India’s cosmetics market is one of the fastest-growing in the world — projected to reach $20 billion, driven by a rising middle class, growing beauty consciousness, and an explosion in D2C and e-commerce channels. For international cosmetic brands, exporters, and manufacturers, this growth represents a compelling market entry opportunity.
But entering India’s cosmetics market legally requires one non-negotiable step: obtaining a CDSCO Import Registration Certificate (Form COS-2) by submitting Form COS-1.
No cosmetic shall be imported into India unless the product is registered under the rules by the Central Licensing Authority. All cosmetic products must be registered with CDSCO before import and sale in India. Informal market access routes or ‘import first, register later’ approaches are not permitted or ‘import first, register later’ approaches are not permitted. CDSCO regulations do not permit post-import registration, meaning cosmetic products cannot be imported first and registered later.
This guide is written specifically for international cosmetic exporters — brands, manufacturers, and trading companies based outside India — who want a clear, accurate understanding of exactly what is required, how the process works, and how to avoid the documentation mistakes that delay approvals by months.
Understanding the Indian Cosmetics Regulatory Framework
Before diving into the application process, international exporters need to understand the two-layer regulatory structure that governs cosmetics in India:
| Activity | Regulatory Authority | Applicable Law | Form |
| Importing cosmetics into India | CDSCO — Central Licensing Authority (DCGI) | Drugs and Cosmetics Act, 1940 + Cosmetics Rules, 2020 | COS-1 → COS-2 |
| Manufacturing cosmetics in India | State Licensing Authority (SLA) | Drugs and Cosmetics Act, 1940 + Cosmetics Rules, 2020 | COS-5 / COS-8 |
For international exporters supplying cosmetics to India, CDSCO is the primary regulatory authority. The Drugs Controller General of India (DCGI) at CDSCO Headquarters, New Delhi, is the Central Licensing Authority who grants the Import Registration Certificate.
Critical rule for international exporters: Foreign cosmetic manufacturers cannot apply directly to CDSCO. You must appoint an authorized Indian entity — an Authorized Indian Agent or Indian importer — to hold the import registration on your behalf and apply through the SUGAM portal.
What Is Form COS-1 and What Is Form COS-2?
These two forms are often confused — and understanding the distinction is foundational:
- Form COS-1 — the application for import registration. Submitted online by the Indian importer or authorized agent on the SUGAM portal (cdscoonline.gov.in). Contains manufacturer details, product details, ingredient list, variants, pack sizes, and all supporting documents.
- Form COS-2 — the Import Registration Certificate issued by CDSCO after reviewing and approving the COS-1 application.This is the Import Registration Certificate required for legal import of cosmetics into India.
The COS-2 certificate allows importers to import only those cosmetic products that were included in the approved COS-1 application. Any product, variant, shade, pack size, or manufacturing site not listed in the approved COS-1 cannot be imported under that COS-2 certificate.
Who Can Apply — and Who Cannot
An application for COS-1 can be made by:
- Foreign manufacturers must apply through an Authorized Indian Agent or Indian importer registered on the SUGAM portal.
- An Authorized Indian Agent appointed by the foreign manufacturer
- An Indian importer authorized by the foreign manufacturer
- An Indian subsidiary of the foreign manufacturer, authorized in writing
In practice, the vast majority of international exporters entering India appoint either an Authorized Indian Agent (a regulatory consultant or services company) or an Indian importer/distributor to hold the COS-2 licence and manage compliance on their behalf.
Choosing the right Indian entity to hold your COS-2 is a strategic decision — not just an administrative one. The holder of the COS-2 is legally responsible for import compliance, label compliance, adverse event reporting, and regulatory obligations. Choose carefully.
Which Products Require COS-1 Registration?
Any article falling within the definition of cosmetic under the Drugs and Cosmetics Act, 1940 — intended to be rubbed, poured, sprinkled, sprayed on, or applied to the human body for cleansing, beautifying, promoting attractiveness, or altering appearance — requires registration before import.
This includes all products in categories such as:
| Category | Examples |
| Skincare | Moisturisers, serums, face oils, toners, eye creams, face masks |
| Colour Cosmetics | Foundations, lipsticks, eyeshadows, blush, mascara, nail colour |
| Haircare | Shampoos, conditioners, hair serums, scalp treatments, hair colour |
| Sun Care | Sunscreens (SPF products), after-sun, self-tanners |
| Personal Care | Body lotions, shower gels, deodorants, intimate care |
| Fragrances | Perfumes, EDTs, EDPs, body mists |
| Baby Care | Baby lotion, baby shampoo, baby oil, baby powder |
| Oral Care | Toothpastes, mouthwashes, teeth whitening products |
| Organic / Natural | ECOCERT/COSMOS certified products, herbal cosmetics |
Each product must be registered along with its pack size, variant(s), shades, and manufacturing premises. A single COS-1 application may cover multiple products depending on category, manufacturer, and CDSCO guidelines, and may include multiple variants and manufacturing sites. — subject to applicable government fees. This consolidation can significantly reduce cost and administrative burden for international exporters with wide product ranges.
Documents Required: The Complete Checklist for International Exporters
Documentation preparation is the most time-intensive and error-prone part of the COS-1 process. Most application delays occur not because of product quality, but due to documentation gaps or inconsistencies. Even small discrepancies — mismatched manufacturer names, incorrect ingredient nomenclature, or incomplete declarations — can result in formal CDSCO queries.
1. Authorization Letter (First Schedule) — Most Scrutinised Document
This authorizes the Indian importer or agent to apply for import registration on behalf of the foreign manufacturer. CDSCO’s requirements are specific:
- Must be on the manufacturer’s official letterhead
- Must name the specific Indian entity being authorized (importer or agent)
- Must list the specific products and manufacturing site(s) covered
- Must be authenticated by one of:
- A First Class Magistrate in India, OR
- The Indian Embassy in the country of origin, OR
- Notary Public + Apostille (for Hague Convention member countries)
- All details in the Authorization must match the COS-1 form exactly
2. Free Sale Certificate (FSC)
Confirms your cosmetic products are freely sold in their country of manufacture. CDSCO requirements:
- Issued by the competent authority in country of origin
- Authentication pathway — one of:
- Indian Embassy of country of origin, OR
- Chamber of Commerce + Apostille, OR
- Notary Public + Apostille
- Product list on FSC must be signed and stamped by the issuing authority
- Must cover all products and variants listed in your COS-1 application
The correlation between products listed in COS-1, the FSC, and the Authorization must be documented in your covering letter — CDSCO specifically requires a correlation chart.
3. Manufacturing Licence of Overseas Manufacturer
A copy of your manufacturing licence to produce cosmetics in your country. Where no such licensing provision exists in the country of origin, a declaration from the importer to this effect — acceptable to CDSCO — must be provided instead.
4. Complete INCI Ingredient List
The full ingredient list in descending order of concentration using correct INCI (International Nomenclature of Cosmetic Ingredients) nomenclature. Every ingredient must be checked against:
- BIS IS 4707 (Part 2): 2025 — revised list of prohibited, restricted, and GNRAS ingredients (updated August 2025)
- BIS IS 4707 (Part 3): 2025 — permitted preservatives with concentration limits (new standard, September 2025)
- The Ninth Schedule of Cosmetics Rules, 2020 — permitted colours and pigments
Any prohibited ingredient requires reformulation before registration. Restricted ingredients must be within permitted concentration limits — with safety data supporting the usage level if near the limit.
5. Product Labels / Proposed Artwork for Indian Market
Your Indian market label must comply with Cosmetics Rules, 2020 and Legal Metrology (Packaged Commodities) Rules, 2011. Mandatory elements:
- Product name and generic category
- Brand name
- Complete INCI ingredient list in descending order
- Manufacturer name and address (“Manufactured by: [overseas manufacturer]”)
- Importer name and address (“Imported by: [Indian entity]”)
- COS-2 registration number (added after approval)
- Net weight/volume
- Manufacturing date and expiry / best before date
- Batch number
- MRP inclusive of all taxes
- Country of origin
- Directions for use and precautions (where applicable)
6. Certificate of Analysis (COA)
For each product, confirming it meets quality specifications — including heavy metals declaration where required by CDSCO.
7. Undertaking / Self-Declaration (Schedule D-III)
A signed commitment to comply with all conditions of the registration certificate under Cosmetics Rules, 2020 — including adverse event reporting, market withdrawal procedures, and compliance with Indian standards.
8. Animal Testing Declaration
Under Cosmetics Rules, 2020, any cosmetic whose manufacture involves animal testing after 12th November 2014 cannot be imported into India. A declaration confirming no animal testing post this date is required for all applications.
Step-by-Step: The Complete COS-1 Application Process
1
Appoint Your Indian Authorized Agent or Importer
Select your Indian entity — authorized agent, importer, or subsidiary — who will hold the COS-2 licence and apply on your behalf. This entity must have a valid SUGAM portal account, active GST registration, and IEC (Import Export Code). Execute the Authorization Letter in their name and get it authenticated via the appropriate pathway for your country. This single document is the most frequently rejected in CDSCO review — get the format and authentication exactly right.
2
Obtain and Authenticate the Free Sale Certificate
Obtain the FSC from the competent authority in your country of origin — typically the health ministry, trade ministry, or chamber of commerce depending on your country. Confirm which authentication pathway applies for your country (Indian Embassy, Chamber of Commerce + Apostille, or Notary + Apostille). Ensure the FSC product list is signed and stamped, and covers every product and variant in your planned application. This process can take 4–8 weeks depending on your country — start early.
3
Prepare Your INCI Ingredient Lists and Compliance Check
Compile the complete INCI ingredient list for every product in descending order of concentration. Check every ingredient against BIS IS 4707 (Part 2): 2025 (prohibited/restricted ingredients) and IS 4707 (Part 3): 2025 (permitted preservatives). Flag any restricted ingredients and confirm usage concentrations are within permitted limits. Any prohibited ingredient requires reformulation before applying — there is no waiver process. This compliance check must be completed before the COS-1 form is filled, since the ingredient list is entered directly into the portal.
4
Design Your Indian Market Labels
Prepare Indian market label artwork for all products and variants. Every mandatory element listed under Cosmetics Rules, 2020 and Legal Metrology Rules must be present. Labels must not contain drug claims, therapeutic claims, or unsubstantiated organic/natural claims. For colour cosmetics: each shade must be listed separately with its colour index number where applicable. Labels are reviewed by CDSCO as part of the COS-1 submission — non-compliant labels are a common query trigger.
5
Register on SUGAM Portal and File COS-1
Your Indian agent or importer registers on cdscoonline.gov.in as an importer. Once the account is approved (3–5 working days), they access Form COS-1 and enter: manufacturer and manufacturing site details, product name, brand name, product category, pack sizes and variants, INCI ingredient list for each product, and labelling information. Upload all supporting documents — authorization, FSC, manufacturing licence, COA, labels, undertaking, and animal testing declaration. Pay the government fee through Bharatkosh gateway. Confirm the SRN (Service Request Number) after submission.
6
CDSCO Review and Query Handling
CDSCO reviews the submitted application. If deficiencies are found — document authentication issues, ingredient compliance questions, label non-compliance, or data mismatches — a formal query is raised through the SUGAM portal. Respond completely and promptly. Each query cycle adds 4–8 weeks. Partial responses lead to repeat queries — the most common cause of extended timelines. Ensure your Indian agent monitors the portal dashboard regularly and has all original documents accessible for immediate reference.
7
Receive COS-2 and Prepare for First Import
Once CDSCO is satisfied, the COS-2 Import Registration Certificate (required for legal import of cosmetics into India) is issued and available on the SUGAM dashboard. The certificate is generally valid for 5 years from the date of issue. Add the COS-2 registration number to your Indian market labels. Prepare your commercial invoice, packing list, and shipping documents with the COS-2 number — it must be cited at customs for clearance of each shipment. Your first legal shipment to India can now proceed.
Government Fee Structure
| Application Type | Fee |
| Import Registration — per product category (brand) | USD 250 per category |
| Additional variants within same category | Applicable per variant as specified |
| Payment gateway | Bharatkosh only (Head of Account “0210041040000-00-1”) |
Note: Fee structures are revised periodically. Verify current applicable fees with CDSCO or your regulatory consultant before applying.
Realistic Timeline for International Exporters
| Stage | Estimated Time |
| Authorization Letter execution and authentication | 2–4 weeks |
| Free Sale Certificate authentication | 4–8 weeks (country-dependent) |
| INCI compliance check and label preparation | 2–4 weeks |
| SUGAM account approval | 3–5 working days |
| COS-1 application review by CDSCO | 3–6 months (complete, compliant dossier) |
| Query response and re-review | +4–8 weeks per query cycle |
| Total realistic timeline | 6–9 months from start to COS-2 in hand |
Practical advice: Begin your COS-1 process at least 9 months before your planned India market launch. The FSC authentication from overseas — particularly through Indian Embassies — is often the longest single lead-time item.
Country-Specific Notes for International Exporters
South Korea (K-Beauty Brands)
South Korea is a Hague Convention member — Apostille authentication is available and accepted by CDSCO for Authorization Letters and FSCs. South Korean cosmetics are extremely popular in India — however, CDSCO applies the same BIS IS 4707 ingredient standards to all products regardless of origin, and some K-Beauty ingredients that are routine in Korean regulations may require additional safety documentation in India.
France / EU (European Luxury and Mass Beauty Brands)
EU manufacturers can use Apostille authentication. EU GMP-compliant manufacturing documentation is generally robust for CDSCO’s manufacturing licence requirement. Note that EU cosmetic ingredient nomenclature may differ slightly from INCI — verify all ingredient names are in correct INCI format before submission.
United Kingdom (Post-Brexit)
UK is a Hague Convention member — Apostille authentication available. UK MHRA Free Sale Certificates are generally accepted by CDSCO when properly authenticated.
United States
The US does not issue standardized FSCs through a single federal authority — typically obtained through the FDA or State authorities depending on product type. Authentication through the Indian Embassy in Washington DC or applicable consulates, or via Notary + Apostille (US is a Hague Convention member), are both accepted pathways.
Japan (J-Beauty Brands)
Japan is a Hague Convention member. Japanese cosmetics regulations are stringent — Japanese manufacturing documentation is generally strong for CDSCO review. Ingredient lists may need careful verification as Japanese INCI usage can differ from the international standard in some product categories.
Most Common Mistakes International Exporters Make
| Mistake | Impact | Prevention |
| Authorization letter not properly authenticated | Most common rejection reason — entire application stalled | Use correct authentication pathway for your country, verify format against First Schedule |
| FSC does not cover all products in COS-1 | CDSCO query — correlation gap | Build FSC product list before finalising COS-1 product list |
| Prohibited ingredient in formulation | Application rejected — reformulation required | Complete IS 4707 compliance check before any document preparation |
| Manufacturer name spelled differently across documents | Immediate CDSCO query — consistency is mandatory | Use exact legal name consistently across all documents |
| Label missing mandatory elements | CDSCO query, label revision required | Label compliance review before submission |
| Products added after COS-2 issued without amendment | Importing unlisted products is a regulatory violation | File COS-1 amendment for new products before importing |
| Importing before COS-2 is issued | Customs seizure, financial loss | Never ship to India without valid COS-2 in hand |
Post-Registration Compliance Obligations
Obtaining the COS-2 is not the end of your regulatory obligations — it is the beginning of ongoing compliance:
- COS-2 validity: Generally 5 years — renewal must be applied before expiry.
- Adverse event reporting: Any market withdrawal, regulatory restriction, or “not of standard quality” report from any country where the cosmetic is sold must be reported to CDSCO. Despatch and marketing must be stopped pending clearance
- Post-approval amendments: Changes to formulation, pack size, shade range, manufacturing site, or importer details require filing an amendment on the SUGAM portal before the change takes effect
- Label compliance: All physical labels on imported products must match the approved label in the COS-1 submission, with the COS-2 number printed on the label
- Sampling rights: The Licensing Authority may take samples of your cosmetics for testing at any time — maintain batch records and COAs for all imported batches
The Bottom Line for International Exporters
India’s cosmetics market is large, growing, and genuinely accessible to international brands — but only through the correct regulatory pathway. The COS-1 and COS-2 process is structured, sequential, and manageable when approached with accurate documentation and realistic timelines.
The brands that enter successfully are the ones that start the process early, invest in getting the Authorization Letter and FSC authentication right the first time, complete the IS 4707 ingredient compliance check before any other document is prepared, and work with an experienced Indian regulatory partner who understands CDSCO’s review process.
The brands that struggle are the ones that underestimate documentation lead times, assume the process works like other markets they have entered, or try to import before registration is complete.
Start the process now — and plan for a 6–9 month runway before your first India shipment.
Need Help Getting Your COS-1 and Import Licence for India?
We work with international cosmetic exporters across South Korea, Japan, France, UK, USA, Germany, and other markets to obtain CDSCO import registration efficiently and without errors. Our services include:
- Authorization Letter drafting and authentication guidance (country-specific)
- Free Sale Certificate review and authentication pathway guidance
- Complete INCI ingredient list preparation and IS 4707 compliance check
- Indian market label compliance review (Cosmetics Rules, 2020 + Legal Metrology)
- SUGAM portal registration and COS-1 filing
- CDSCO query handling until COS-2 is issued
- Authorized Indian Agent services — we can act as your Indian representative
Get a free consultation for your India market entry today. Talk to our CDSCO regulatory team →
