Common Mistakes When Applying For Form COS-1 In India

Mistakes when applying for form COS-1 can lead to unintended delays, denials, and unwanted legal issues for a business in India. COS-1 is the form used to apply for cosmetic import registration in India under the CDSCO. Filing a change of particulars under GST might be conceptually simple and filing a simple form, but often mistakes and errors made by applicants themselves result in losses and complications.

In this article, we identified the typical errors made by businesses and individuals related to filing COS-1 and associated guidance on avoiding these costly mistakes.

What Is Form COS-1?

The COS-1 form is the application to obtain a license to import cosmetics in India. The form needs to be filled properly and accompanied by the proper documents like product details, facility layout, standard operating procedures (SOPs), safety, and details of qualifications of the technical personnel.

Why Is It Necessary To Apply For Form COS-1?

Form COS-1 is required by anyone who wishes to legally import cosmetics in India. This form is an official application for permission to apply for a license from the Central Drugs Standard Control Organization, which confirms that all cosmetic products meet safety, quality, and labeling requirements as governed by the Indian government. If Form COS-1 is not approved, you cannot legally sell or supply cosmetic products in India. This application provides consumer protection to check that cosmetics are safe based on the Drugs and Cosmetics Act, 1940. Thus, if you want to legally access and do business in the Indian cosmetic market without breaching penal Laws, you will need to apply for Form COS-1.

Top 8 Mistakes To Avoid When Applying For Form COS-1?

Here are the most common mistakes that cosmetic importers make while applying for form COS-1, such as:

Incomplete Application Form

Be careful applying on the Form COS-1, as it may result in submitting an incomplete application form. For example, some of the optional details of the application form (i.e., the facility address, product type, ownership) were left blank will result in immediate rejection.

Incorrect Or Missing Documents

Many applicants leave out submitting either proof of ownership, layout, etc, or sometimes the qualifications of the technical person. If you are missing just one document, it will severely impact time limits for getting the permit.

Submission Of Outdated Or Wrong Forms

Some applicants submit an old form, or even a completely different form (a good example is Form 31 or Form 32, which are both drug-related).   These errors will result in unnecessary delays.

Errors In Product Listing

Many applicants have provided incorrect products, incorrect names, incorrect categories (for example, a medicinal product as a cosmetic), or even missed listing variants.

Failure To Comply With Labelling

Cosmetic products must comply with certain labelling standards, like including ingredient lists, batch numbers, expiry dates, manufacturer, etc.  Many applications get flagged due to incorrect labelling formats.

Ignoring State-Specific Rules

Licensing rules may be a little different in each Indian state. Some states will require additional documents, site visits, or even local approvals before a licensing approval.

Not Paying The Correct Fees

Some applicants either underpay or forget to include proof of payment.  If there are no correct fees, the application cannot move further for processing. 

Failure To Follow Up

Submitting your application is just the start; you must follow up with the licensing authority and respond to any queries or objections.  If you simply apply and disappear, then your application may stall or be rejected.

How To Avoid These Mistakes When Applying For Form COS-1

To ensure a successful application process, follow these practical tips:

• Check Consistency: Ensure that the name and address of the applicant, manufacturer, and agent are identical across all documents, including Form COS‑1, FSC, and authorization letter.
• Correct Authorization: Always include an apostilled manufacturer authorization letter that mentions all product names or variants.
• Fee Accuracy: Refer to the latest CDSCO fee structure and use the Bharatkosh portal to pay. Upload the correct payment proof with your form.
• Free Sale Certificate: Ensure the FSC is valid, colored, and matches the exact product names listed in Form COS-1.
• INCI Compliance: Verify that the submitted ingredient list followed the International Nomenclature of Cosmetic Ingredients (INCI) and concentration percentages.
• Testing Declarations: Signed declarations including non-animal testing, heavy metals, and hexachlorophene, along with supporting lab documents.
• Label Requirements: sample labels according to Indian Cosmetic Rules that indicate MRP, batch no., importer name and address, expiry/manufacture dates.
• Submit All Test Protocols: include all validated methods you used to test your product quality and safety, which need to be signed by a competent technical authority.
• Use the Sugam Checklist: please read through the checklist from the CDSCO Sugam Portal, printed checklist item by item. This is important to ensure you include all the information in your submission before the final submission.

How ELT Corporate Can Help?

At ELT Corporate, we specialize in providing practical support to remove the headache and time required to complete your Form COS-1 application. We can provide advice and drafting for your paperwork, we check all forms and certificates, help with payments and submission through CDSCO Sugam, and we provide general assistance to help you become regulatory compliant so that you do not become delayed or ejected. We can also provide a full end-to-end service from application to compliance, so you have the confidence that you can legally grow your cosmetics business.

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