Q.01

How do I import cosmetics into India?

To import cosmetics into India, each product must first be registered with CDSCO. The Drugs Controller General of India (the Central Licensing Authority) grants an Import Registration Certificate in Form COS-2 after an online application in Form COS-1 on the SUGAM portal. Rule 12(1) of the Cosmetics Rules, 2020 says "No cosmetic shall be imported into India unless the product has been registered" (Cosmetics Rules, 2020, CDSCO text, p.8). The registration covers the product, its pack sizes, variants and manufacturing premises [1].

Approach: I read CDSCO's guidance on cosmetics import registration (19.01.2021) and CDSCO circulars and public notices up to October 2026. I also read the Cosmetics Rules, 2020 (G.S.R. 763(E), 15.12.2020) as CDSCO publishes them on its website.

1. Who applies

  • Applicant: the foreign manufacturer itself, its authorised agent, the importer in India, or an Indian subsidiary authorised by the manufacturer (Rule 12(2)) [2].
  • Responsibility of the authorised agent: the agent "shall be responsible for the business activities of the manufacturer in India including compliance" with the Act and rules (Rule 3(d), Rules p.2).
  • Already-registered products: if a product is already registered under Rule 13, any other importer can apply in Form COS-4 to get an Import Registration Number in Form COS-4A. That number is valid for three years (Rule 17, Rules p.12).
    • Since 23 Feb 2024, CDSCO has required holders of a COS-4A number to send an annual statement of their imports. It must cover the consignments or bills of entry, quantities, cost and warehouse details [3].
  • New cosmetics: a product with a novel ingredient first needs prior permission in Form COS-3 (Rule 13(3), Rules p.10).

2. The COS-1 dossier

Per CDSCO's guidance:

  • Covering letter: states whether the application is fresh, an endorsement or a re-registration [p2].
  • Manufacturer's authorisation (First Schedule):
    • It must be authenticated by a First Class Magistrate in India, by an equivalent authority in the country of origin, by the Indian Embassy, or by apostille.
    • Both the manufacturer and the Indian agent sign it jointly.
    • Products are categorised as in the Fourth Schedule [p2][p8].
  • Second Schedule Part I information and undertakings: particulars of the manufacturer and Indian agent, the list of countries where the product is authorised, ingredients, specifications, labelling, and compliance undertakings [p10][p11].
  • Composition: ingredients with their percentages [p3]. The guidance also says:
    • No raw materials from Annex A of IS 4707 Part 2.
    • Only the colours permitted under IS 4707 and the Tenth Schedule.
    • Limits on permitted colours: arsenic 2 ppm, lead 20 ppm, other heavy metals 100 ppm.
    • Mercury: not more than 70 ppm as a preservative in eye-area products, and unintentional mercury not more than 1 ppm in other products.
    • Lead and arsenic compounds are prohibited for colouring [p3][p4].
  • Specifications and test methods: to the Ninth Schedule BIS standards or, for products the Ninth Schedule does not cover, the standards of the country of origin [p5].
  • Manufacturing licence or marketing authorisation from the country of origin, or an undertaking where no such licence exists there [p5].
  • Free Sale Certificate: from the national authority, or from a competent association authenticated by the Indian Embassy, or authenticated with an apostille. A chart must correlate it with the products in COS-1 [p5][p6].
  • No-animal-testing undertaking [p6].
  • Heavy metals and hexachlorophene: test reports or an undertaking [p6].

3. Fees and timelines

  • Fees (Third Schedule), paid through Bharatkosh [p6][p7]:
    • US$1,000 per category of cosmetics
    • US$500 per manufacturing site
    • US$50 per variant
  • Decision: CDSCO grants COS-2 or rejects the application, with reasons, within six months. An appeal to the Central Government is possible within 45 days (Rule 13, Rules pp.9-10).
  • Validity: the certificate stays valid in perpetuity, as long as the retention fee is paid before five years from issue. Late payment carries a 2% per month late fee. If the fee is still unpaid after 180 days, the certificate is deemed cancelled (Rule 14, Rules p.10).

4. Import conditions at the border (Rules 18-22)

  • Prohibited imports:
    • Products banned in their country of origin.
    • Products whose "use before" date is not later than six months from the date of import.
    • Products containing hexachlorophene.
    • Products tested on animals after 12 November 2014.
  • Customs: a compliance declaration must be given to the Commissioner of Customs. Port officers may sample consignments and hold them until test results arrive. Products that fail and cannot be remedied must be re-exported or destroyed within two months.
  • Points of entry: imports may only come through the points listed in rule 43A of the Drugs and Cosmetics Rules, 1945.
  • Personal use: small quantities in a passenger's baggage are allowed.

5. Labelling (Chapter VI)

  • India-specific details: each unit pack must show the RC number (preceded by "RC", "RC No" or "Reg. Cert. No") and the importer's name and address. These may be stickered on at bonded warehouses.
  • Other required items: name, manufacturer and "Made in…", expiry, batch number, net contents, warnings, and ingredients in descending order [p4][p5].
  • Hair colours: a June 2026 CDSCO circular says they must comply with IS 4707 Parts 1 and 2, IS 8481, and Rules 34 and 37 [4].

6. After registration

  • Changes to labelling, composition, testing or specifications: notify CDSCO within fifteen days (Rule 15(2), Rules p.11). The undertaking form in CDSCO's guidance says thirty days instead [p11]. The fifteen days in the rule text is the figure that applies.
  • Name or address changes: need prior approval, applied for within 60 days.
  • Change in constitution: needs a fresh application within 180 days (Rule 15).
  • Enforcement: CDSCO is actively enforcing. A July 2026 circular tells port officers and state authorities to step up watch on imported cosmetics sold without a valid RC [5]. In 2025-2026 CDSCO cancelled several RCs and COS-4A numbers, for example [6].

Sources:

Q.02

How can I check an importer's registration certificate?

CDSCO's website has no public search tool or consolidated register of current cosmetics RCs. So the check is document-based: get the importer's certificate, compare it against the Cosmetics Rules, 2020, and check it against the cancellation and surrender notices CDSCO publishes. CDSCO's cosmetics page links to guidance, checklists, the SUGAM portal and case-by-case cancellation and surrender orders, with no RC lookup or approved-product list (CDSCO Cosmetics page).

Approach: I searched CDSCO's cosmetics circulars, public notices and import-registration guidance, plus CDSCO's historical RC-holder register (2013-2017), then read CDSCO's cosmetics web page and its FAQ on registration and import. The only register in the datasets is that historical list of pre-2020 certificates (Form 43 era), so it can't confirm a current COS-2.

1. Get the right document from the importer

  • COS-2 (Import Registration Certificate): what the RC holder has, i.e. the manufacturer, its authorised agent, its subsidiary or the importer (CDSCO FAQ, Q.6, Q.12).
  • COS-4A (Import Registration Number): what any other importer of an already-registered product has. It "shall remain valid for a period of three years from the date of its issue, unless it is suspended or cancelled" (FAQ Q.22-23). A COS-4A must sit on top of a Rules-2020 COS-2. A product registered only under an old Form 43 doesn't qualify (FAQ Q.74).
  • Old Form 43 certificates: these stayed valid only "till its expiry or for a period of eighteen months from the date these rules are notified, whichever is later" (FAQ Q.70, Q.72). New products, pack sizes or sites can't be endorsed onto a Form 43 (FAQ Q.70). The historical CDSCO register lists such certificates with fixed validity periods, for example Cos010/13, valid 01.4.2013 to 31.03.2016 [7].

2. Check the certificate's contents against the product

  • Coverage: the COS-2 names the brand, category, pack size and variants separately, and a different pack size is not a variant (FAQ Q.66). Confirm that the exact product, shade or flavour, pack size and manufacturing site you're dealing with are listed. Products added later appear in endorsements, which carry the same validity as the parent RC (FAQ Q.27-28).
  • Parties: the Indian agent or importer and the legal or actual manufacturer must match. Name or address changes need prior CDSCO approval, applied for within 60 days. A change in constitution, including an acquisition or merger, needs a fresh application within 180 days (FAQ Q.38-41).
  • Validity: a COS-2 stays valid in perpetuity only if the retention fee is paid before five years from issue. If it is still unpaid 180 days after the due date, the certificate "shall be deemed to have been cancelled" (FAQ Q.26). Ask for proof that the retention fee was paid if the RC is more than five years old.
  • Label: importers may add India-specific details (importer name and address, RC number) after landing, at bonded warehouses (FAQ Q.45). Check that the number on the pack matches the certificate.

3. Check it against CDSCO's cancellations and surrenders

CDSCO publishes individual orders, and you can search them by RC number or company name. Recent examples:

  • Surrender of RC/COS-005067 (notice of 06.10.2026) [8]
  • Cancellation order dated 24.08.2026, Skintle Enterprises Pvt Ltd [9]
  • Surrender of RC/COS-003938 [10]
  • Cancellation of products under RC/COS-001655 (27.01.2026) [11]
  • Cancellation of a single product under RC/COS-005139, which is otherwise valid up to 14 July 2029 [12]

The last one shows that a certificate can stay valid while individual products under it are cancelled.

4. Why it matters

CDSCO's 23 July 2026 circular says imported cosmetics "are being sold in domestic market without valid Registration certificate." It directs state licensing authorities and CDSCO zonal heads to step up surveillance, and port officers to keep a strict vigil [5].

5. Asking CDSCO directly

The FAQ says only the applicant or its authorised regular employee may ask about an application's status, not a third party or consultant (Q.48). That covers pending applications. The FAQ doesn't say how a third party can ask CDSCO to confirm an issued certificate. The Cosmetics Division sits at CDSCO HQ, FDA Bhawan, Kotla Road, New Delhi (dci@nic.in) (FAQ Q.8-9).

If you send me the RC or COS-4A number or the importer's name, I can search CDSCO's cancellation and surrender notices and the historical register for it.

Sources:

Q.03

What customs duty applies to imported cosmetics?

I couldn't confirm the basic customs duty (BCD) currently in force for cosmetics from CBIC's live tariff. The last rate I could trace on official pages is 20%, for finished cosmetics and toiletries in headings 3303 to 3307. The Union Budget 2018-19 raised it from 10%, and neither the 2025 nor the 2026 Budget changed those headings. A 10% Social Welfare Surcharge (SWS) and IGST are charged on top. CDSCO's cosmetics rules don't set any duty; it comes from the Customs Tariff Act, 1975 and the GST rate notifications.

Approach: The regulatory datasets hold no Indian customs tariff, so I read the Finance Ministry's budget documents on indiabudget.gov.in (2018-19, 2025-26 and 2026-27) and the GST Council's release on its 56th meeting. I didn't check the Budgets from 2019-20 to 2024-25 one by one, and I couldn't open CBIC's tariff pages or the IGST rate notification.

1. Basic customs duty: 20% from Budget 2018-19

Annexure 6 of the 2018-19 Budget Speech, under "Perfumes and toiletry preparations", raised the duty from 10% to 20% on (Budget Speech 2018-19, p.53):

  • 3303: perfumes and toilet waters
  • 3304: beauty or make-up preparations and skin-care preparations (other than medicaments), including sunscreen and suntan preparations, and manicure and pedicure preparations
  • 3305: preparations for use on the hair
  • 3306: preparations for oral or dental hygiene, including dental floss in retail packs
  • 3307: pre-shave, shaving and after-shave preparations, personal deodorants, bath preparations, depilatories, other perfumery, cosmetic or toilet preparations not elsewhere specified, and room deodorisers

The same table also raised 9616 (scent sprays, powder puffs and pads for applying cosmetics) from 10% to 20% (p.56).

Later budgets:

  • 2025-26: the only Chapter 33 change was a cut from 100% to 20% for synthetic flavouring essences and odoriferous mixtures used in food and drink (3302 10) (Budget 2025-26 duty changes, p.6).
  • 2026-27: the only Chapter 33 item is the same food and drink odoriferous mixtures. Their rate moves from an exemption notification into the First Schedule from 1 May 2026, with "no change in the applicable rate of duty" (Budget 2026-27 duty changes, pp.11-12). Chapters 34-37 are marked "No Change" (p.12).

2. Social Welfare Surcharge

The 2018-19 Budget brought in an SWS "at the rate of 10% of the aggregate duties of Customs, on imported goods." It replaced the education cesses on imports (Budget Speech, para 162, p.32; Annexure 6, p.57). The Budget 2026-27 document still defines SWS as a customs duty levied under Section 110 of the Finance Act, 2018 (p.3).

3. IGST at import

IGST is charged at the GST rate for the product's HSN code. The GST Council's 56th meeting, applying to goods from 22 September 2025, recommended these changes (Ministry of Finance release, 3 Sep 2025, pp.1, 4):

  • GST was cut "from 18% OR 12% to 5%" on items including hair oil, toilet soap bars, shampoos and toothpaste (p.1).
  • Its list of goods with rate changes also covers talcum and face powder (3304), dental floss and tooth powder (3306), and shaving cream, shaving lotion and aftershave lotion (3307) (p.18).
  • The new structure has a standard rate of 18%, a merit rate of 5% and a 40% de-merit rate for a few goods (p.1).

The rate columns in that list didn't come through. The rates are set in Notification No. 9/2025-Integrated Tax (Rate), which I couldn't open, so I can't give the IGST rate for each cosmetic HSN code. That notification is the text to apply.

What this means for a shipment

  • Find the 8-digit code first. Each product's code within 3303-3307 decides both the BCD and the IGST.
  • Two figures are still unconfirmed: the current First Schedule rate and any exemption entry under Notification No. 45/2025-Customs that might lower it. Both come from CBIC's Customs Tariff, which I couldn't reach.

I can try the CBIC tariff and the IGST notification again for specific products if you send me their tariff codes.

Sources:

Q.04