Form COS-1 and COS-2: CDSCO Registration Forms for Import of Cosmetic Products

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Beauty and personal care market in India has attracted global cosmetic brands to import their products into the country. However, to legally import and distribute cosmetic products in India, regulatory compliance is essential. The Central Drugs Standard Control Organisation (CDSCO) plays a key role in this process through the issuance of Form COS-1 and COS-2, which are mandatory for cosmetic product registration in India. This article provides a complete overview of the CDSCO Registration Forms for Import of Cosmetic Products, namely Form COS-1 and COS-2, their application process, eligibility, required documents, and other essential guidelines.

CDSCO’s Role in Cosmetic Imports

The Central Drugs Standard Control Organisation (CDSCO), under the Directorate General of Health Services, Ministry of Health & Family Welfare, Government of India, regulates the import of cosmetics in accordance with the Drugs and Cosmetics Act, 1940 and the Cosmetics Rules, 2020.

As per Section 3(aaa) of the Act, "cosmetic" refers to any product intended to be rubbed, poured, sprinkled, or applied to the human body for cleansing, beautifying, or altering appearance.To import such products, companies must obtain a CDSCO Import Registration Certificate, which involves submitting Form COS-1 and receiving Form COS-2 from the CDSCO.

What are Form COS-1 and COS-2?

• Form COS-1 is the application form submitted to the Central Licensing Authority (CDSCO) for obtaining the Import Registration Certificate for cosmetic products.

• Form COS-2 is the Import Registration Certificate issued by CDSCO after the approval of Form COS-1.

These forms are part of the compliance mechanism under the Cosmetics Rules, 2020, ensuring that only safe and standardized cosmetic products enter the Indian market.

Who Can Apply for COS-1 and COS-2?

In India, the process of importing cosmetics is not restricted to manufacturers alone. A manufacturer or importer who wishes to bring cosmetic products from different countries into India is eligible to apply for the necessary import registration through CDSCO. Additionally, the manufacturer or importer can appoint an authorized representative—such as a distributor, consultant, or agent—who can legally apply for the cosmetic registration on their behalf. This provision is particularly helpful for overseas companies that may not have a direct presence in India. Furthermore, individuals who are planning to start a cosmetic import business can also apply for the import registration certificate themselves, even if they are not yet established importers, provided they fulfill the CDSCO’s documentation and regulatory requirements. This inclusive approach encourages new entrants and businesses to participate in the growing Indian cosmetic market.

Procedure for Submitting Form COS-1 and COS-2

Step 1: Register on the SUGAM Portal

Applicants must first create an account on the SUGAM Portal, the official CDSCO online platform for regulatory submissions.

Step 2: Fill Form COS-1 Online

Log into the Sugam portal and fill in Form COS-1 with the required details:

• Product name and variant

• Manufacturing facility details

• Brand and pack size

• Ingredients and intended use

• Label details and product specification

Step 3: Upload Required Documents

Attach the following documents:

• Manufacturing license and authorization

• Free Sale Certificate

• Product labels and artwork

• Product testing method and analysis certificate

• Heavy metal and microbiological test reports

• Undertaking from the manufacturer

• Power of attorney (if applicable)

Step 4: Payment of Fees

Submit the requisite government fees via challan on the Bharatkosh or specified payment portal and attach proof of payment with the application.

Step 5: Submission and Review

Submit the complete application online. The CDSCO may request additional information or clarification if required.

What Happens After Submission?

Once the application in Form COS-1 is reviewed and approved, the CDSCO issues the Import Registration Certificate in Form COS-2. This certificate permits the import and sale of the cosmetic product in India. According to the Cosmetics Rules, 2020, the approval process for cosmetic registration may take up to 180 working days.

Validity of Form COS-2 Certificate

The COS-2 certificate (Registration Certificate) is valid for five years from the date of issuance. Importers must renew the license before expiration to continue legal imports.

Important Points for Cosmetic Importers to Remember

Importers must comply with the following key requirements:

• Ensure all documents are legally valid and consistent in terms of names, addresses, and product details.

• Documentation must be submitted in English.

• Cosmetic products must comply with the 9th Schedule of the Bureau of Indian Standards (BIS) specifications.

• The label should include claims that match the product's specifications.

• Products must not contain prohibited ingredients and should follow BIS norms for color, fragrance, and composition.

• The importer should keep a hard copy of COS-2 for inspections by licensing authorities.

What Products Need COS-1 and COS-2 Registration?

Any cosmetic product (as per the legal definition) intended to be imported, marketed, and sold in India must be registered under this system. These products span over 80 categories, including:

• Skin care products (creams, lotions)

• Hair care (shampoos, hair oils)

• Oral hygiene products (toothpastes, mouthwashes)

• Nail and eye cosmetics

• Fragrances and perfumes

Each pack size, formulation, and manufacturing site must be registered separately.

Labelling Guidelines for Imported Cosmetics

CDSCO has specific labelling rules under the Cosmetics Rules, 2020:

• Labels must be in English or Hindi.

• Must show the product name, manufacturing date, expiry date, MRP, batch number, and country of origin.

• Must include the importer’s name and address.

• Any therapeutic claim must be avoided unless permitted.

Compliance with Indian Standards

Cosmetic products must conform to the guidelines laid down by:

• Drugs and Cosmetics Rules, 1945

• Cosmetics Rules, 2020

Bureau of Indian Standards (BIS)

Non-compliance can result in seizure of products, cancellation of registration, or penalties.

Conclusion

The CDSCO regulatory framework is important for cosmetic importers and manufacturers seeking to enter the Indian market. Proper registration using Form COS-1 and COS-2 not only ensures legal compliance but also builds trust with consumers and regulators. With the online SUGAM portal, streamlined documentation, and a clear approval process, importing cosmetics into India has become more efficient. Businesses must remain diligent with labelling, ingredient compliance, and timely renewals to maintain market presence. Whether you are a global cosmetic giant or a small exporter, understanding and correctly submitting the CDSCO Registration Forms for Import of Cosmetic Products is essential for long-term success in India’s successful beauty market.

Frequently Asked Questions (FAQs)

Q1. What are Form COS-1 and COS-2, and why are they important for importing cosmetics into India?

Ans. Form COS-1 is the primary online application for a CDSCO Cosmetic Import License, submitted through the SUGAM portal. Form COS-2 is the official Import Registration Certificate issued upon approval of the COS-1 application. Both forms are crucial for legal import, sale, and distribution of cosmetics in India, ensuring safety and compliance with the Cosmetic Rules 2020.

Q2. What information is required in the Form COS-1 application?

Ans. The Form COS-1 application requires detailed information about the foreign manufacturer, the Indian applicant, and the specific cosmetic products to be imported. Accuracy and consistency with supporting documents are essential. Applicants should refer to the "Online checklist for grant of Registration Certificate in Form COS-1" for a comprehensive list of required information and documents.

Q3. What is the objective of Form COS-1 and COS-2?

Ans. The primary objective is to ensure the safety and quality of cosmetic products available to consumers in India. By requiring these registrations, the CDSCO verifies that imported cosmetics adhere to the standards and specifications of the Cosmetic Rules 2020, preventing the import of substandard or harmful products and safeguarding public health.

Q4. Who can apply for a CDSCO Cosmetic Import License (Form COS-1 and COS-2)?

Ans. The article mentions that the Cosmetic Rules 2020 specify the categories of entities eligible to apply. These include the actual manufacturer of the cosmetic product (with a registered office or legally recognized presence in India) and an agent formally authorized by the manufacturer to import cosmetics on their behalf. (Note: The specific categories are not fully listed in the provided excerpt, but this question highlights the importance of understanding eligibility.)

Q5. What are the consequences of importing cosmetics without a valid Form COS-2 license?

Ans. Importing cosmetics without the mandatory Form COS-2 license can lead to penalties, confiscation of goods, and potential bans on future imports. Holding a valid license demonstrates regulatory compliance, builds consumer trust, and allows for the legal marketing and sale of cosmetics in the Indian market.

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