Organic cosmetic brands are becoming increasingly popular in India as consumers look for safer, natural, and cruelty-free beauty products. However, before any imported organic cosmetic can be legally sold in India, it must comply with Indian cosmetic regulations and be registered with the Central Drugs Standard Control Organisation (CDSCO). Under the Cosmetics Rules, 2020, CDSCO regulates the import of all cosmetic products, including those marketed as organic, natural, herbal, or vegan. For imported cosmetics, registration is done through Form COS-1, which is submitted online on the CDSCO SUGAM portal. Once approved, CDSCO issues Form COS-2, which allows the product to be imported and sold in India. This article explains the complete and correct step-by-step process for Form COS-1 submission for organic cosmetics in India, including documentation, organic-claim requirements, approval flow, and post-approval compliance.
What Is Form COS-1 Under CDSCO?
Form COS-1 is the official online application form used to apply for cosmetic import registration in India. It is submitted by an Indian authorised agent or importer on behalf of the foreign manufacturer. After reviewing the application and documents, CDSCO issues Form COS-2, which is the Cosmetic Import Registration Certificate.
- Form COS-1 – Application for cosmetic import registration
- Form COS-2 – Approval certificate used for customs clearance
Without a valid COS-2 certificate, imported cosmetic products cannot be legally cleared at customs or sold in India.
Who Must Apply for Form COS-1?
Form COS-1 submission is required when:
- The cosmetic product is manufactured outside India
- The product is imported for commercial sale
- The product is marketed as organic, natural, herbal, vegan, or cruelty-free
- The product falls under the definition of a cosmetic under Indian law
The application must be filed by an Indian authorised agent or importer who is legally appointed by the foreign manufacturer.
Step-by-Step Process for Form COS-1 Submission Organic Cosmetics India
Step 1: Confirm the Product Qualifies as a Cosmetic
Before applying, it is important to confirm that the product qualifies as a cosmetic under the Cosmetics Rules, 2020.
Organic or natural claims do not change the product’s classification. Products that claim to treat, cure, or prevent diseases may be classified as drugs and rejected under cosmetic rules.
Step 2: Appoint an Indian Authorised Agent
Foreign organic cosmetic brands must appoint an Indian authorised agent or importer. This agent is responsible for:
- Creating and managing the SUGAM portal account
- Submitting Form COS-1
- Communicating with CDSCO
- Handling customs clearance and post-approval compliance
A valid Authorisation Letter or Power of Attorney from the manufacturer is mandatory.
Step 3: Prepare Documents for Organic Cosmetic Registration
Document preparation is the most critical stage in Form COS-1 submission for organic cosmetics in India.
Required documents generally include:
- Duly filled Form COS-1
- Covering letter
- Manufacturer’s name and address
- Manufacturing license or GMP certificate
- Free Sale Certificate (FSC) from the country of origin
- Complete ingredient list using INCI names in descending order
- Product specifications and Certificate of Analysis
- Safety data and test reports (such as microbial limits)
- Shelf-life or stability justification (may be requested, especially for organic products)
- Non-animal testing declaration (mandatory in India)
- Label artwork as per Indian labelling rules
- Accepted certifications may include COSMOS, ECOCERT, USDA Organic, or equivalent internationally recognised bodies.
- Authorisation letter from manufacturer to Indian agent
If only certain ingredients are organic, this must be clearly stated in both documentation and labelling.
Step 4: Review Organic Claims and Label Compliance
CDSCO does not certify products as “organic”, but it strictly checks whether organic claims are truthful and supported.
Important points:
- “Organic” claims must be backed by valid certification
- Certification logos must match the scope of the certificate
- Labels must include importer details, batch number, manufacturing date, expiry date, net content, and ingredient list
- Medical or therapeutic claims are not allowed
Incorrect or misleading organic claims are a common reason for CDSCO queries.
Step 5: Online Submission on CDSCO SUGAM Portal
The Indian authorised agent logs into the SUGAM portal, selects cosmetic import registration, and fills out Form COS-1 online.
All documents must be uploaded in the prescribed format. Any mismatch, unclear scan, or missing document can delay the approval.
Step 6: Fee Payment and Final Submission
After document upload, as per the Cosmetics Rules, 2020, the government fee is USD 1000 per product category and USD 50 per variant. Once submitted, an application reference number is generated to track the status.
Step 7: CDSCO Review and Query Resolution
CDSCO reviews the application for:
- Ingredient safety and restrictions
- Label compliance
- Organic claim justification
- Manufacturing standards
- Non-animal testing compliance
If CDSCO requires clarification, queries are raised through the portal. Prompt and accurate responses help avoid delays.
Step 8: Issuance of Form COS-2 Certificate
Once CDSCO is fulfilled, Form COS-2 is issued. This certificate confirms that the cosmetic product is approved for import and sale in India. Form COS-2 is required during customs clearance and must be kept available for inspections.
Post-Approval Compliance for Organic Cosmetic Brands
After COS-2 approval, brands must:
- Import only the approved products and variants
- Use labels exactly as approved
- Maintain batch-wise records
- Ensure organic certification remains valid (if claimed)
- Cooperate with inspections or market surveillance
Major changes in formulation, claims, or manufacturer require prior CDSCO approval. Minor label layout changes may only require intimation.
Common Mistakes to Avoid
- Using “organic” claims without valid certification
- Submitting incomplete or incorrect ingredient lists
- Uploading non-compliant labels
- Missing the non-animal testing declaration
- Making therapeutic or medicinal claims
Avoiding these mistakes helps ensure faster approval.
Is Form COS-1 mandatory for organic cosmetics imported into India?
Yes, all imported cosmetic products, including organic ones, must be registered using Form COS-1.
Can organic cosmetics be sold in India without COS-2?
No, COS-2 approval is mandatory for legal import and sale.
Does CDSCO certify cosmetics as organic?
No, CDSCO only verifies regulatory compliance; organic status depends on valid certification.
Is animal testing allowed for organic cosmetics in India?
No, animal testing and sale of animal-tested cosmetics are completely banned.
Can one COS-2 cover multiple products?
Yes, multiple products and variants from the same manufacturer and within the same product category can be covered under a single COS-1 application and approved under one COS-2.
