An overseas skincare brand may have appointed an Indian distributor, completed its commercial agreement and scheduled the first shipment. However, if its products, variants or manufacturing site are not covered by a valid CDSCO Import Registration Certificate, commercial import cannot be treated as ready.
This issue has become more important following CDSCO’s 22 July 2026 circular directing regulators and port officers to increase surveillance against imported cosmetics sold or entering India without valid registration.
A CDSCO cosmetic import registration consultant in India helps a manufacturer or importer determine the correct application route, prepare Form COS-1, map products to the applicable categories, verify ingredients and labels, calculate government fees, respond to CDSCO queries and maintain the registration after approval.
For most new applications, the process involves applying through the SUGAM portal in Form COS-1 and obtaining the Import Registration Certificate in Form COS-2 from the Central Licensing Authority.
Cosmetics imported for sale and use in India are regulated under the Drugs and Cosmetics Act, 1940 and the Cosmetics Rules, 2020. The Drugs Controller General of India, functioning through CDSCO, acts as the Central Licensing Authority for cosmetic imports.
Rule 12 of the Cosmetics Rules provides that a cosmetic cannot be imported unless it has been registered by the Central Licensing Authority. The registration is connected not only to the product name, but also to its category, variant, pack size, manufacturer and manufacturing site.
The usual forms are:
Registration should be completed before commercial consignments are planned around an assumed approval date.
Registration should be evaluated when a business intends to import foreign-manufactured cosmetics for commercial sale or distribution in India.
Common applicants include:
The Cosmetics Rules permit the manufacturer, the manufacturer’s authorised agent, an importer in India or an authorised Indian subsidiary to submit Form COS-1. It is therefore incorrect to assume that only an Indian agent can be the applicant in every case.
The commercial decision should nevertheless consider who will control:
| Business situation | Application route | Outcome |
|---|---|---|
| Product or foreign manufacturing site is not registered | Form COS-1 | Form COS-2 |
| Product and site are already covered by a valid COS-2, but another importer wants to import them | Form COS-4 | Form COS-4A |
| Product qualifies as a new cosmetic | Form COS-12 first, followed by COS-1 after permission | Form COS-3, then COS-2 |
| Addition of products, pack sizes or manufacturing sites to an existing registration | Endorsement or amendment route on SUGAM | Updated regulatory coverage |
| Limited activity falling within a specific exemption | Examine Twelfth Schedule conditions | Registration may not apply if every condition is met |
A COS-4A route is available only where the cosmetic and foreign site are already registered under Rule 13 in a valid COS-2. COS-4A remains valid for three years unless suspended or cancelled.
A business should not select COS-4 merely because the brand has previously imported into India. The product, variant and manufacturing site must first be confirmed against the existing COS-2.
The Twelfth Schedule contains limited, conditional exemptions. These include specified situations involving:
These exemptions are narrow and condition-based. A business should not rely on an exemption merely because the quantity is small, the products are samples or they are not being sold through conventional retail channels.
The first review should assess the product’s intended use, composition, claims and presentation.
A product promoted for cleansing, beautifying, altering appearance or promoting attractiveness may fall within the cosmetic definition. A product making treatment, disease-prevention or body-function claims may require a different regulatory assessment.
This distinction is particularly important for products marketed using expressions such as:
CDSCO’s non-compliance guidance identifies drug-like or treatment-oriented label claims as a recurring problem in cosmetic applications.
The parties should decide whether the applicant will be:
Where an Indian agent is appointed, the manufacturer’s authorisation must comply with the authentication requirements under Rule 12 and the First Schedule. The official checklist requires the authorisation to identify the manufacturer, manufacturing site, Indian agent, products, variants and pack sizes and to be jointly signed and properly authenticated.
The applicant’s name and address should remain consistent across:
Before opening the SUGAM application, create a master spreadsheet with one line for every proposed product and variant.
Recommended fields include:
| Field | Why it matters |
|---|---|
| Brand and product name | Must remain consistent across every document |
| Cosmetic category | Determines category coverage and government fee |
| Variant, shade or flavour | Each variant may attract a separate fee |
| Pack size | Must match the application and supporting documents |
| Legal manufacturer | Establishes brand and regulatory responsibility |
| Actual manufacturer | Identifies the physical manufacturer |
| Manufacturing-site address | Each site must be correctly registered |
| Country of origin | Must align with regulatory and free-sale documentation |
| Free Sale Certificate reference | Demonstrates market status |
| Formula version | Prevents submission of an obsolete composition |
| Label version | Ensures the filed label is the intended Indian-market version |
Cosmetics must be classified according to the Fourth Schedule. Different shades, colours or flavours may be treated as variants for registration purposes.
The applicant should obtain the complete ingredient composition in recognised nomenclature, including the percentage of each ingredient.
The submission should be reviewed against:
The official checklist requires the ingredient nomenclature and percentages, proposed labels, product specifications, test methods and package inserts where applicable.
Hair-colour products require particular attention. CDSCO’s June 2026 circular refers to IS 4707 Parts 1 and 2, IS 8481 and the warning, patch-test and labelling provisions of Rules 34 and 37. It also requires relevant changes in composition, labels and specifications to be reported to the licensing authority.
Imported cosmetic labels generally need to be assessed for:
Rule 34 permits specified India-specific declarations to be added through labels at a bonded warehouse, but this should not be treated as a substitute for completing the regulatory label review before shipment.
The Cosmetics Amendment Rules, 2025 clarify that “use before” refers to use before the first day of the stated month, while the expiry date refers to expiry on the last day of that month.
| Foreign manufacturer or brand owner | Indian applicant | Joint or coordinated documents |
|---|---|---|
| Manufacturing licence or equivalent regulatory evidence | GST certificate | Form COS-1 |
| Free Sale Certificate or acceptable official alternative | IEC documentation | Product-category matrix |
| Complete ingredient composition | Applicant incorporation details | Manufacturer authorisation |
| Product specifications and test methods | Authorised-person details | Proposed Indian labels |
| Product and manufacturer declarations | Government-fee receipt | Correlation chart |
| Non-animal-testing undertaking | SUGAM account information | Product, variant and site list |
| Heavy-metal and restricted-substance undertaking | Indian importer information | Responses to CDSCO queries |
| Manufacturer and site details | Indian-market contact details | Change-control records |
The exact evidence depends on the manufacturer’s country, legal structure, product and available regulatory documentation. The checklist allows defined alternatives where the country of origin does not issue a conventional manufacturing licence or where a Free Sale Certificate is issued by another competent body, subject to the applicable declarations and authentication.
Government fees under the Third Schedule are based on categories, manufacturing sites and variants rather than a single flat registration amount.
| Fee component | Government fee |
|---|---|
| Grant or retention for each cosmetic category | USD 1,000 |
| Each additional category | USD 1,000 |
| Each manufacturing site | USD 500 |
| Each variant | USD 50 |
| Prior permission for a new cosmetic | USD 500 |
| Duplicate registration certificate | USD 200 |
| Inspection of each overseas manufacturing site, where required | USD 5,000 |
Fees may be paid in US dollars or the permitted equivalent in Indian rupees through the prescribed government mechanism. The INR equivalent should be calculated at the time of payment rather than inserted as a permanent figure in the article.
Professional consulting charges are separate from CDSCO government fees and depend on dossier size, number of products, sites, variants, documentation condition and the support required.
The application is submitted online through CDSCO’s SUGAM system.
The filing sequence generally includes:
The application should be filed only after the product matrix and supporting documents have been reconciled. Uploading documents first and attempting to correct inconsistencies later frequently creates avoidable queries.
CDSCO may issue observations asking for clarification, corrected documents or additional evidence.
A query response should:
A consultant cannot guarantee that CDSCO will not raise a query. The objective is to reduce preventable deficiencies and provide a complete, traceable response.
After approval, the business should verify that the granted COS-2 correctly covers:
Commercial shipment planning should use the granted coverage, not the scope originally requested in the application.
Rule 13 states that the Central Licensing Authority may grant Form COS-2 or reject the application for recorded reasons within six months from the application date. A rejection may be appealed within 45 days.
The six-month provision should not be presented as an approval guarantee. Actual elapsed time can be influenced by:
Consultants quoting a guaranteed 30-, 60- or 90-day approval should be asked to identify the official provision supporting that promise.
A COS-2 registration remains valid in perpetuity unless suspended or cancelled, subject to payment of the applicable retention fee before completion of each five-year period.
If the retention fee is not paid on time, the Rules provide a limited delayed-payment period with an additional fee. A compliance calendar should therefore begin from the date of grant rather than waiting until the fifth year.
Registration is not the end of compliance.
The Cosmetics Rules prescribe different actions for different changes:
These timeframes should be read with Rules 14 and 15 and any subsequent CDSCO clarification.
CDSCO’s own non-compliance document identifies recurring problems such as:
The practical lesson is that application quality depends on cross-document consistency, not simply the number of uploaded files.
Before filing, confirm that the answer to each question is “yes”:
Where several answers are “no,” filing should normally be postponed until the gaps are resolved.
This is an illustrative example and not a claim about a Green Permits client.
A foreign personal-care brand proposes to introduce 24 products manufactured at two facilities. Its catalogue appears to contain four categories, but the submission documents use different product names in the Free Sale Certificate, labels and manufacturer authorisation.
A pre-application review identifies that:
Instead of filing immediately, the company first creates a controlled product matrix, obtains corrected manufacturer documents, revises the claims and recalculates the fee. This does not guarantee approval, but it removes several predictable reasons for a CDSCO query.
A competent consultant should help the business with:
The consultant should distinguish between:
No consultant can lawfully guarantee approval or prevent CDSCO from asking for further evidence.
COS-2 addresses cosmetic import registration. It does not automatically complete every Indian market-entry requirement.
Depending on the transaction and packaging, the business may separately need to review:
Green Permits’ existing market-entry framework treats CDSCO, LMPC, DGFT and related approvals as connected but legally distinct requirements. Reviewing them together can reduce duplicated documentation and late-stage corrections.
Before submitting Form COS-1 or dispatching a commercial shipment, have the following reviewed together:
📞 +91 78350 06182
📧 wecare@greenpermits.in
👉 Book a Consultation with Green Permits
Rule 12 provides that cosmetics cannot be imported unless registered by the Central Licensing Authority, except where a specific exemption applies.
The manufacturer, its authorised Indian agent, an importer in India or an authorised Indian subsidiary may apply.
COS-1 is the application for import registration. COS-2 is the registration certificate issued by CDSCO.
Where the product and foreign manufacturing site are already covered by a valid COS-2, another importer may apply in COS-4 for an Import Registration Number in COS-4A.
