Top Reasons Why Companies Surrender Their Cosmetic Registration Under CDSCO?

In India, every cosmetic product that is imported, manufactured, or sold must be registered with the Central Drugs Standard Control Organization (CDSCO) under the Drugs and Cosmetics Rules, 1945.

However, there are situations where companies voluntarily decide to surrender their cosmetic registration certificate. This article explains the top reasons why companies surrender their cosmetic registration under CDSCO, along with detailed insights, compliance requirements, and a few frequently asked questions.

What Does It Mean to Surrender Cosmetic Registration Under CDSCO?

Surrendering cosmetic registration means the company (importer, manufacturer, or authorized agent) officially withdraws its CDSCO Cosmetic Registration Certificate (Form COS-3) before its expiry or renewal period. Once surrendered, the registration becomes invalid, and the company can no longer import or market the concerned cosmetic products in India.

Top Reasons Why Companies Surrender Their Cosmetic Registration Under CDSCO

Here are the most common and valid reasons for surrendering a CDSCO cosmetic registration certificate:

1. Discontinuation of Product in the Market

One of the main reasons for surrendering the registration is the discontinuation of the cosmetic product.

This happens when:

• The company stops production or import of a particular product.
• The product fails to perform commercially in the Indian market.
• The brand plans to replace it with a new or reformulated version.

2. Change in Product Composition or Formulation

If a cosmetic product undergoes major reformulation or change in ingredients, the existing registration becomes invalid because the product’s composition no longer matches the details submitted to CDSCO. In such cases, companies prefer to surrender the old registration and apply for a new one with updated ingredient details

3. Change in Manufacturing Site or Brand Ownership

If there’s a change in manufacturing location, ownership transfer, or merger/acquisition, the old registration may no longer be valid.

To maintain compliance, companies surrender the previous registration and obtain a fresh one with updated manufacturer details.

4. Non-Compliance or Regulatory Violations

Sometimes, CDSCO may issue notices or warnings if a product violates safety standards or labelling norms. In such cases, companies may voluntarily surrender the registration to avoid further legal complications, penalties, or suspension orders.

5. Expiry or Non-Renewal of License

Cosmetic registration certificates are valid for 5 years.

If a company decides not to renew the registration after expiry, it must officially surrender the license to CDSCO instead of letting it lapse.

6. Strategic Business or Marketing Decision

Companies often restructure their product portfolio or change their business direction.

To focus on high-demand products or different markets, they may choose to withdraw certain cosmetic lines and surrender those registrations.

7. Product Recall or Safety Concerns

If there are adverse reactions, contamination issues, or safety alerts associated with a cosmetic product, companies may voluntarily recall and surrender the registration to protect consumer trust and comply with CDSCO safety norms.

How to Surrender Cosmetic Registration Under CDSCO?

To surrender a cosmetic registration, the following steps are generally followed:

1. Prepare a formal surrender letter addressed to the CDSCO stating the reason for surrender.
2. Attach the original CDSCO Registration Certificate (Form COS-3).
3. Include product details such as product name, registration number, and import license number.
4. Submit to the CDSCO office (HQ or Zonal Office) where the registration was initially obtained.
5. Await official acknowledgement or confirmation of surrender from CDSCO.

Conclusion

Surrendering cosmetic registration under CDSCO is a formal process undertaken when a company discontinues a product, changes formulation, faces regulatory issues, or realigns its business strategy. Whatever the reason, it must be done transparently and officially to maintain compliance with Indian cosmetic regulations. Properly managing registration surrenders helps companies avoid legal risks, maintain brand credibility, and ensure smooth regulatory relations with CDSCO.