COS-2 is the import registration certificate issued to the foreign manufacturer under Rule 13 of the Cosmetics Rules 2020. Valid in perpetuity subject to 5-yearly retention fees under Rule 14. Distinct from the Indian importer's COS-1 license — both are required for lawful import.
Every cosmetic product manufactured outside India and imported for sale requires two distinct authorisations. The Indian importer holds a COS-1 license. The foreign manufacturer holds a COS-2 registration certificate. Both are mandatory. Neither substitutes for the other.
COS-2 is the import registration certificate issued by the Central Licensing Authority under Rule 13 of the Cosmetics Rules 2020. It is granted to the foreign manufacturer — or to their authorised agent acting on the manufacturer's behalf — and it registers specific cosmetic products, from a specific manufacturing site, for import into India. Without a valid COS-2, no Indian importer can lawfully bring those products across the border, regardless of what their own COS-1 license permits.
This page covers what COS-2 is, how it differs from COS-1, the complete Rule 13 application process, fees under the Third Schedule, the perpetual validity mechanism under Rule 14, and how to add products to an existing certificate via endorsement.
The confusion between COS-1 and COS-2 is common and consequential. They are not two names for the same thing. They are two stages of the same regulatory process, held by two different parties.
COS-1 is the application form. It is submitted via the SUGAM portal by the applicant — the manufacturer, their authorised agent, the Indian importer, or the Indian subsidiary — to initiate registration.
COS-2 is the registration certificate. It is the document that Rule 13(1) empowers the Central Licensing Authority to issue "on being satisfied" after examining the COS-1 application and supporting documents.
In practice, COS-1 refers colloquially to the importer's import license (issued under a separate track for the Indian entity), while COS-2 refers to the foreign manufacturer's product registration certificate. The distinction matters at the port of entry: Customs will verify that the importer's COS-1 license covers the product category and that the foreign manufacturer holds a valid COS-2 for those specific products from that specific site. A mismatch on either document will result in clearance refusal.
The COS-2 certificate is issued in respect of the foreign manufacturer's products. The applicant may be:
- The foreign manufacturer directly
- Their appointed authorised agent in India
- The Indian importer
- An Indian subsidiary of the foreign manufacturer
In the overwhelming majority of import transactions, the application is filed by the authorised agent. The granted certificate text explicitly records that it is "issued through the office of" the authorised agent, who is responsible for the manufacturer's Indian business "in all respects" under Rule 3(d).
The authorised agent is defined under Rule 3(d) as "a person in India authorised by the manufacturer" who "shall be responsible for the business activities of the manufacturer in India including compliance to the provisions of the Act and rules made thereunder." The agent does not merely file paperwork — they carry ongoing compliance liability for every product registered under the manufacturer's COS-2.
Applications are filed via the SUGAM portal using Form COS-1. Rule 12(2) specifies that "an application for registration of a cosmetic product intended to be imported into India shall be made through the online portal of the Central Government in Form COS-1."
Rule 13(1) sets the review standard and timeline: "After examination of documents furnished with the application under sub-rule (2) of rule 12, the Central Licensing Authority may, on being satisfied, grant import registration certificate in Form COS-2 or may reject such application for which reasons shall be recorded in writing within a period of six months from the date of application."
The six-month clock starts from the date of application submission. Incomplete submissions trigger a stop-clock notice; the clock restarts only when all outstanding documents are received.
The application under Rule 12 and Part I of the Second Schedule requires:
1. Form COS-1 — completed and submitted via SUGAM
2. Covering letter — signed and stamped by the authorised agent
3. Power of Attorney / Authorisation — from the foreign manufacturer to the Indian authorised agent, prepared per the First Schedule template, apostilled or authenticated through the Indian embassy in the manufacturer's country
4. Manufacturer particulars — details of the manufacturing entity and premises
5. Product details — brand names, all variants, pack sizes
6. Manufacturing licence and Free Sale Certificate — from the competent authority in the country of origin, confirming the products are licensed for manufacture and sale there
7. List of countries with import permission or marketing authorisation for the products
8. Ingredient information — full INCI list with concentrations, functions, and CAS numbers for each ingredient
9. Draft labels — compliant with Rule 34 and Chapter VI of the Cosmetics Rules 2020
10. BIS specifications — per the Ninth Schedule, where applicable
11. Legal undertaking — signed declaration confirming compliance with Indian BIS standards, non-animal testing, and heavy metal limits per IS 4707
For bulk finished formulations imported for filling and packaging in India, an additional requirement applies: a valid manufacturing licence from the State Licensing Authority for the Indian entity that will undertake the fill operation, plus details of the registered brand owner in India.
The authorised agent signs and stamps both the Form COS-1 and the covering letter. Every document in the Second Schedule dossier must be attested by the agent before upload to SUGAM.
COS-2 does not expire on a fixed date. Rule 14(1) states: "A registration certificate granted under rule 13 shall remain valid in perpetuity, subject to payment of registration certificate retention fee as specified in the Third Schedule before completion of the period of five years from the date of its issue, unless it is suspended or cancelled by the Licensing Authority."
Perpetual validity is therefore conditional, not unconditional. The retention fee must be paid before every five-year anniversary of the certificate's issue date. Miss the deadline, and the consequences are severe.
Rule 14(2) sets out the late payment mechanism exactly: "If the licensee fails to pay the required registration certificate retention fee on or before the due date as referred to in sub-rule (1), the registration certificate holder shall, in addition to the registration certificate retention fee, be liable to pay a late fee calculated at the rate of two per cent. of the registration certificate retention fee for every month or part thereof within one hundred and eighty days and in the event of non-payment of such fee during that period, the registration certificate shall be deemed to have been cancelled."
The structure is: 180 days of late payment at 2% per month, then automatic cancellation. There is no reinstatement mechanism — cancellation under Rule 14(2) requires a fresh application.
Tracking the five-year retention due date is the single most operationally critical compliance task associated with COS-2.
Item | Fee
Registration of one cosmetic category, one manufacturing site | USD 1,000
Each additional manufacturing site | USD 500
Each variant within a registered category | USD 50
Each additional cosmetic category | USD 1,000
Retention fee (every 5 years) | Same as original grant fee
Late retention fee | 2% per month on retention fee, up to 180 days
Fees are paid in Indian Rupees at the exchange rate applicable on the date of payment, via the SUGAM portal payment gateway.
Rule 13(4) permits a single COS-2 certificate to cover "one or more cosmetics manufactured by the same manufacturer." Adding products to an existing COS-2 — rather than applying for a new certificate — is handled through endorsement.
The endorsement process requires a fresh COS-1 application on SUGAM referencing the existing COS-2. The covering letter must cite the existing certificate number and registration date. The dossier includes the updated product documents — labels, ingredient lists, specifications — for the products being added.
Fee implications: if the new products fall within an already-registered category and are manufactured at the same site already registered under the COS-2, no additional fee applies. If the addition involves a new product category or a new manufacturing site, the corresponding Third Schedule fees apply.
CDSCO's official guidance clarifies: "Importer has to apply for endorsement to the existing valid Registration Certificate along with the requisite documents except fees if the category is already registered and provided that the additional product(s) are being manufactured at the same manufacturing site."
The endorsement route is significantly faster than a new COS-2 application and is the correct path for any portfolio expansion by a manufacturer already registered in India.
The COS-2 certificate is structurally tied to the authorised agent named on it. An agent change is not administrative — it is a post-approval change that requires a formal process under Rule 15.
If the change is a "change in constitution" of the registration holder, Rule 15(1) requires a fresh application within 180 days. The existing COS-2 remains valid during this period.
For a straightforward change of agent without a change in constitution, Rule 15(3) governs amendments for changes in the name or address of the registration holder. This is processed as an amendment application on SUGAM.
If the authorised agent fails their compliance obligations or is de-registered, Rule 16 empowers the Central Licensing Authority to suspend or cancel the COS-2 certificate outright. A foreign manufacturer whose Indian agent becomes non-compliant does not retain a valid registration by default — the certificate and the agent's standing are legally linked.
Foreign manufacturers must vet their authorised agent appointment carefully. A change of agent mid-registration creates regulatory exposure across the entire product portfolio registered under that COS-2.
The authorised agent named on a COS-2 must themselves be registered with CDSCO. CDSCO maintains a register of authorised agents, and only entities on that register may act in the agent capacity for COS-2 applications. This requirement operates independently of the COS-2 application itself — an agent who is not registered with CDSCO cannot file or hold a COS-2 on a manufacturer's behalf, regardless of the validity of their Power of Attorney.
When appointing an agent, foreign manufacturers must confirm that the agent holds active CDSCO registration before the COS-1 application is filed. An application filed by an unregistered agent will be rejected.
CDSCO records rejection reasons in writing under Rule 13(1). The most common deficiencies leading to rejection or stop-clock notices:
- Power of Attorney not apostilled or not authenticated through the Indian embassy — the authentication route depends on whether the manufacturer's country is a Hague Convention signatory
- Signatures on COS-1 or the covering letter not matching the authorised signatory recorded in the manufacturer's corporate documents
- Ingredient list incomplete — missing CAS numbers, concentrations, or functional roles
- Labels non-compliant with Rule 34 — missing mandatory declarations, incorrect font size for net content, or absent batch/manufacturing information
- Free Sale Certificate not covering all product variants listed in the application
- BIS specifications absent for products falling within a Ninth Schedule category
A rejection does not restart the process from zero — CDSCO records reasons in writing, and a fresh application addressing those reasons can be filed. But the six-month clock does not carry over; each application runs its own timeline.
COS-2 is the foreign manufacturer's entry credential for the Indian market. It operates independently of the Indian importer's COS-1 license, and no import transaction is complete without both. Cosmetics Consultants India manages the full COS-2 registration lifecycle — initial application, endorsement for new products, retention fee compliance, and agent change amendments. Contact us to assess your registration position.
COS-1 is the mandatory import Registration Certificate for all cosmetics from non-SAARC countries under Rule 12(1) of the Cosmetics Rules 2020. We manage the full application — Second Schedule, Letter of Authorization, fee calculation, and SUGAM portal filing.
Learn more →Rule 3(d) of the Cosmetics Rules, 2020 requires every COS-1 applicant to appoint an Authorised Agent — a person in India fully responsible for the manufacturer's regulatory compliance. We act as Authorised Agent for foreign manufacturers across all product categories.
Learn more →Complete fee schedule and processing timeline for COS-1 and COS-2 import registration under the Cosmetics Rules 2020. Covers category, site, and variant fees; Rule 14 retention obligations; Rule 15 amendment fees; and statutory timeline mechanics.
Learn more →Want to learn more?
Our blog covers Import Licensing topics in depth — guides, checklists, and regulatory updates.