, with manufacturer and agent details, product and brand lists, formulations, the manufacturing licence and Free Sale Certificate from the country of origin, testing methods and safety data.
Artwork sits inside that file. Change the label after submission and you are amending an application under review.
The efficient order is therefore: classify the product, review claims against that classification, appoint and authenticate the agent, settle importer details and MRP, finalise artwork, then compile. Brands that do artwork last, as they would for an EU launch, tend to go around twice.
Where outside help pays for itself
Consultancies working on cosmetic regulations in India typically cover product classification, formula and labelling review, CDSCO registration, testing coordination, responsible person services and Legal Metrology support. That last item is the one European brands most often do not know they need — it is a separate compliance track from the cosmetic registration itself, and it is enforced separately.
After the certificate
Products entering large-scale retail and e-commerce distribution attract growing scrutiny on ingredient safety, microbiological quality and heavy metal limits, and label compliance is checked at the border as well as in the market.
A product that clears registration can still be stopped at customs over a declaration nobody thought to check.
