We prepare every document required for a complete, CDSCO-compliant COS-1 application dossier — across all cosmetic categories including skincare, haircare, colour cosmetics, personal care, fragrances, sun care, and baby care.
1. Product Classification & Category Mapping
CDSCO has defined approximately 80 product families for cosmetic registration. Correctly identifying your product’s category determines the applicable fee, the scope of your application, and how CDSCO evaluates your dossier. We map every product to its correct category before a single document is drafted.
2. Form COS-1 — Application Form Preparation
The COS-1 form on SUGAM requires precise entry of:
- Applicant (importer/agent) details
- Overseas manufacturer name, address, and manufacturing site details
- Product name, brand name, variants, shades, pack sizes
- Product category and intended use
- Complete INCI ingredient list in correct descending order
Every field must match your supporting documents exactly. We prepare and cross-check the form against all dossier components before submission.
3. Authorization Letter (First Schedule)
The authorization from your overseas manufacturer to the Indian importer/agent is one of the most scrutinised documents in the dossier. It must:
- Be executed and authenticated before a First Class Magistrate in India, or authenticated from the Indian Embassy of the country of origin, or Apostilled (for Hague Convention member countries)
- Contain specific mandatory clauses as per the First Schedule of Cosmetics Rules, 2020
- Name the correct parties, products, and manufacturing sites
We draft authorization letters in the correct format and guide you through the authentication process — whether in India or from the country of origin.
4. Free Sale Certificate (FSC) Review & Authentication Guidance
The Free Sale Certificate confirms that your cosmetic product is freely sold in its country of manufacture. For CDSCO acceptance, the FSC must be:
- Issued by the competent authority in the country of origin
- Authenticated from the Indian Embassy of country of origin — or authenticated from Chamber of Commerce and Apostilled — or authenticated from notary public and Apostilled
- Product list signed and stamped by the issuing authority
- Covering all products and variants listed in your COS-1 application
We review your FSC for CDSCO compliance and provide detailed guidance on the correct authentication pathway for your country of origin.
5. Complete INCI Ingredient List Preparation & Compliance Check
The complete ingredient list is one of the most technically demanding components of the cosmetic dossier. We prepare:
- Full INCI nomenclature ingredient list in correct descending order of concentration
- BIS IS 4707 compliance check — including the updated IS 4707 (Part 2): 2025 standard (revised August 2025) covering prohibited, restricted, and GNRAS ingredients
- IS 4707 (Part 3): 2025 compliance check — permitted preservatives with concentration limits (new standard, September 2025)
- Flagging of any restricted ingredients — including permitted concentration ranges and usage conditions
- Identification of any prohibited substances requiring reformulation before application
6. Label / Artwork Review & Compliance
Your proposed Indian market label must comply with both Cosmetics Rules, 2020 and the Legal Metrology (Packaged Commodities) Rules, 2011. We review and advise on:
Mandatory Label Elements
Product name, brand, manufacturer & importer details, COS-2 number, ingredients, net quantity, batch no., manufacturing & expiry date, MRP, country of origin
Claims Compliance
Review of “organic,” “natural,” “herbal,” “cruelty-free” and SPF claims for CDSCO and Legal Metrology compliance
Private Label Structure
“Manufactured by / Imported by / Marketed by” structure for private label and D2C brands
Marketplace Compliance
Label elements required for Amazon, Nykaa, Myntra, and own D2C website listings
7. Manufacturing Licence of Overseas Manufacturer
CDSCO requires a copy of the overseas manufacturer’s licence to manufacture cosmetics in their country. Where no such licensing provision exists in the country of origin, we prepare a compliant declaration from the importer — as accepted by CDSCO under their guidance document.
8. Certificate of Analysis (COA) & Safety Documentation
We assist with compiling and reviewing:
- Certificate of Analysis for each product
- Heavy metals declaration (where required)
- Safety data for restricted or borderline ingredients
- Microbial testing and stability data documentation
9. Covering Letter & Checklist Preparation
The covering letter acts as a guidebook for the CDSCO review officer — it describes the purpose of the application, the products included, and provides a structured index of all submitted documents with correlation charts linking products to their respective FSCs and authorizations. A well-drafted covering letter significantly improves reviewer experience and reduces the likelihood of queries.
10. Full Dossier Cross-Check Before Submission
Before your application goes live on SUGAM, we conduct a complete cross-check of the entire dossier:
- All data in COS-1 form matches all supporting documents
- Product names, variants, shades, and pack sizes are consistent throughout
- Manufacturer and importer details match across authorization, FSC, and form
- All PDFs are within SUGAM’s file size limits and correctly formatted
- Fee calculation verified against product categories and number of products