• Import route: File Form COS-1 on the SUGAM portal; the Central Licensing Authority (CDSCO) grants Form COS-2, valid for 5 years.
• Manufacture route: File Form COS-5 with the State Licensing Authority; the license is granted in Form COS-8, valid until cancelled, subject to a 5-year retention fee.
• Timelines: Import registration takes up to 180 working days; a manufacturing license is granted within 45 days of document verification, followed by a GMP inspection.
• Coverage: Applies to all makeup categories under the Fourth Schedule of the Cosmetics Rules, 2020 — foundation, lipstick, mascara, eyeliner, nail polish, and more.

Introduction

CDSCO Cosmetic Makeup Registration is the mandatory approval under the Cosmetics Rules, 2020 for selling makeup products in India. Importers file Form COS-1 with CDSCO (Central Licensing Authority) and receive the Form COS-2 registration certificate, valid for 5 years, generally within 180 working days.

Domestic manufacturers file Form COS-5 with their State Licensing Authority and receive the Form COS-8 manufacturing license, generally within 45 days, followed by a GMP site inspection. Both routes require product categorization under the Fourth Schedule (80+ categories), safety documentation, and payment of prescribed fees on the SUGAM portal.

What Is CDSCO Cosmetic Makeup Registration?

CDSCO Cosmetic Makeup Registration refers to the regulatory approval that every foundation, lipstick, eyeliner, mascara, nail polish, blush, highlighter, or eyeshadow brand must secure before it is legally imported into or manufactured in India. Makeup falls under the legal definition of “cosmetic” in Section 3(aaa) of the Drugs and Cosmetics Act, 1940 — any article intended to be rubbed, poured, sprinkled, sprayed on, or applied to the human body for cleansing, beautifying, or altering appearance. The Central Drugs Standard Control Organization (CDSCO), functioning under the Ministry of Health & Family Welfare, administers this approval framework through the Cosmetics Rules, 2020.

There are two distinct compliance routes, and brands often need both if they import some SKUs and manufacture others locally:

• Import route — Form COS-1 (application) → Form COS-2 (Import Registration Certificate) issued by the Central Licensing Authority.
• Manufacturing route — Form COS-5 (application) → Form COS-8 (Manufacturing License) issued by the State Licensing Authority.

Import vs Manufacturing: Quick Comparison

Form COS-1: Application for Import Registration

Form COS-1 is the online application filed on the SUGAM portal to register a makeup product for import into India. It can be filed by the overseas manufacturer, its authorized Indian agent, an Indian subsidiary, or an importer authorized by the manufacturer. Foreign brands cannot file directly — they must appoint an Indian entity to hold the registration.

Who Should File COS-1

• Overseas cosmetic manufacturers selling makeup in India through a local entity.
• Authorized Indian agents or distributors representing a foreign brand.
• Indian subsidiaries of global cosmetic companies.
• Importers who want to bring in makeup products already registered abroad, for resale under their own arrangement.

Documents Required for COS-1

• Covering letter with an index of enclosed documents.
• Authorization letter from the manufacturer in favour of the Indian agent (as per the First Schedule).
• Certificate of Free Sale (CFS) from the country of origin, notarized/apostilled or attested by the Indian Embassy.
• Product list with names, variants, shades, and pack sizes in the Indian Metric System.
• Category mapping of each product under the Fourth Schedule (80+ categories).
• Ingredient list / formulation with percentage composition.
• Label copies (inner and outer) as per Chapter VI of the Cosmetics Rules, 2020.
• Non-animal testing declaration and a declaration of no Hexachlorophene content.
• Manufacturing site details and Good Manufacturing Practice (GMP)/ISO 22716 certificate of the overseas facility.
• Fee payment receipt generated through the Bharatkosh gateway.

Step-by-Step COS-1 Process

• Register the Indian agent/importer on the SUGAM portal and select ‘Cosmetic Registration’.
• Identify the correct Fourth Schedule category for every makeup product and variant.
• Compile the manufacturer authorization, Free Sale Certificate, labels, and testing declarations.
• Fill Form COS-1 online with product, manufacturer, and agent details.
• Pay the prescribed government fee via Bharatkosh and upload the challan.
• Submit the application; CDSCO scrutinizes documents and may raise queries.
• Respond to queries within the stipulated time to avoid rejection.
• On satisfactory review, the Central Licensing Authority grants Form COS-2.

Form COS-2: Grant of Import Registration Certificate

Form COS-2 is the Import Registration Certificate issued by the Central Licensing Authority once a COS-1 application is approved. It legally permits the import, sale, and distribution of the listed makeup products, variants, and manufacturing sites in India. The certificate number must appear on product labels sold in the Indian market.

• Validity: 5 years from the date of issue.
• Renewal: A retention application with fresh fee payment must be filed before expiry to keep the registration active.
• Amendments: Any change in product composition, labelling, or company constitution must be intimated to CDSCO within 15–180 days depending on the change.
• Additional imports: Once COS-2 is granted, further consignments of already-registered products can be imported under Form COS-4/COS-4A without a fresh COS-1.

Form COS-5: Application for Grant of Manufacturing License

Form COS-5 is filed with the State Licensing Authority (State Drug Controller) by any entity that wants to manufacture makeup products in India — whether for domestic sale or export. If the applicant does not own manufacturing premises, a loan license can instead be sought using Form COS-6.

Eligibility for COS-5

The manufacturing unit must comply with the Seventh Schedule (premises, plant, and equipment norms) of the Cosmetics Rules, 2020.

• A technical/competent person must hold a diploma or degree in pharmacy, chemistry, or an equivalent qualification recognized under the Pharmacy Act, 1948.
• The applicant must self-certify Good Manufacturing Practice (GMP) compliance under Schedule M-II / Seventh Schedule using Form COS-7.
• A manufacturing license under COS-5 can cover up to 10 items per cosmetic category; additional categories attract extra fees.

Documents Required for COS-5

• Form COS-5 application (or COS-6 for a loan license) with the prescribed fee.
• Self-declaration of GMP compliance in Form COS-7.
• Site layout plan, list of machinery, and manufacturing process flow chart.
• Details of the technical/competent staff with qualification proof.
• Product formulation, specifications, and Fourth Schedule category mapping for each makeup product.
• Proof of premises ownership or lease, and constitution documents of the firm.
• Undertaking as specified in Part-II of the Second Schedule of the Cosmetics Rules, 2020.

Step-by-Step COS-5 Process

• Set up the manufacturing premises as per Seventh Schedule GMP norms.
• Appoint a qualified technical/competent person to supervise production.
• File Form COS-5 (or COS-6 for loan license) on the SUGAM portal with Form COS-7 self-declaration.
• Pay the fee prescribed under the Third Schedule.
• Submit the application to the concerned State Licensing Authority for scrutiny.
• Respond to any deficiency memo raised by the authority.
• Receive the manufacturing license in Form COS-8 (or COS-9 for loan license) within 45 days of satisfactory verification.
• Prepare for a GMP site inspection within 30 days of license grant.

Form COS-8: Grant of Manufacturing License

Form COS-8 is the manufacturing license itself, issued by the State Licensing Authority after it reviews the COS-5 application and supporting documents. It is the legal permit that allows a company to formulate, fill, pack, and sell makeup products under its own manufacturing license number (“Mfg. Lic. No.”), which must be printed on every product label.

• Validity: Valid until cancelled or surrendered, provided the retention fee is paid every 5 years.
• Late retention fee: Payable within 180 days of the due date with a 2% per month late fee.
• Inspection cycle: Licensed sites are inspected by the State Licensing Authority at least once every 3 years, in addition to the first inspection within 30 days of grant.
• Loan license: Brands using a third-party manufacturing facility receive the equivalent license in Form COS-9 instead of COS-8.
• Endorsements: New makeup SKUs or categories can be added to an existing COS-8 license through a portal-based endorsement, without filing a fresh COS-5 in most cases.

Full Cosmetic Makeup Products Table (Fourth Schedule Coverage)

The table below lists common makeup and related cosmetic products covered under CDSCO Cosmetic Makeup Registration, mapped to their broad Fourth Schedule category groups. Every SKU and shade variant must be declared individually in Form COS-1 or COS-5.

Note: The Cosmetics Rules, 2020 recognise 80+ product categories under the Fourth Schedule. Incorrect categorisation is one of the leading causes of CDSCO queries, so each makeup product should be mapped carefully against its intended use, area of application, and any functional claims (e.g., SPF, waterproof, long-wear) before filing.

Benefits of CDSCO Cosmetic Makeup Registration

• Legal market access — registered/licensed makeup can be sold across India, including on e-commerce marketplaces, without customs detention risk.
• Consumer trust — a valid COS-2 or COS-8 number on the label signals safety and regulatory compliance to buyers and retailers.
• Smooth customs clearance — registered import consignments clear Indian ports faster since CDSCO does not permit post-import registration.
• Retailer and marketplace eligibility — most organised retail chains and online platforms require a valid CDSCO license before listing a makeup brand.
• Long-term validity — COS-2 lasts 5 years and COS-8 is valid indefinitely (subject to retention fees), reducing repeat filing effort.

Eligibility, Requirements & Compliance Checklist

CDSCO Cosmetic Makeup Registration Fees

Fees are prescribed under the Third Schedule of the Cosmetics Rules, 2020, and are payable through the Bharatkosh gateway.

Validity, Renewal & Approval Timeline

Common Mistakes to Avoid in CDSCO Cosmetic Makeup Registration

• Mis-categorizing a makeup product under the wrong Fourth Schedule heading, leading to avoidable queries and 2–4 months of delay.
• Inconsistent product names, addresses, or pack sizes across the Free Sale Certificate, authorization letter, and Form COS-1.
• Importing makeup consignments before COS-2 is granted — CDSCO does not allow post-import registration.
• Missing SPF or performance-claim substantiation data for tinted sunscreen/BB cream makeup products.
• Delaying the 5-year retention filing for COS-2 or the COS-8 retention fee, resulting in lapsed validity or late fees.
• Skipping the qualified technical/competent person requirement at a domestic manufacturing site, which blocks COS-5 approval.

Conclusion

CDSCO Cosmetic Makeup Registration protects consumers and gives brands a clear, predictable pathway into India's fast-growing beauty market. Whether you are importing an international makeup line through COS-1/COS-2 or setting up domestic production through COS-5/COS-8, accurate Fourth Schedule categorisation, complete documentation, and on-time retention filings are what keep the approval fast and the license valid. Engaging an experienced CDSCO regulatory consultant can help first-time applicants avoid the categorisation errors and documentation gaps that most commonly delay approval.

Frequently Asked Questions