- COS-2 (import registration) must be renewed before its 5-year validity ends — India does not allow lapsed or retrospective renewal.
- COS-8 (manufacturing license) never expires outright, but you must pay a retention fee every 5 years to keep it active.
- Both renewals are filed on the CDSCO SUGAM portal, using largely the same documents as the original application.
- Missing a deadline can mean a 2% monthly late fee, import/production stoppage, or — for COS-8 — permanent cancellation after 180 days.
Introduction
To renew a cosmetic license in India, the process depends on the license type. For a COS-2 import registration, file a renewal application on the CDSCO SUGAM portal about six months before expiry, using the same documents as your original COS-1 filing — approval typically takes 60–90 days.
For a COS-8 manufacturing license, there is no separate renewal form; instead, pay the retention fee to your State Licensing Authority before every five-year anniversary of issue to keep the license valid. Missing either deadline risks penalties, a trading halt, or cancellation.
Understanding Cosmetic License Renewal: Two Separate Pathways
India regulates cosmetics under the Drugs and Cosmetics Act, 1940 and the Cosmetics Rules, 2020, enforced by the Central Drugs Standard Control Organization (CDSCO) for imports and by each State Licensing Authority (SLA) for domestic manufacturing. Because these are two different regulators, "renewing a cosmetic license" actually means two different things depending on whether you import cosmetics into India or manufacture them here.
If you import finished cosmetic products, your renewal concerns Form COS-1 (application) and Form COS-2 (the import registration certificate). If you manufacture cosmetics in India, your renewal concerns Form COS-5 (application) and Form COS-8 (the manufacturing license, or COS-9 for a loan license). The table below lays out how the two compare, since the rules, fees, and deadlines are not the same.
| Aspect | Import Route (COS-1 → COS-2) | Manufacturing Route (COS-5 → COS-8) |
| Regulator | CDSCO (Central Licensing Authority) | State Licensing Authority (SLA) |
| Application form | COS-1 | COS-5 (COS-6 for loan license) |
| Certificate/license form | COS-2 | COS-8 (COS-9 for loan license) |
| Validity | 5 years from date of issue | Perpetual, subject to 5-year retention fee |
| Renewal type | Fresh renewal application required | Retention fee payment only — no fresh application |
| Portal | CDSCO SUGAM | SUGAM / respective state online portal |
| Typical processing time | 60–90 days (up to 180 working days by rule) | Retention is usually processed quickly once fee is paid |
| Late renewal consequence | No retrospective renewal — import halts on expiry | 2% monthly late fee; license deemed cancelled after 180 days unpaid |
How to Renew COS-2 — Cosmetic Import Registration Certificate
A COS-2 Import Registration Certificate is valid for five years from its date of issue. Because Indian rules do not permit importing cosmetics first and registering them later, they also do not permit renewing a certificate after it has already lapsed — so the renewal window has to be treated as a hard deadline, not a soft one.
Who Needs to Renew COS-2
- The Indian agent, subsidiary, or authorized importer named on the existing COS-2 certificate.
- Any business that intends to keep importing, selling, or distributing the same cosmetic products beyond the current 5-year validity.
- Businesses adding new variants or categories under an existing registration (these may need to be filed alongside the renewal).
Documents Required for COS-2 Renewal
- Existing COS-2 certificate copy and original COS-1 approval record.
- Updated Free Sale Certificate from the foreign manufacturer.
- Manufacturing license copy of the overseas manufacturing site (or an undertaking, where applicable).
- Non-Animal Testing Declaration and No-Hexachlorophene Declaration, re-confirmed for current formulations.
- Updated product labels complying with the Cosmetics Rules, 2020 and BIS Ninth Schedule specifications.
- Power of attorney/authorization letter from the manufacturer to the Indian agent, if applicable.
- Government fee payment receipt.
Step-by-Step COS-2 Renewal Process
- Log in to the CDSCO SUGAM portal using your existing registered credentials.
- Initiate the renewal filing roughly six months before the current COS-2 expiry date — this buffer covers document review and any CDSCO queries.
- Upload the updated documents listed above, mapped to the correct cosmetic category for each product.
- Pay the applicable government fee for category, site, and variant retention.
- Respond promptly to any discrepancy notices CDSCO raises on the portal — delayed responses are the most common reason renewals overshoot the timeline.
- Once CDSCO is satisfied, the renewed COS-2 certificate is issued and appears on your SUGAM dashboard, valid for a fresh 5-year term.
COS-2 Renewal Fees
Fees fall under the Third Schedule of the Cosmetics Rules, 2020 and are payable in US dollars or the rupee equivalent. Always confirm the live figure on SUGAM before paying, since government fee notifications can be revised.
| Fee Head | Approx. Amount |
| Grant/retention of registration per cosmetic category | USD 1,000 |
| Registration of each overseas manufacturing site | USD 500 |
| Each additional product variant | USD 50 |
| Additional cosmetic category | USD 1,000 |
| Duplicate certificate (if lost/damaged) | USD 200 |
| Overseas manufacturing site inspection (if required) | USD 5,000 |
Renewal timeline: file at least 6 months before expiry; approval typically takes 60–90 days from a complete filing, though the Cosmetics Rules, 2020 allow the licensing authority up to 180 working days where documentation needs multiple rounds of correction.
How to Renew COS-8 — Cosmetic Manufacturing License
COS-8, the domestic manufacturing license issued by the State Licensing Authority, works differently. It does not carry a fixed expiry date and does not require a fresh renewal application. Instead, the license stays in force indefinitely as long as the licensee pays the prescribed retention fee before every five-year anniversary of the original issue date.
Who Needs to Pay COS-8 Retention Fee
- Any manufacturer holding an active COS-8 license who wants to continue production without interruption.
- Loan license holders under COS-9 (manufacturing at another party's licensed premises), who follow the same retention cycle.
- Manufacturers adding a new cosmetic category or additional items, since these often need to be reflected at the time of retention payment.
Documents Required for COS-8 Retention/Renewal
- Existing COS-8 (or COS-9) license copy.
- Updated list of cosmetic products and categories currently manufactured.
- Current plant layout, equipment list, and Good Manufacturing Practice (GMP) compliance undertaking under Schedule 7.
- Details and qualification certificates of the competent technical staff (Diploma in Pharmacy, Pharmacy Act registration, Intermediate with Chemistry, or a degree in Cosmetic Technology).
- Retention fee payment receipt.
Step-by-Step COS-8 Retention Process
- Track the 5-year anniversary of your COS-8 issue date — there is no automatic reminder, so this is the manufacturer's responsibility.
- Log in to the state's licensing portal (or SUGAM, depending on your state's process) before the due date.
- Submit the updated product/category list and compliance documents along with the retention fee.
- The State Licensing Authority may conduct a fresh site inspection if new categories or premises changes are involved; otherwise, retention is largely a documentation and payment exercise.
- Once accepted, the license continues in force for the next 5-year cycle — no new certificate number is issued, since COS-8 itself doesn't expire.
COS-8 Retention Fees and Late Payment Rules
| Fee Head | Amount (INR) |
| Retention fee — up to 10 items per category | ₹10,000 |
| Retention fee — each additional item in a category | ₹500 |
| Retention fee — additional cosmetic category (up to 10 items) | ₹10,000 |
| Duplicate license copy (defaced/lost original) | ₹500 |
| Late fee | 2% of the retention fee per month of delay |
Important: if the retention fee is not paid within 180 days of the due date, the license is deemed cancelled, and the manufacturer must apply afresh through Form COS-5 — effectively restarting the entire licensing process, including a new site inspection.
Benefits of Renewing Your Cosmetic License on Time
- Uninterrupted business — no gap in legal authorization to import, manufacture, sell, or distribute.
- Avoids the 2% monthly late fee (COS-8) or a complete filing restart (COS-2, since lapsed certificates can't be revived).
- Protects stock from seizure and the business from penalties under the Drugs and Cosmetics Act, 1940.
- Maintains credibility with retailers, e-commerce marketplaces, and consumers who check registration numbers on labels.
- Keeps your SUGAM portal profile active, which speeds up future product additions or category expansions.
Common Mistakes That Delay Cosmetic License Renewal
- Waiting until close to the expiry date instead of starting the COS-2 renewal six months in advance.
- Submitting a Free Sale Certificate or label that no longer matches the current product formulation.
- Assuming COS-8 renews automatically without tracking the 5-year retention due date.
- Mismatched names, addresses, or product details across documents — a leading cause of CDSCO queries.
- Not budgeting for the 2% monthly late fee on COS-8, which compounds quickly if retention is delayed.
Conclusion
Renewing a cosmetic license in India comes down to knowing which pathway applies to you. Importers must treat the COS-2 certificate's 5-year validity as a strict deadline and file the renewal through SUGAM well in advance, since a lapsed certificate cannot be revived. Manufacturers, on the other hand, keep their COS-8 license alive simply by paying the retention fee on time every five years — but a missed payment carries its own escalating late fees and, eventually, cancellation. Staying ahead of either deadline is the simplest way to keep your cosmetic business fully compliant and running without interruption.
This guide reflects the Cosmetics Rules, 2020 and current CDSCO/SUGAM practice as of 2026. Fee amounts fall under the Third Schedule and are subject to government revision, so always verify the live figure on the SUGAM portal before submitting payment.
Frequently Asked Questions
What happens if my COS-2 import registration expires before I renew it?
Once a COS-2 certificate lapses, Indian rules do not allow retrospective renewal — imports must stop, and you would need to file a fresh COS-1 application rather than a simple renewal.
Does the COS-8 manufacturing license ever expire?
No. COS-8 remains valid indefinitely unless the State Licensing Authority suspends or cancels it. It only requires a retention fee payment every five years, not a fresh license.
How early should I start the COS-2 renewal process?
Start around six months before your current COS-2 certificate's expiry date, since document review and any CDSCO queries can take time to resolve.
What is the retention fee for a COS-8 manufacturing license?
Typically ₹10,000 for up to 10 items in a cosmetic category, plus ₹500 per additional item and ₹10,000 per additional category, as per the Third Schedule of the Cosmetics Rules, 2020.
What is the late fee if I miss the COS-8 retention deadline?
A late fee of 2% of the retention fee is charged for every month of delay. If the fee remains unpaid for 180 days, the license is deemed cancelled.
How long does COS-2 renewal approval take?
Most complete filings are approved in 60–90 days, though the Cosmetics Rules, 2020 permit the licensing authority up to 180 working days where documentation needs correction.
Do I need a site inspection again during renewal?
For COS-2, generally no, unless CDSCO specifically requests one. For COS-8 retention, an inspection may be required only if you're adding new categories, products, or premises.
Can one renewed certificate cover multiple cosmetic products?
Yes — if the products fall under the same manufacturer and category, a single COS-2 or COS-8 renewal can continue to cover them, subject to correct category mapping.
Who is responsible for tracking the renewal or retention deadline?
The certificate or license holder — the importer, agent, or manufacturer — not CDSCO or the State Licensing Authority. There is no guaranteed reminder system, so internal tracking is essential.
What's the core difference between COS-2 renewal and COS-8 retention?
COS-2 renewal is a fresh application-style filing with a hard 5-year cutoff and no lapse tolerance. COS-8 retention is simply a fee payment to keep an otherwise perpetual license active, with a 180-day grace window before cancellation.
Can I add new products at the time of renewal?
Yes, both COS-2 renewal and COS-8 retention filings can include new variants or categories, though this may attract additional government fees and, for manufacturing, a fresh inspection.
