Rule 15 of the Cosmetics Rules 2020 governs all post-approval changes to COS-1 and COS-2. Three distinct tracks apply: endorsement of additional products, amendment of name or address, and change in constitution requiring fresh registration.
Post-approval changes to a COS-2 registration certificate or COS-1 import license are governed by Rule 15 of the Cosmetics Rules 2020. The rule distinguishes three distinct change categories — each with a separate procedure, timeline, and fee obligation. Conflating them is the most common error in post-approval management; it produces either defective applications or unlawful operation under a lapsed registration.
This page covers the full Rule 15 framework: endorsement of additional products, amendment of name and address details, and change in constitution. All applications are filed through the CDSCO SUGAM portal. Offline submissions are not accepted.
Rule 15 structures post-approval changes into three discrete tracks. The applicable track determines the application type, the required documents, the fee, and the processing timeline.
Track 1 — Endorsement of additional products (Rule 15(2) read with Second Schedule Part-I): Adding new cosmetic products or pack size variants to an existing COS-2 registration certificate. This is the most frequent post-approval action for importers managing growing portfolios.
Track 2 — Amendment of name or address (Rule 15(3)): Changes to the registered name or address of the registration holder or overseas manufacturer. Rule 15(3) requires prior approval from the Central Licensing Authority before the change takes operational effect.
Track 3 — Change in constitution (Rule 15(1)): Structural changes to the registration holder or overseas manufacturer — mergers, acquisitions, ownership restructuring, or any other change in legal constitution. Rule 15(1) treats this not as an amendment but as a trigger for a fresh registration under Rule 12(2).
Endorsement applies when an existing COS-2 holder seeks to add new product categories, new variants of registered products, or new pack sizes to their current registration certificate. It does not apply to changes in the registered entity's details — those fall under Track 2 or Track 3.
CDSCO clarified in its official FAQs that endorsement requires submission of information per Second Schedule Part-I for each new product being added. A fresh Second Schedule form is mandatory — the existing registration's Second Schedule does not carry forward to new products.
- Covering letter specifying the endorsement purpose and listing products to be added
- Second Schedule Part-I — complete submission for each new product category or variant
- Authorization from the overseas manufacturer in the prescribed format
- No Change Declaration for composition, labelling, specifications, and test methods (applicable where variants of already-registered products are being added)
- Applicable fees via SUGAM payment module
Change Type | Fee (USD)
Each additional product category | 1,000
Each additional variant | 50
Each additional manufacturing site | 500
Fees are paid at the time of application submission through SUGAM. Up to five payment challans may be uploaded per application.
As of February 22, 2025, CDSCO mandated that all cosmetic variant approvals and endorsement applications be filed exclusively through the SUGAM portal's dedicated endorsement module. Paper or email submissions are not valid.
1. Log into the SUGAM portal and select the Cosmetics department
2. Select application type: Endorsement
3. Complete the online form and proceed to the Checklist module
4. Upload all required documents per the checklist
5. Submit and complete fee payment (SUGAM generates the payment reference)
6. Upload payment proof — maximum five challans
7. Submit Form COS-1/COS-2 as generated by SUGAM
8. Application forwarded to the Designated Officer for compliance review
9. If documents are complete, forwarded to the Central Licensing Authority for approval
10. Discrepancies, if any, communicated via the SUGAM dashboard
Stop-clock risk: As of January 16, 2026, CDSCO automatically rejects applications where regulatory queries remain unanswered for 90 days after the first reminder. Monitor your SUGAM dashboard after submission. An unanswered query does not generate a physical notice — the rejection is administrative and the application must be refiled.
180 working days from the date of complete receipt. Incomplete submissions trigger a stop-clock notice; the 180-day clock restarts only after the deficiency is resolved and re-filed correctly.
Rule 15(3) applies when the registered name or address of the COS-2 holder or overseas manufacturer changes — for example, a company rebranding, relocation of manufacturing premises, or change in the authorised agent's registered address.
Rule 15(3) requires that an application for amendment be made on the SUGAM portal within 60 days of the date of such change, and that the Central Licensing Authority's prior approval be obtained before the change is treated as effective on the registration certificate.
Operating under a changed name or address without prior CLA approval is a registration compliance failure.
- Covering letter citing Rule 15(3) and identifying the specific change
- Evidence of the change (e.g., company registration certificate with updated name, lease or ownership document for new address)
- Copy of existing COS-2 registration certificate
- Authorization confirming the applicant's authority to make the amendment
No separate statutory timeline is prescribed under Rule 15(3) beyond the 60-day filing obligation. Processing follows standard SUGAM review timelines; the existing COS-2 remains valid during the pendency of an amendment application.
Change in constitution is the highest-risk post-approval event in cosmetics registration management. Rule 15(1) is unambiguous: when the constitution of a registration holder or overseas manufacturer changes after COS-2 has been granted, the holder must file a fresh application under Rule 12(2) within 180 days of the date of change in constitution.
This is not an amendment — it is a new registration. The full Rule 12(2) application process applies, including a complete Second Schedule Part-I submission, all supporting documents, and full Third Schedule fees.
Acquisition of one company by another, merger, demerger, change in partnership, or any other restructuring that alters the legal identity or ownership structure of the registration holder or the overseas manufacturer triggers Rule 15(1). CDSCO FAQs confirm that acquisition of a manufacturer by another company is explicitly classified as a change in constitution requiring a fresh application.
Rule 15(1) includes a critical proviso: the existing COS-2 registration is deemed valid until either the fresh registration is granted or the application is rejected by the Central Licensing Authority. This deemed validity provision prevents a gap in import authorization during the pendency of the fresh application — provided the fresh application is filed within the 180-day window.
If the fresh application is not filed within 180 days, the deemed validity provision does not apply. The existing COS-2 loses its legal standing, and import under that certificate is unauthorized from that point.
Because Rule 15(1) mandates a fresh application under Rule 12(2), full Third Schedule fees apply:
Item | Fee (USD)
Each product category | 1,000
Each variant | 50
Each manufacturing site | 500
There is no fee concession for a change-in-constitution application relative to a first-time registration.
Rule 15(2) governs a separate category — changes to the labelling, composition, testing, or specifications of a product already registered under COS-2. This is not an endorsement and not an amendment in the Track 2 sense. Rule 15(2) requires the Central Licensing Authority to be informed in writing within 15 days of such a change, along with an undertaking that the product continues to comply with the BIS standards specified in the Ninth Schedule.
Rule 15(2) notification does not require prior CLA approval before the change is implemented, but the 15-day window is mandatory. Failure to notify within 15 days is a registration compliance breach.
Rule 14 governs COS-2 retention independently of any pending amendments or endorsements. A COS-2 is valid in perpetuity subject to payment of the retention fee specified in the Third Schedule before the completion of each five-year period.
No pending amendment, endorsement, or change-in-constitution application suspends the retention fee obligation. If the retention fee is not paid on schedule, a 2% monthly late fee accrues for 180 days; after that period, the registration certificate is deemed cancelled under Rule 14. Cancellation under Rule 14 is not reversed by a pending Track 2 or Track 3 application — the endorsement or amendment process becomes void along with the underlying registration.
Track the retention fee deadline independently of any ongoing post-approval change process.
Changes to a COS-1 import license — changes to the authorised agent, importer details, or product scope — follow the same Rule 15 framework as COS-2. Where the change in question involves a structural change to the importer or agent, a fresh COS-1 application under Rule 12(2) is required. The SUGAM portal processes COS-1 amendments through the same module structure as COS-2.
Post-approval changes to a COS-2 or COS-1 require accurate classification of the change type before any application is prepared. Misclassification — filing a Track 2 amendment when Rule 15(1) demands a fresh application — produces defective submissions and exposes the registration holder to a compliance gap. Cosmetics Consultants India manages the full post-approval change cycle across COS-1 and COS-2 portfolios. Contact us to assess the correct filing track for your specific change.
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.
Learn more →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.
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