COS-8 is the manufacturing license required under Rule 23 of the Cosmetics Rules 2020 for any person manufacturing cosmetics for sale or distribution in India. Issued by the State Licensing Authority, it is valid in perpetuity subject to 5-yearly retention fees.
India's Cosmetics Rules 2020 draw a hard line before the first batch leaves your facility. Rule 33 prohibits the sale or distribution of any cosmetic of Indian origin unless it is "manufactured by a licensed manufacturer." That license is the COS-8, granted under Rule 23 by the State Licensing Authority (SLA) — the State Drugs Controller of your state. No COS-8 means no lawful sale, regardless of product quality or brand standing.
This guide covers every aspect of the COS-8 license: the legal framework, complete document checklist, fee schedule, application process, GMP obligations under the Seventh Schedule, and the validity and retention structure that keeps your license alive.
Rule 23(1) is unambiguous: "Any person who intends to manufacture cosmetics shall make an application for grant of a licence or loan licence to manufacture for sale or for distribution to the State Licensing Authority."
The obligation applies to all cosmetic categories listed in the Fourth Schedule — skin care, hair care, colour cosmetics, oral care, fragrances, nail care, and every other category the Rules recognise. There is no threshold quantity below which the license is not required. One unit manufactured for sale triggers the obligation.
Rule 4(2) establishes the SLA's exclusive jurisdiction: "The State Drugs Controller, by whatever name called, shall be the State Licensing Authority and the competent authority for enforcement of these rules in matters relating to — (i) manufacture for sale or distribution of all categories of cosmetics." CDSCO has no role in COS-8 issuance. This is entirely a state authority function.
Rule 23 contains the complete framework for manufacturing licensing:
Rule 23(1): Mandates the license application to the SLA
Rule 23(2): Specifies that the application must be in Form COS-5, accompanied by documents in Part II of the Second Schedule
Rule 23(4): Confirms the document and fee requirements
Rule 23(9): Authorises the SLA to cancel a license where the self-certificate of GMP compliance (Form COS-7) is found to contain false information, after giving the licensee a show-cause opportunity
Rule 24: Requires a separate application and separate COS-8 for each distinct manufacturing premises — a single license does not cover multiple sites
Rule 33 completes the enforcement frame: no licensed manufacturer, no lawful sale.
The complete document requirement is set out in Part II of the Second Schedule under Rule 23(2). Every document below is mandatory:
1. Fee payment receipt or challan — proof of online payment via SUGAM portal
2. Approved layout plan of the manufacturing area — must be SLA-approved before submission
3. Premises possession documents — ownership deed, or rent/lease agreement (minimum 10-year term if rented), with notarized copies where premises are not owned
4. List of machinery and equipment — all manufacturing and testing equipment at the site
5. Constitution of the firm — Partnership Deed, Memorandum and Articles of Association, Certificate of Incorporation (CIN issued by MCA/ROC), or Udyam Aadhaar for proprietorships and MSMEs
6. Technical staff particulars — full details of qualified technical personnel, including copies of educational qualification certificates and experience certificates; a consent letter confirming full-time employment at the site
7. Product list with composition formulae — in triplicate; each product listed with complete ingredient formula and proposed labelling
8. Brand ownership documents — trademark registration certificate from IP India, or evidence that the trademark application is pending
9. Full name of proprietor, partners, or Directors/Authorised Signatory
10. Form COS-7 self-certificate — self-declaration of GMP compliance per the Seventh Schedule
11. Signed undertaking — declaring compliance with all license conditions, confirming no animal testing, committing to conform to BIS standards, and agreeing to report administrative changes
NOCs from Fire, Pollution Control Board, and GST registration are required by most SLAs as a practical matter, though the precise list of ancillary NOCs varies by state.
Fees under the Third Schedule (Manufacturing Licence section) are structured by product volume and category:
Fee Head | Amount
Grant of COS-8 — up to 10 items per category | ₹10,000
Each additional item within a category | ₹500
Each additional category (up to 10 items) | ₹10,000
5-year retention fee (same structure as above) | ₹10,000 base
Duplicate license (defaced, damaged, or lost) | ₹500
Re-application after rejection | ₹1,000
Late retention fee | 2% per month on outstanding amount
All fees are paid online through the SUGAM portal (cdscoonline.gov.in). A manufacturer producing skin care and hair care products across 15 SKUs would pay ₹10,000 for the first category (10 items), ₹2,500 for the five additional skin care SKUs, and ₹10,000 for the hair care category — a total of ₹22,500 at application.
Finalise your manufacturing premises layout and obtain SLA approval for the layout plan before filing. Recruit qualified technical staff. Complete in-house GMP readiness per the Seventh Schedule.
Submit the application online at cdscoonline.gov.in using Form COS-5. Attach all documents from Part II of the Second Schedule. Pay the applicable fee. For Delhi, the application routes through the Delhi Drugs Control Department's portal linked to SUGAM.
The SLA reviews the application for document completeness and regulatory compliance. If the application is deficient, the SLA will return it with reasons under Rule 27(2). Deficiencies must be remedied and the application resubmitted; a fresh fee of ₹1,000 applies after a formal rejection.
An SLA officer inspects the premises to verify GMP compliance against the Seventh Schedule and the self-declaration in Form COS-7. If no inspection occurs within 30 days, the application is treated as deemed-approved for inspection purposes. False information in Form COS-7 is a ground for license cancellation under Rule 23(9).
On satisfaction of all requirements, the SLA issues the COS-8 license. The license is valid in perpetuity from the date of issue, subject to 5-yearly retention fee payments.
A critical correction that applies across all competitor pages: Schedule M (Cosmetics) — the old GMP schedule under the previous rules — has been explicitly omitted under the Thirteenth Schedule of the Cosmetics Rules 2020. GMP requirements are now entirely governed by the Seventh Schedule. References to Schedule M for cosmetics manufacturing are obsolete.
The Seventh Schedule mandates:
The factory must be sanitary, hygienic, well-ventilated, and strictly separated from residential areas. Walls and floors must be smooth, washable, coved at junctions, and free from cracks. Adequate lighting throughout.
Sufficient qualified and experienced personnel. Workers must be free from contagious diseases. Clean uniforms, masks, and head coverings are mandatory in production areas.
Potable water supply to all production and testing areas. Waste and effluents must be disposed of in compliance with Environmental Pollution Control Board norms.
Mandatory sampling, inspection, and testing of raw materials, packaging materials, in-process materials, and finished products. All testing records maintained per the Eighth Schedule.
Regular servicing, calibration, and maintenance of all production and testing equipment. Records of calibration and maintenance must be retained.
The Seventh Schedule specifies equipment requirements by product category. Nail polish manufacturing requires flameproof exhaust systems. Aerosol products have separate containment and pressure testing requirements. These are not optional — they are conditions of the license.
Rule 30(1) states the COS-8 "shall remain valid in perpetuity, subject to payment of licence or loan licence 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 State Licensing Authority."
The perpetuity structure means there is no renewal cycle in the conventional sense. The license does not expire at five years — it lapses only if the retention fee is not paid. Rule 30(2) sets the consequences:
Late payment attracts a fee of 2% per month on the outstanding retention amount
Failure to pay within 180 days of the retention due date: the license is deemed cancelled by operation of law
A deemed cancellation under Rule 30(2) is automatic — there is no show-cause requirement. Reinstatement requires fresh application and payment of the re-application fee.
Applications fail most frequently on these grounds:
Unapproved premises layout — layout submitted without prior SLA approval
Unqualified technical staff — nominated technical person lacks the qualification threshold (Diploma in Pharmacy, B.Sc. Chemistry, or equivalent as required by the SLA)
Missing or deficient Form COS-7 — GMP self-certificate incomplete or inconsistent with inspection findings
Premises documents insufficient — rent agreement below 10 years, or lacking notarization where required
Product formula discrepancies — composition listed in Form COS-5 inconsistent with product labels submitted in triplicate
SUGAM portal mismatches — document uploads not matching the declared details in the online form
Rule 23(1) covers manufacturing for all purposes, including export. A single COS-8 authorises manufacturing for both domestic sale and export from the same licensed premises. The label compliance requirement diverges at the point of export: Rule 34(10) directs that labels on exported cosmetics "shall meet the specific requirements of law of the country to which the cosmetic is to be exported." The domestic Mfg. Lic. No. requirement under Rule 34(2)(b) remains applicable unless the destination country law differs.
COS-8 is issued under Cosmetics Rules 2020 by the SLA in its cosmetics licensing capacity. If a manufacturer also produces drug products — including any product that crosses the Rule 36 threshold into drug classification — a separate drug manufacturing license under the Drugs Rules is required. The SLA issues both but under distinct regulatory frameworks. A pure cosmetics manufacturer with no drug product lines requires only the COS-8. The product list in your COS-8 application determines scope — cosmetics claiming therapeutic efficacy risk classification as drugs under Rule 36, which changes the licensing requirement entirely.
For labelling of domestically manufactured cosmetics, Rule 34 governs. The Mfg. Lic. No. must appear on every domestic product label under Rule 34(2)(b). Imported cosmetics carry the RC No. instead under Rule 34(5) — the distinction is explicit in the rule text.
The COS-8 is the foundational authorization for every cosmetics manufacturer selling in India. Rule 23 sets the obligation, the Seventh Schedule sets the GMP standard, and Rule 30 governs the perpetuity structure that keeps the license valid. A lapsed license — through missed retention fees or a Rule 23(9) cancellation — stops lawful manufacture immediately.
Cosmetics Consultants India manages COS-8 applications, Seventh Schedule GMP readiness assessments, and retention tracking for manufacturing clients across India. Contact us to begin your application or audit your existing license compliance.
COS-8 manufacturing licenses are issued by the State Licensing Authority under Rule 23(1) of the Cosmetics Rules, 2020. This page covers the application process, Seventh Schedule GMP requirements, fees, validity, and the 2025 amendments.
Learn more →The Seventh Schedule of the Cosmetics Rules 2020 is the sole GMP standard for cosmetics manufacturing in India. COS-8 grant and renewal are both conditioned on Seventh Schedule compliance under Rule 26(b). This page sets out what the schedule requires, how the State Licensing Authority verifies it, and what foreign manufacturers must demonstrate for import registration.
Learn more →Schedule M-II was omitted by Thirteenth Schedule, Clause 22 of the Cosmetics Rules 2020. The Seventh Schedule is the current GMP standard for cosmetics manufacturing in India, operative through Rule 23(4) and Rule 26(b).
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