Rule 12(1) of the Cosmetics Rules, 2020 prohibits import of any cosmetic without a valid Registration Certificate. This page covers the complete framework: COS-1 application, COS-2 grant, COS-4 secondary import, renewal under Rule 14, and the four compliance pillars every importer must satisfy.
Importing a cosmetic product into India without a valid registration certificate is prohibited under Rule 12(1) of the Cosmetics Rules, 2020. The exact prohibition reads: "No cosmetic shall be imported into India unless the product has been registered in accordance with these rules by the Central Licensing Authority or by any officer to whom such powers may be delegated under sub-rule (1) of rule 5." The statutory basis is Section 10 of the Drugs and Cosmetics Act, 1940. Compliance applies to every cosmetic imported for commercial sale, regardless of origin country.
This page explains the complete import licensing framework: the forms involved, the pathway from application to authorisation, the four compliance pillars that must be satisfied in parallel, and the rules governing renewal, secondary import, and test imports.
The Cosmetics Rules, 2020 (effective January 2, 2021) replaced the Cosmetics Rules, 1945 and established the current import licensing regime. The Central Licensing Authority under Rule 3(f) is the DCGI, operating through CDSCO.
Three rules form the operational core:
Rule 12 governs the application. Rule 12(2) requires the application to be filed via SUGAM in Form COS-1 by the manufacturer, their authorised agent, the importer, or an authorised Indian subsidiary. Rule 12(3) mandates a duly authenticated authorisation. Rule 12(4) requires all information and documents specified in Part I of the Second Schedule. Rule 12(5) requires proof of fee payment per the Third Schedule.
Rule 13 governs the grant. After examining the submitted documents, the Central Licensing Authority grants the Import Registration Certificate in Form COS-2 or rejects the application with written reasons. Rule 13(1) specifies the processing period as six months from the date of application.
Rule 17 governs secondary import registrations. Any person seeking to import a cosmetic already registered under Rule 13 by another entity may apply in Form COS-4 with the undertaking specified in the Sixth Schedule. Rule 17(2) provides for the grant of an Import Registration Number in Form COS-4A. Rule 17(3) sets the validity of a COS-4A at three years.
Form COS-1 is the application form submitted to CDSCO to obtain primary import registration. It is not a licence — it is the application that, if approved, results in a licence.
Form COS-2 is the Import Registration Certificate issued by CDSCO under Rule 13(1). Rule 3(k) defines it: "'Import registration certificate' means a certificate issued under rule 13 by the Central Licensing Authority for registration of cosmetics manufactured for import into and use in India." COS-2 is valid in perpetuity, subject to retention fees under Rule 14.
Form COS-4 / COS-4A is the secondary import pathway. Where a COS-2 already exists for a product, a third-party importer may apply via Form COS-4 to obtain an Import Registration Number (Form COS-4A) under Rule 17. COS-4A is valid for three years per Rule 17(3). No re-testing is required.
The COS-1 → COS-2 pathway is for the manufacturer or their direct representative obtaining primary registration. The COS-4 → COS-4A pathway is for any subsequent importer distributing the same registered product independently.
A COS-2 registration certificate authorises import. It does not, by itself, authorise legal sale. Three further compliance requirements must be satisfied in parallel:
1. Import licensing (CDSCO) — COS-2 under Rule 13, or COS-4A under Rule 17. This is the gateway.
2. Labelling compliance — Rule 35 prescribes mandatory front-of-pack and back-of-pack elements including INC ingredient names, country of origin, importer name and address, batch number, date of manufacture, date of expiry, and net quantity. Rule 36 restricts claims — any claim implying medicinal, therapeutic, or drug-like effect triggers reclassification under Section 3 of the Drugs and Cosmetics Act.
3. Legal metrology — An LMPC registration under the Legal Metrology (Packaged Commodities) Rules, 2011 is mandatory for any entity selling pre-packaged cosmetics in India. LMPC is a separate registration from CDSCO, issued by DPIIT. Absence of LMPC is a distinct violation, independent of COS-2 status.
4. Product testing — Cosmetics must comply with applicable standards under Rule 39 and the Ninth Schedule. BIS standards under IS 4707 apply to composition and safety. IS 14648-2011 governs microbiological testing.
All four pillars must be satisfied. A COS-2 held while the label is non-compliant, LMPC is absent, or the product fails IS 4707 testing results in legal exposure at import and retail stage.
1. Identify the applicant entity under Rule 12(2): manufacturer, authorised agent, importer, or authorised Indian subsidiary.
2. Prepare Second Schedule Part I documentation: product composition with INC names and CAS numbers, ingredient percentages, manufacturing site details, all variants and pack sizes, claims, manufacturer's licence from country of origin, and Free Sale Certificate.
3. Authenticate the Letter of Authorization per Rule 12(3) and the First Schedule — by First Class Magistrate, Indian Embassy, or apostille.
4. Register on SUGAM (cdscoonline.gov.in) under the applicable role. Submit Form COS-1 with all documents attached and fee paid per the Third Schedule.
5. Respond to any CDSCO queries within the specified period. Each unanswered query triggers a stop-clock notice — the 6-month processing period under Rule 13(1) is suspended until the query is resolved.
6. COS-2 issued upon approval. Produced at the port of entry for each import consignment.
August 2024 restriction (F. No. COS-1018(11)/5/2024): COS-1 applications are capped at 50 products. Applications exceeding this limit are returned without processing.
Item | Fee
Registration Certificate (per category, up to 10 items) | Rs. 1,000 / USD 100
Additional variants | USD 50 per variant
Manufacturing site | USD 500 per site
Duplicate certificate | Rs. 500 / USD 50
Retention (every 5 years) | Same as grant fee
Late retention (grace period: 180 days) | 2% per month
Processing time: 6 months from complete receipt under Rule 13(1). Stop-clock mechanism suspends this period during query-response cycles.
COS-4A validity: 3 years from issue per Rule 17(3).
COS-2 validity: Perpetual, subject to retention fee every 5 years under Rule 14. Failure to pay within 180-day grace period results in deemed cancellation under Rule 14(2).
Rule 14(1) governs retention of the Registration Certificate — fees due every 5 years. Under Rule 14(2), if unpaid by the due date, a 180-day grace period applies with a late fee of 2% per month. If unpaid after 180 days, the registration certificate is deemed cancelled by operation of Rule 14(2) — no separate cancellation order is required.
The February 2024 CDSCO circular requires all COS-2 holders to submit annual import data through SUGAM. Failure to comply is a condition violation under Rule 16.
Rule 64(1) provides exemptions for categories listed in the Twelfth Schedule. Item 3(ii) of the Twelfth Schedule exempts cosmetics imported for R&D purposes — including packaging trials, consumer studies, shelf life studies, and transport studies — from Chapter III registration requirements, on the strict condition that these products are not used for domestic sale.
Rule 18(1) separately provides that cosmetics otherwise prohibited in their country of origin may be imported solely for examination, test, or analysis. In both cases, a No Objection Certificate from the concerned CDSCO Port Office is required per CDSCO FAQ 51.
Rule 16 governs suspension and cancellation of a Registration Certificate where the manufacturer or authorised agent fails to comply with any condition. The CLA must issue a show-cause notice before any order.
Rule 14(2) provides for automatic deemed cancellation upon failure to pay retention fees within the 180-day grace period — no show-cause process applies.
Cosmetics Consultants India manages end-to-end COS-1 registration for foreign manufacturers and Indian importers — from Second Schedule preparation and LOA authentication to SUGAM filing and query response. Contact us to assess your product's registration pathway.
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.
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