CDSCO cosmetic hair oil registration is mandatory under the Drugs and Cosmetics Act, 1940 for all hair oil products sold or imported in India. Manufacturers apply using Form COS-5 and receive a grant of license through COS-8, while importers use COS-1 to apply for and COS-2 to receive the Cosmetic Import License. Businesses that outsource production use COS-9 for a Cosmetic Loan License.
All applications are submitted online via the SUGAM portal. Products must meet Schedule-S labelling standards. Licenses are typically valid for 5 years and can be renewed 6 months before expiry.
What Is CDSCO Cosmetic Registration and Why Does It Matter for Hair Oils?
If you manufacture or import hair oil products in India, CDSCO cosmetic registration is not optional — it is a legal requirement. The Central Drugs Standard Control Organisation (CDSCO), operating under the Ministry of Health and Family Welfare, regulates cosmetics in India under the Drugs and Cosmetics Act, 1940 and its Amendment Rules of 2020.
Hair oils — including coconut-based oils, argan hair oils, growth oils, herbal hair treatment oils, and scalp serums — fall under Schedule M-II and Schedule-S of the Cosmetics Rules, 2020. Without proper CDSCO cosmetic hair oil registration, your products cannot legally be sold, imported, or distributed in the Indian market.
Whether you are a startup entering the beauty industry, an established brand expanding your portfolio, or a foreign manufacturer looking to enter India, this guide covers every aspect of the CDSCO registration process for cosmetic hair oil products — from understanding the right license type to completing the application and maintaining compliance in 2026.
Cosmetic Hair Oil Products: Category-Wise Table Under CDSCO
Not all hair oils are treated equally under CDSCO regulations. Products are classified based on their composition, intended use, and formulation type. Here is a category-wise breakdown of cosmetic hair oil products that require CDSCO registration:
| Category | Product Examples | Regulatory Schedule | License Required |
| General Hair Oils | Coconut hair oil, Almond oil, Castor oil blends | Schedule-S, Schedule M-II | COS-5 / COS-8 (Manufacture) or COS-1 / COS-2 (Import) |
| Herbal / Ayurvedic Hair Oils | Bhringraj oil, Brahmi hair oil, Amla hair oil, Neem oil | Schedule-S, Schedule M-II | COS-5 / COS-8 or COS-1 / COS-2 |
| Medicated Hair Oils (Cosmetic Grade) | Anti-dandruff oil (non-drug), Scalp nourishing oil | Schedule-S | COS-5 / COS-8 or COS-1 / COS-2 |
| Specialty / Premium Hair Oils | Argan oil, Keratin hair oil, Moroccan oil blends | Schedule-S | COS-5 / COS-8 or COS-1 / COS-2 |
| Hair Growth & Treatment Oils | Onion hair oil, Rosemary scalp oil, Biotin hair oil | Schedule-S, Schedule M-II | COS-5 / COS-8 or COS-1 / COS-2 |
| Imported Luxury Hair Oils | French argan oil blends, Japanese camellia oil, Korean hair oils | Schedule-S | COS-1 (Application), COS-2 (License Grant) |
| Loan License Manufactured Oils | Third-party or contract-manufactured hair oil products | Schedule-S, Schedule M-II | COS-9 (Cosmetic Loan License) |
| Private Label Hair Oils | White-label hair oil manufactured for brands | Schedule-S | COS-9 or COS-5 / COS-8 depending on structure |
| Important Note: If a hair oil product claims to treat or cure a medical condition (e.g., alopecia, fungal infection), it may be classified as a drug under the Drugs and Cosmetics Act and will require drug registration instead of cosmetic registration. Always confirm the product category with a regulatory expert before applying. |
Types of CDSCO Cosmetic Licenses for Hair Oil Products
CDSCO issues several types of cosmetic licenses depending on whether you are manufacturing, importing, or outsourcing production of cosmetic hair oil products. Understanding which license applies to your business model is the first step to a smooth registration process.
| License Type | Form (Application) | Form (Grant) | Who Needs It |
| Cosmetic Import License | COS-1 | COS-2 | Foreign manufacturers & Indian importers of cosmetic hair oils |
| Cosmetic Manufacture License | COS-5 | COS-8 | Indian manufacturers of cosmetic hair oil products |
| Cosmetic Loan License | COS-9 | COS-9 (Amended) | Brands outsourcing production to a licensed third-party manufacturer |
Cosmetic Import License for Hair Oil – COS-1 Application & COS-2 Grant of License
If you are looking to import cosmetic hair oil products into India — whether from France, South Korea, the USA, or any other country — you must obtain a Cosmetic Import License from CDSCO. This is mandatory under Rule 129 of the Cosmetics Rules, 2020.
What Is COS-1 (Application for Cosmetic Import License)?
COS-1 is the official application form that importers or foreign manufacturers must submit to CDSCO for obtaining permission to import cosmetic hair oil products into India. This form is submitted through the SUGAM online portal.
What Is COS-2 (Grant of Cosmetic Import License)?
COS-2 is the license document issued by CDSCO after successful review and approval of your COS-1 application. This license authorises you to import specific cosmetic hair oil products into India. The COS-2 license specifies the product name, manufacturer details, country of origin, and validity period.
Who Needs a Cosmetic Import License (COS-1 / COS-2)?
- Indian importers bringing foreign cosmetic hair oil products into India for retail, wholesale, or distribution
- Foreign manufacturers who want to sell their hair oil products directly in the Indian market
- E-commerce platforms importing hair oils for online retail in India
- Authorized distributors acting as the Indian representative of a foreign cosmetic brand
Eligibility Criteria for Cosmetic Import License
| Eligibility Parameter | Requirement |
| Applicant Type | Indian importer or authorized representative of a foreign manufacturer |
| Legal Entity | Company, LLP, Partnership Firm, or Sole Proprietorship registered in India |
| Product Classification | Product must qualify as a cosmetic under Schedule-S (not a drug) |
| Manufacturer Compliance | Foreign manufacturer must comply with Good Manufacturing Practices (GMP) |
| Labelling Compliance | Product labelling must comply with Schedule-S of Cosmetics Rules, 2020 |
| Free Sale Certificate | Required from the competent authority in the country of origin |
Documents Required for COS-1 Application (Cosmetic Import License)
- Duly filled COS-1 application form submitted on SUGAM portal
- Certificate of Incorporation or Business Registration of the Indian importer
- Free Sale Certificate (FSC) from the country of origin — notarised and apostilled
- Manufacturing Site details of the foreign manufacturer
- Product composition and ingredient list (INCI names)
- Schedule-S compliant label artwork and leaflet (draft)
- Certificate of Analysis (CoA) for the product
- Good Manufacturing Practice (GMP) certificate of the foreign manufacturer
- Safety Data Sheet (SDS) for all ingredients
- Power of Attorney if applying through an Indian authorized representative
- Stability test reports (if available)
- Cancelled cheque or bank details for fee payment
Fee Structure for Cosmetic Import License (COS-1)
| Fee Category | Government Fee (INR) |
| Application fee for first product (COS-1) | INR 3,000 per product |
| Additional product under same application | INR 1,000 per additional product |
| Amendment to existing COS-2 license | INR 1,000 per amendment |
| Renewal of COS-2 license | INR 1,500 per product |
| Note: Government fees are subject to change. Always verify the current fee schedule on the official SUGAM portal (sugam.gov.in) before submitting your application. | |
Step-by-Step COS-1 Application Process
- Register your company on the SUGAM portal
- Log in and select 'Cosmetics' under the Import License module
- Fill in the COS-1 application form with product details, manufacturer information, and importer details
- Upload all required documents in the prescribed format (PDF, size limits apply)
- Pay the prescribed government fee online via the SUGAM payment gateway
- Submit the application and note down your application reference number
- CDSCO technical staff will review your application — queries may be raised online
- Respond to any deficiency letter or query within the stipulated time
- Upon approval, download your COS-2 (Grant of Import License) from the SUGAM portal
Timeline for Cosmetic Import License
| Stage | Expected Timeline |
| Application submission to acknowledgement | 1–3 working days |
| Technical scrutiny by CDSCO | 15–30 working days |
| Response to deficiency (if any) | 30 days from query date |
| Grant of COS-2 license (after all queries resolved) | 45–90 working days (standard) |
| Overall expected timeline | 60–120 days (subject to CDSCO workload) |
Validity and Renewal of Cosmetic Import License (COS-2)
- The COS-2 Cosmetic Import License is valid for 5 years from the date of grant
- Renewal application must be submitted at least 6 months before expiry
- Renewal is filed through the SUGAM portal using the renewal module
- Products can be imported during the renewal processing period if the application was submitted in time
- Failure to renew results in suspension of import rights for those products
Cosmetic Manufacture License for Hair Oil – COS-5 Application & COS-8 Grant of License
Any business that manufactures cosmetic hair oil products within India must obtain a Cosmetic Manufacture License from the State Licensing Authority (SLA) — typically the State Drugs Controller of the relevant state — as per the Cosmetics Rules, 2020.
What Is COS-5 (Application for Cosmetic Manufacture License)?
COS-5 is the application form submitted by cosmetic manufacturers to the State Licensing Authority (SLA) to obtain permission to manufacture cosmetic hair oil products at their facility. This application covers the manufacturing site, product categories, and technical competence of the applicant.
What Is COS-8 (Grant of Cosmetic Manufacture License)?
COS-8 is the license document issued by the State Licensing Authority upon successful inspection and approval of your manufacturing facility. The COS-8 license authorises you to manufacture specific categories of cosmetic products, including hair oil products, at the approved site.
Who Needs a Cosmetic Manufacture License (COS-5 / COS-8)?
- Manufacturers producing cosmetic hair oil products at their own factory or plant in India
- Companies setting up new manufacturing units for hair care products
- Existing manufacturers adding new product categories like hair oils to their license
- Manufacturers who want to supply hair oil products to other brands as a contract manufacturer
Eligibility Criteria for Cosmetic Manufacture License
| Eligibility Parameter | Requirement |
| Applicant Type | Manufacturer with a physical production facility in India |
| Technical Staff | Qualified technical person (B.Pharma, M.Sc Chemistry, or equivalent) as per Schedule M-II |
| Manufacturing Premises | Dedicated premises complying with Schedule M-II GMP standards |
| Equipment | Adequate equipment for mixing, filling, packaging, and testing of hair oils |
| Quality Control | In-house or outsourced QC lab for product testing |
| Water System | Purified water system compliant with Cosmetics Rules, 2020 |
Documents Required for COS-5 Application
- Duly filled COS-5 application form
- Proof of ownership or lease of manufacturing premises
- Site Master File (SMF) detailing manufacturing layout and flow
- List of products to be manufactured (with category and formulation details)
- Qualification certificates of the technical personnel
- List of plant and equipment with technical specifications
- Water analysis report (for purified water system)
- SOPs for manufacturing, quality control, and sanitation
- Certificate of Incorporation / Business Registration
- GMP compliance declaration
- Fee challan or online payment receipt
- Stability study protocols (for each hair oil product category)
Fee Structure for Cosmetic Manufacture License (COS-5 / COS-8)
| Fee Category | Government Fee (INR) |
| Application fee for Cosmetic Manufacture License (COS-5) | INR 3,500 (varies by state) |
| Inspection fee (site visit by SLA inspector) | INR 2,000 – 5,000 (varies by state) |
| License grant fee (COS-8) | INR 2,500 – 5,000 (varies by state) |
| Additional product category endorsement | INR 500 – 1,000 per category |
| License renewal (every 5 years) | INR 2,500 – 5,000 |
| State Variation: Cosmetic manufacture license fees vary across states. Maharashtra, Karnataka, Gujarat, and Uttar Pradesh may have different fee schedules. Always check with your State Drugs Controller for the current and applicable fee. | |
Step-by-Step COS-5 Application Process
- Ensure your manufacturing facility is GMP compliant as per Schedule M-II
- Prepare all required documents including the Site Master File and SOPs
- Submit the COS-5 application to the State Licensing Authority (State Drugs Controller) — online through state portal or physical submission depending on the state
- Pay the prescribed application and inspection fees
- Await a scheduled inspection of your manufacturing premises by SLA inspectors
- Address any observations or deficiencies noted during inspection
- Upon satisfactory inspection and document review, SLA issues the COS-8 Manufacture License
- Display the COS-8 license prominently at your manufacturing facility
Timeline for Cosmetic Manufacture License
| Stage | Expected Timeline |
| Application submission to acknowledgement | 7–15 working days |
| Site inspection scheduling | 30–60 days from submission |
| Post-inspection review | 15–30 days |
| Grant of COS-8 license | 60–120 days (from application date) |
| Overall expected timeline | 3–6 months depending on state and inspection availability |
Validity and Renewal of COS-8 Manufacture License
- COS-8 Cosmetic Manufacture License is valid for 5 years from the date of issue
- Renewal must be applied for at least 6 months before expiry using the COS-5 form again
- Manufacturing can continue during renewal processing if the application was filed on time
- Non-renewal leads to cancellation of the manufacturing license and business disruption
Cosmetic Loan License (COS-9) – What It Is and Who Needs It
A Cosmetic Loan License, applied through Form COS-9, is a smart and cost-effective option for brands that want to sell cosmetic hair oil products in India but do not own a manufacturing facility. Under a loan license arrangement, the brand (loan licensee) uses the manufacturing site and equipment of a licensed manufacturer (COS-8 holder) to produce its products.
What Is COS-9 (Cosmetic Loan License)?
COS-9 is both the application and the license document for a Cosmetic Loan License. It is issued by the State Licensing Authority to a brand or company that wishes to manufacture cosmetic products (including hair oil products) at a third-party licensed manufacturing facility. The loan licensee is responsible for product quality and compliance, even though manufacturing is outsourced.
Who Needs a COS-9 Cosmetic Loan License?
- Startups and small businesses that want to launch hair oil products without investing in a manufacturing plant
- D2C (Direct-to-Consumer) beauty brands launching private label hair oil ranges
- Established brands outsourcing specific product lines to contract manufacturers
- E-commerce entrepreneurs wanting to sell cosmetic hair oil products under their own brand name
- Companies transitioning from one manufacturer to another and needing temporary production
Key Difference Between COS-9 (Loan License) and COS-8 (Manufacture License)
| Parameter | COS-8 (Manufacture License) | COS-9 (Loan License) |
| Manufacturing Facility | Own manufacturing site required | Uses a licensed third-party manufacturer's facility |
| Capital Investment | High — factory, equipment, QC lab required | Low — no manufacturing investment needed |
| Responsibility | Manufacturer is fully responsible | Loan licensee is responsible for quality and compliance |
| Product Ownership | Manufacturer sells their own or contract products | Loan licensee owns the brand and sells under their label |
| Issued By | State Licensing Authority (SLA) | State Licensing Authority (SLA) |
| Who Applies | Factory owner / manufacturer | Brand owner / company without own factory |
Documents Required for COS-9 Application
- Duly filled COS-9 application form
- Agreement between the loan licensee (brand) and the loan licensor (manufacturer with COS-8)
- Copy of the COS-8 license of the lending manufacturer
- Certificate of Incorporation or Business Registration of the loan licensee brand
- List of cosmetic hair oil products to be manufactured under the loan license
- Label artwork and draft label compliant with Schedule-S
- Quality agreement between the two parties
- Technical personnel details (qualified person of the loan licensee)
- Fee payment receipt
Fee Structure for COS-9 (Cosmetic Loan License)
| Fee Category | Government Fee (INR) |
| COS-9 application fee | INR 1,500 – 3,000 (varies by state) |
| Inspection fee (if applicable) | INR 1,000 – 3,000 |
| License grant / renewal fee | INR 1,500 – 2,500 |
Step-by-Step COS-9 Application Process
- Identify a licensed cosmetic manufacturer (COS-8 holder) who can produce your hair oil product
- Sign a formal Loan License Agreement specifying responsibilities, product details, and quality standards
- Prepare the COS-9 application form with all required documents
- Submit the application to the State Licensing Authority along with fees
- SLA may inspect the manufacturing premises (loan licensor's facility) to verify compliance
- Upon approval, COS-9 Loan License is issued to the brand (loan licensee)
- Products can now be manufactured at the licensed facility and sold under the brand's name
Validity and Renewal of COS-9 Loan License
- COS-9 Loan License is typically valid for 5 years or co-terminus with the COS-8 license of the manufacturer
- If the manufacturer's COS-8 license expires or is cancelled, the COS-9 automatically becomes invalid
- Always ensure the loan licensor maintains a valid COS-8 license throughout the production period
- Renewal of COS-9 must be applied for in time — 6 months before expiry is recommended
How to Apply on SUGAM Portal – Step-by-Step Online Process
SUGAM is the official online regulatory portal of CDSCO. All cosmetic import license applications (COS-1) are processed through SUGAM. Many states are also transitioning cosmetic manufacture license applications to state-specific digital portals.
SUGAM Portal Registration Steps
- Go to sugam and click on 'New Registration'
- Select 'Importer' or 'Manufacturer' as your user type
- Fill in company details, PAN, GSTIN, and upload required documents
- Verify your email address and mobile number via OTP
- Log in with your SUGAM credentials
- Navigate to 'Cosmetics' module to begin your application
| Pro Tip: Keep scanned copies of all documents ready in PDF format (less than 5 MB each) before starting your SUGAM application. Incomplete submissions or large file sizes are the most common reasons for delays in CDSCO cosmetic registration. |
Schedule-S Labelling Requirements for Cosmetic Hair Oil Products
Every cosmetic hair oil product sold in India — whether imported or manufactured locally — must carry labelling that complies with Schedule-S of the Cosmetics Rules, 2020. Non-compliant labelling is one of the most common reasons for product rejection or recall.
Mandatory Information on Hair Oil Labels
- Name of the product and cosmetic category (e.g., Hair Oil)
- Name and address of the manufacturer (and importer if applicable)
- Country of origin (for imported hair oils)
- Net content — weight or volume (e.g., 100 ml, 200 ml)
- Complete list of ingredients in INCI (International Nomenclature of Cosmetic Ingredients) format
- Batch number and manufacturing date
- Best before date or Period After Opening (PAO) symbol
- Directions for use and any precautions or warnings
- License number (COS-2 for imported products, COS-8 or COS-9 for manufactured products)
- MRP inclusive of all taxes for Indian market sale
Non-Compliance, Penalties, and Enforcement
Failure to comply with CDSCO cosmetic registration requirements can result in serious legal and financial consequences. Here is what you need to know about enforcement under the Drugs and Cosmetics Act, 1940:
| Violation | Penalty |
| Manufacturing cosmetics without COS-8 license | Imprisonment up to 3 years and/or fine |
| Importing cosmetics without COS-2 license | Seizure of goods, fine, and prosecution |
| Selling products with non-Schedule-S compliant labels | Product recall, fine, and license suspension |
| Adulterating or mislabelling cosmetic products | Imprisonment up to 3 years and/or heavy fine |
| Operating under an expired cosmetic license | Suspension of operations and prosecution risk |
| Using a loan license without valid COS-9 | Product seizure and prosecution of brand owner |
Key Benefits of Obtaining CDSCO Cosmetic Registration for Hair Oil Products
- Legal authorization to manufacture, import, or sell cosmetic hair oil products in the Indian market
- Access to legitimate retail channels — supermarkets, pharmacies, e-commerce platforms, and exports
- Brand credibility and consumer trust — registered products signal regulatory compliance and safety
- Protection against market counterfeits — registered products have legal standing against infringement
- Ease of obtaining bank loans and investment — regulatory compliance is required by financial institutions
- Foundation for exporting Indian hair oil products globally — many countries require proof of home-country registration
- Enables collaboration with major retail chains like Nykaa, Amazon, Flipkart, D-Mart, and modern trade partners
Common Mistakes to Avoid in CDSCO Cosmetic Hair Oil Registration
- Applying for cosmetic registration when the product qualifies as a drug — always verify classification first
- Submitting incomplete documents — missing Free Sale Certificate or GMP certificate is the biggest delay cause
- Using incorrect label formats — Schedule-S non-compliance leads to immediate rejection
- Ignoring deficiency letters from CDSCO — failure to respond within the stipulated time may result in application closure
- Not maintaining the COS-8 license validity as a manufacturer when operating as a loan licensor under COS-9
- Underestimating registration timelines — plan your product launch at least 4–6 months after application submission
- Not updating the SUGAM portal with company changes — address, ownership, and technical staff changes must be notified
CDSCO Cosmetic License Types
| Feature | COS-1 / COS-2 (Import) | COS-5 / COS-8 (Manufacture) | COS-9 (Loan License) |
| Purpose | Import of cosmetic hair oils | Manufacture of cosmetic hair oils | Brand using 3rd party manufacturer |
| Issued By | CDSCO (Central) | State Licensing Authority (SLA) | State Licensing Authority (SLA) |
| Application Form | COS-1 | COS-5 | COS-9 |
| License Form | COS-2 | COS-8 | COS-9 (amended) |
| Online Portal | SUGAM | State portal / SLA office | State portal / SLA office |
| Validity | 5 years | 5 years | 5 years or COS-8 validity |
| Approx. Fees | INR 3,000/product | INR 3,500 – 10,000 | INR 1,500 – 5,000 |
| Timeline | 60–120 days | 3–6 months | 45–90 days |
| Physical Inspection | Generally not required | Mandatory site inspection | May require inspection |
| Renewal Period | 6 months before expiry | 6 months before expiry | 6 months before expiry |
Conclusion
CDSCO Cosmetic Hair Oil Registration was prepared by regulatory compliance specialists in 2026 to help manufacturers, importers, brand owners, and entrepreneurs navigate the complex regulatory landscape for cosmetic hair oil products in India. All information reflects the Drugs and Cosmetics Act, 1940 and Cosmetics Rules, 2020 as amended.
Frequently Asked Questions
Is CDSCO registration mandatory for all hair oil products sold in India?
Yes. All cosmetic hair oil products manufactured in India or imported for sale in India must be registered under the Cosmetics Rules, 2020. Without a valid COS-2 (import) or COS-8/COS-9 (manufacture/loan) license, selling hair oil products is illegal under the Drugs and Cosmetics Act, 1940.
What is the difference between COS-1 and COS-2 for cosmetic import?
COS-1 is the application form you submit to CDSCO to request an import license. COS-2 is the actual import license document that CDSCO grants after reviewing and approving your COS-1 application. You import products using the COS-2 license number.
Can I sell imported hair oil products while my COS-1 application is under review?
No. You cannot import or sell cosmetic hair oil products without a valid COS-2 license. Importing products before receiving COS-2 is illegal and can lead to seizure of goods at Indian customs.
What is a Cosmetic Loan License (COS-9) and who should apply?
A Cosmetic Loan License (COS-9) allows a brand or company to manufacture hair oil products at a third-party licensed manufacturer's facility. D2C brands, startups, and private label businesses that do not own a manufacturing plant should apply for COS-9 instead of COS-8.
How long does CDSCO cosmetic hair oil registration take?
For import licenses (COS-1 to COS-2), the typical timeline is 60–120 days, provided all documents are complete. For manufacture licenses (COS-5 to COS-8), it can take 3–6 months depending on the state and inspection schedule. Loan licenses (COS-9) typically take 45–90 days.
What is the validity of CDSCO cosmetic licenses?
All CDSCO and SLA cosmetic licenses — COS-2, COS-8, and COS-9 — are valid for 5 years from the date of grant. Renewal must be applied for at least 6 months before the license expiry date.
Is a Free Sale Certificate mandatory for cosmetic import license?
Yes. A Free Sale Certificate (FSC) from the competent authority of the country of origin is mandatory for obtaining a COS-2 import license. The FSC must be notarised and apostilled as per Indian legal requirements.
Can one COS-2 license cover multiple hair oil products?
No. COS-2 import licenses are issued on a product-by-product basis. Each cosmetic hair oil product (distinct formulation or brand name) requires a separate import license application. However, you can apply for multiple products in a single application submission.
What happens if my COS-8 license expires — can I still manufacture?
No. If your COS-8 Cosmetic Manufacture License expires, you must immediately stop manufacturing cosmetic products. Manufacturing without a valid license is a punishable offense. Always apply for renewal at least 6 months before the expiry date.
Do I need separate CDSCO registration for each state where I sell my hair oil products?
For import licenses (COS-2), one central CDSCO registration covers all India. For manufacture licenses (COS-8), the license is issued by the State Licensing Authority and is valid for manufacturing at that specific premises. You do not need state-wise licenses to sell — distribution and sales are not separately licensed under cosmetic regulations.
