India’s cosmetic market is growing rapidly, with international beauty brands, skincare products, haircare products, makeup and personal care products becoming increasingly available through distributors, retailers and e-commerce platforms. However, bringing a cosmetic product into the Indian market involves more than simply importing the product from a foreign manufacturer.
Imported cosmetics are subject to specific regulatory requirements in India, including registration with the Central Licensing Authority before import.
In a recent July 2026 circular, the Central Drugs Standard Control Organization (CDSCO) raised concerns about imported cosmetic products being sold in the domestic market without a valid Import Registration Certificate. CDSCO has directed State Licensing Authorities and CDSCO Zonal and Sub-Zonal Offices to enhance surveillance of such products. Port Offices have also been instructed to maintain strict vigilance to prevent the entry of cosmetics into India without the required registration.
This development is important for cosmetic importers, foreign manufacturers, authorized agents, distributors, retailers and businesses selling imported cosmetics through physical or online channels.
What Is the Latest CDSCO Circular About?
The CDSCO Cosmetics Division issued a circular concerning the vigilance on imported cosmetics products sold in the domestic market without a valid Import Registration Certificate.
According to the circular, CDSCO has received information indicating that imported cosmetics are being sold in the domestic market without a valid registration certificate. In response, CDSCO has asked State Licensing Authorities and CDSCO Zonal and Sub-Zonal Offices to direct their inspectorates to undertake enhanced surveillance of such cosmetic products.
The circular also directs Port Offices to maintain strict vigilance to help prevent cosmetics from entering India without the required registration.
The circular does not create a completely new registration requirement. Instead, it reinforces the existing requirement under the Cosmetics Rules, 2020 and signals increased regulatory attention toward imported cosmetics.
CDSCO’s latest circular list includes this vigilance circular among its July 2026 regulatory updates.
Is Registration Mandatory for Imported Cosmetics in India?
Yes.
Under Rule 12(1) of the Cosmetics Rules, 2020, a cosmetic cannot be imported into India unless the product has been registered in accordance with the rules by the Central Licensing Authority or an officer to whom the relevant powers have been delegated.
CDSCO’s official cosmetics guidance similarly states that imported cosmetics are regulated through a registration system and that cosmetics falling within the regulatory definition must be registered before import into India.
This means a product being legally marketed in another country does not, by itself, authorize its import and sale in India.
An importer or business must consider the Indian regulatory requirements before bringing the cosmetic product into the country.
What Is an Import Registration Certificate?
An Import Registration Certificate is the regulatory authorization associated with the registration of cosmetic products intended for import into India.
Under the Cosmetics Rules, 2020, the application for registration of a cosmetic product intended to be imported is submitted online in Form COS-1 through the CDSCO’s designated online system.
The application may be submitted by:
- The foreign manufacturer;
- The manufacturer’s authorized agent in India;
- The importer in India; or
- A subsidiary in India authorized by the manufacturer.
The manufacturer’s authorization to an Indian agent must also meet the applicable authentication requirements under the Cosmetics Rules, 2020.
Businesses should therefore determine the appropriate applicant structure and ensure that the regulatory documentation accurately represents the relationship between the foreign manufacturer, Indian importer and authorized representative.
Why Has CDSCO Increased Vigilance?
The latest circular specifically states that imported cosmetics have been found being sold in the domestic market without a valid Registration Certificate.
This creates concerns at two stages:
1. Entry into India
Unregistered cosmetic products should not enter India because Rule 12(1) requires registration before import.
2. Sale in the domestic market
The latest CDSCO action also focuses attention on products that are already being sold in India without valid registration.
Therefore, compliance should not be viewed as something that ends once a product reaches the warehouse. Businesses involved in the Indian supply chain should maintain appropriate regulatory records and verify that the products they import or distribute have the required registration.
CDSCO has specifically directed its Port Offices to keep strict vigilance to curb the entry of cosmetics into India without a Registration Certificate.
Who Should Pay Attention to This CDSCO Update?
The development is particularly relevant to businesses dealing with imported cosmetics, including:
👉Cosmetic Importers
Importers should verify that every imported cosmetic product is appropriately registered before import and that the registration details correspond with the products actually being marketed.
👉Foreign Cosmetic Manufacturers
International manufacturers planning to enter or expand in the Indian market should understand that registration in their home country does not replace India’s import registration requirements.
👉Authorized Agents
Indian authorized agents handling regulatory responsibilities for foreign manufacturers should maintain accurate product and manufacturer documentation and monitor registration status.
👉Distributors and Wholesalers
Distributors dealing with imported cosmetics should conduct appropriate regulatory checks before accepting products into their supply chain.
👉Retailers
Retail businesses purchasing imported cosmetics should consider verifying the regulatory status of products supplied to them.
👉E-commerce Sellers
Online sellers and marketplace businesses dealing with imported beauty and personal care products should be particularly careful about the regulatory status of products they offer to Indian consumers.
What Should Cosmetic Importers Check Now?
The latest CDSCO action is a good reason for businesses to conduct an internal compliance review.
1. Check the validity of the registration
Importers should confirm that the relevant cosmetic products have a valid registration and that the registration has not expired, been cancelled or otherwise become invalid.
CDSCO’s cosmetics section also publishes regulatory actions concerning cancellation and surrender of cosmetic registration certificates, demonstrating why businesses should not rely only on old approval documents.
2. Match the registered product with the marketed product
The product being imported and sold should correspond with the details covered by the applicable registration.
Businesses should review details such as:
- Product name;
- Brand;
- Variant;
- Shade, where applicable;
- Pack size;
- Manufacturing site;
- Manufacturer details; and
- Other relevant registration information.
CDSCO’s guidance explains that imported cosmetics are registered with relevant product information, including pack sizes, variants and manufacturing premises.
3. Review the manufacturing site
A registration should not be treated as a blanket authorization for unrelated manufacturing sites or products.
Businesses should verify that the foreign manufacturing premises and products being imported are appropriately covered by the applicable regulatory documentation.
4. Review supporting documentation
Importers should maintain the documents required for their cosmetic registration and ensure consistency between regulatory submissions, product documentation, labels and commercial records.
Incomplete or inconsistent documentation can create unnecessary regulatory complications.
5. Review products sold through distributors.
If a foreign brand uses multiple Indian distributors, the brand owner or regulatory representative should have a clear understanding of where its products are being supplied.
This is especially important when products are sold through multiple channels, including wholesalers, retailers and e-commerce platforms.
What Happens If a Product Is Imported Without Registration?
The key issue is that import of cosmetics is regulated under the Cosmetics Rules, 2020.
Rule 12(1) states that a cosmetic cannot be imported into India unless it has been registered in accordance with the rules.
Therefore, businesses should not treat registration as an optional commercial formality.
A product that is already popular internationally, has approval in another country or is being sold through an overseas website does not automatically satisfy Indian regulatory requirements.
The latest CDSCO circular reinforces this point by directing authorities to increase surveillance of imported cosmetics being sold without valid registration.
The exact regulatory consequences in an individual case can depend on the facts, product status, documentation and applicable provisions. Businesses facing a regulatory inspection or compliance issue should obtain appropriate regulatory advice rather than assuming that a previous shipment or existing commercial arrangement establishes compliance.
Import Registration Is Only One Part of Cosmetic Compliance
Businesses should also remember that registration is not the only regulatory consideration.
CDSCO states that cosmetics must comply with applicable quality and safety requirements. Under Rule 39 of the Cosmetics Rules, 2020, cosmetics must comply with specifications prescribed under the Ninth Schedule or other applicable standards of quality and safety and other provisions of the rules. Where a cosmetic is not covered by the Ninth Schedule, the applicable requirements and standards specified under the rules and, where relevant, the country of origin must be considered.
Cosmetic claims are also important. Rule 36 provides that a cosmetic must not purport or claim to convey an idea that is false or misleading to the intended user.
Therefore, an effective compliance review should look beyond the existence of a certificate and consider the overall regulatory status of the product.
How Can Businesses Prepare for Increased Surveillance?
With CDSCO directing authorities to enhance surveillance, proactive compliance is preferable to waiting for an inspection or regulatory query.
Businesses importing cosmetics into India should consider maintaining an internal compliance checklist covering:
- Valid Import Registration Certificate;
- Registered product details;
- Product variants and pack sizes;
- Foreign manufacturing premises;
- Manufacturer authorization;
- Product labels and packaging;
- Applicable quality and safety requirements;
- Import documentation;
- Distribution records;
- Registration validity and amendments; and
- Regulatory correspondence.
A periodic review can help identify products that were added after the original registration, products whose details have changed, expired registrations, or products being sold through channels that were not properly reviewed by the regulatory team.
Why This Update Matters for the Indian Cosmetic Industry
The July 2026 CDSCO circular is important because it moves attention beyond the theoretical requirement of registration and toward market surveillance and enforcement.
CDSCO has explicitly indicated that imported cosmetics are being sold in the domestic market without valid registration and has responded by asking its field authorities to increase surveillance. Port authorities have also been instructed to remain vigilant at entry points.
For compliant businesses, this can help create a more level playing field by discouraging the sale of products that have entered the Indian market without meeting applicable regulatory requirements.
For importers and international brands, however, the message is equally clear: Indian cosmetic compliance should be addressed before commercial import and sale.
Frequently Asked Questions
1. Is CDSCO registration mandatory for imported cosmetics in India?
Yes. Under Rule 12(1) of the Cosmetics Rules, 2020, cosmetics cannot be imported into India unless the product has been registered in accordance with the applicable rules.
2. Who can apply for cosmetic import registration?
The application may be submitted by the foreign manufacturer, its authorized agent in India, the importer in India or an authorized subsidiary in India, subject to the applicable requirements.
3. Does registration in another country allow a cosmetic to be sold in India?
No. Imported cosmetics must meet the applicable Indian regulatory requirements. Foreign-market approval does not automatically replace Indian cosmetic import registration.
4. Does the latest CDSCO circular introduce a new registration requirement?
The July 2026 circular primarily reinforces enforcement of the existing requirement under Rule 12(1) and directs authorities to enhance surveillance of imported cosmetics being sold without valid registration.
5. Should distributors and retailers verify imported cosmetics?
Businesses in the domestic supply chain should take appropriate steps to verify the regulatory status of imported cosmetic products they purchase and sell, particularly in light of the enhanced surveillance directed by CDSCO.
6. What form is used to apply for cosmetic import registration?
CDSCO’s current guidance states that an application for an Import Registration Certificate is made online in Form COS-1 through the CDSCO online system.
7. Can a cosmetic registration become invalid?
Businesses should monitor the status of their registration and any relevant regulatory actions, including cancellation or surrender. CDSCO’s cosmetics portal publishes such regulatory updates.
Final Takeaway
The latest CDSCO vigilance circular is an important compliance signal for India’s imported cosmetics industry.
The central message is straightforward: imported cosmetics must have the required registration before they are imported into India, and businesses should not assume that an old certificate, foreign approval or commercial availability automatically means the product is compliant.
With CDSCO directing State Licensing Authorities, Zonal and Sub-Zonal Offices and Port Offices to strengthen surveillance, cosmetic importers and international brands should review their regulatory status proactively.
If you are planning to import cosmetics into India, launching a new foreign cosmetic brand, or reviewing the compliance status of products already being sold in India, obtaining the appropriate regulatory guidance before import can help reduce avoidable compliance issues.
For businesses that need assistance with Cosmetic Registration in India, a detailed review of the product, manufacturer, documentation, packaging and applicable regulatory requirements should be carried out before commercial import.
