Form COS-4A Explained: Annual Details of Imported Cosmetics under 2020 Rules

The Indian cosmetic industry is growing rapidly, but each product imported in India should follow the cosmetic rules, 2020, under the Drugs and Cosmetics Act, 1940. These rules ensure that cosmetic products meet security, efficacy and quality standards before reaching Indian consumers. 

One of the compliance requirements for importers is filing Form COS-4A, which belongs to the annual presentation of the Import Registration Number (IRN) and the details of imported cosmetics. This process is an important part of CDSCO cosmetic import compliance and ensures transparency, traceability and proper monitoring of foreign cosmetics entering the Indian market.

What is Form COS-4A?

Form COS-4A is a mandatory compliance document under the Cosmetic Rules, 2020 (Rule 13(7)). It serves two purposes:

1. Grant of Import Registration Number (IRN): For the import of already registered cosmetics.
2. Annual Return Filing: Every importer must furnish annual details of all cosmetic consignments imported during the financial year.

This ensures that only registered and approved cosmetic products are imported into India. It is one of the most important steps in fulfilling the cosmetic import license requirements.

Purpose of Form COS-4A

• To maintain annual records of cosmetic imports.
• To ensure traceability of every consignment.
• CDSCO-approved import registration certificate (COS-1) to verify compliance.
• To prevent illegal or unregistered cosmetics from entering India.
• To support broader cosmetic regulatory compliance in India.

Who Needs to File COS-4A?

• Importers holding an Import Registration Certificate (COS-1).
• Authorized agents of foreign manufacturers registered with CDSCO.
• Companies importing cosmetics for commercial distribution or retail sales in India.

COS-4 vs COS-4A: Key Difference

Form No.	Purpose	Who Needs It	Filing Authority	Frequency / Validity
COS-4	Application for Free Sale Certificate (FSC) for cosmetics to be exported from India.	Exporters / Manufacturers	State Licensing Authority	Case-specific (validity depends on the requirements of the importing country).
COS-4A	Grant of Import Registration Number (IRN) and annual submission of imported cosmetic details.	Importers / Authorised Agents	CDSCO (Central Licensing Authority) via SUGAM Portal	IRN valid for 3 years; Annual return to be filed by 30th April each year.

Quick tip: COS-4 is for exports (FSC), while COS-4A is for imports (IRN + annual return). Both are part of the larger framework of COS forms under Cosmetic Rules 2020.

Documents Required for COS-4A Application

When applying for IRN under Form COS-4A, the following documents are required:

• Duly filled Form COS-4.
• Undertaking as per the Sixth Schedule.
• Copy of a valid Import Registration Certificate (COS-1).
• Importer Exporter Code (IEC) and GSTIN.
• Labels or artwork of the cosmetic product.
• List of registered products and registration certificate numbers.

Key Steps to File COS-4A

Step 1: Collect Import Data

• Number of consignments imported during the year.
• Bills of entry and shipping details.
• Quantity and cost of each consignment.
• Country of origin and port of entry.
• Warehousing or storage location in India.
• Distribution or sales details.

Step 2: Prepare Documentation

• Copy of IRN (COS-4A approval).
• Invoices, shipping bills, and bills of entry.
• Product-wise breakup of imports and sales.
• Safety and stability data, if required.

Step 3: Submit the Form via the CDSCO Portal

• Log in to the SUGAM portal.
• Fill Form COS-4A with complete import details.
• Uploadthe  required documents and submit them to CDSCO.

Step 4: Accept the record and maintain the record 

• Keep a copy of the submission acknowledgement.
• Keep the appropriate record for inspection by CDSCO or state officials. 

This step-by-step cosmetic annual return filing process ensures that your business remains in line with Indian law.

Validity & Timelines

• The import registration number (IRN) given under COS-4A is valid for 3 years, until suspended or cancelled.
• Annual return requirement: Each importer must file COS-4A returns before April 30 of the following year.
• Example: For imports made during FY 2024-25, COS-4A annual returns should be filed by 30 April 2025.
• Filing COS-4A annually is mandatory as long as the COS-1 remains valid.

Consequences of Non-Compliance

• Suspension or cancellation of the Import Registration Certificate (COS-1) or IRN (COS-4A).
• Seizure of imported consignments.
• Monetary penalties under the Drugs and Cosmetics Act.
• Loss of credibility and import restrictions.

How ELT Corporate Can Assist You

At ELT Corporate, we help cosmetic importers stay compliant by:

• Guiding you through the COS-4A application and filing process.
• Preparing and verifying annual import documentation.
• Submit applications via the CDSCO’s SUGAM portal.
• Handling follow-ups and compliance notices.
• Ensuring smooth approvals and zero regulatory risks.

FAQs

Which businesses need to file COS-4A?

All cosmetic importers holding an Import Registration Certificate (COS-1).

Is COS-4A required for domestic manufacturers?

No, it is applicable only for importers.

What is the validity of COS-4A approval?

The IRN granted under COS-4A is valid for 3 years.

When must the COS-4A annual return be filed?

By 30th April every year for the preceding financial year.

What happens if I miss the COS-4A filing?

Your COS-1 and IRN may be suspended, and imports may be blocked.

Can an agent file COS-4A on behalf of a foreign manufacturer?

Yes, authorised agents registered with CDSCO can file COS-4A.