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- Understanding what is Form COS-1 and COS-2 is essential to ensure compliance with the Central Drugs Standard Control Organization (CDSCO).
- Under the Cosmetics Rules, 2020, Form COS-1 and COS-2 govern cosmetic import registration in India.
- COS-1 is the application form to obtain a cosmetic import registration certificate.
- COS-2 is the registration certificate issued by CDSCO after successful review.
- Importers, authorised agents, or Indian subsidiaries can apply through the SUGAM portal.
- The certificate remains valid for five years, ensuring compliance with Indian cosmetic safety standards.
Introduction
A French skincare brand once partnered with an Indian distributor eager to launch its premium face serum nationwide. Despite its strong global credentials, their first shipment was held at Mumbai Port. The reason? The product hadn’t been registered under Form COS-1 and COS-2 with CDSCO.
Even though the formulation met EU safety standards, India’s Drugs and Cosmetics Act, 1940, and Cosmetics Rules, 2020 require prior registration before any cosmetic import. It took months of coordination, documentation, and clarification before the consignment was cleared.
This case illustrates a vital truth: in India, regulatory compliance is not a post-import step—it’s the entry ticket. Understanding what is Form COS-1 and COS-2 ensures your brand avoids costly delays and secures smooth market access.
At Diligence Certifications, we help global cosmetic brands, importers, and Indian subsidiaries file their registrations correctly—first time, every time.
What is Form COS-1 and COS-2?
The Central Drugs Standard Control Organisation (CDSCO) regulates cosmetic imports into India through a registration framework established under the Drugs and Cosmetics Act, 1940 and the Cosmetics Rules, 2020.
Form COS-1
Form COS-1 is the application form submitted to CDSCO for obtaining a Registration Certificate to import cosmetics into India.
This form captures details about:
- The manufacturer and manufacturing premises
- The cosmetic product, including variants, pack sizes, and composition
- The authorised Indian agent or importer
It is filed online via the SUGAM portal before any cosmetic consignment can be imported.
Form COS-2
Form COS-2 is the Registration Certificate issued by CDSCO once the application in COS-1 is approved.
It officially permits the import and sale of the listed cosmetic products in India.
Together, these forms establish India’s transparent and traceable system for ensuring cosmetic safety, quality, and regulatory compliance.
Legal Background
According to Section 3(aaa) of the Drugs and Cosmetics Act, 1940, “cosmetic” means any substance that is intended to be applied to the human body for cleansing, beautifying or increasing attractiveness, or altering appearance, in its parts, skin, hair, and other human body regions.
The Cosmetics Rules, 2020 were framed under the Drug and Cosmetics Act, 1940, and require the registration of imported cosmetics. According to Rule 12, no cosmetic can be imported unless it is registered with the Central Licensing Authority (CLA).
The CLA is part of the Drugs Controller General of India (DCGI), which is the head of Central Drug Standard Control Organization (CDSCO)
All cosmetic products imported into India must be registered by submitting Form COS-1 and, if registered, it can be imported into India with Form COS-2 (registration form) acting as a license.
Who Can Apply for Form COS-1 and COS-2 Registration?
According to Rule 13 of the Cosmetics Rules, 2020, the application can be submitted by:
- The manufacturer of the cosmetics; or
- The manufacturer’s authorised agent in India; or
- The importer in India; or
- The subsidiary company of the foreign manufacturer operating in India.
Each applicant must hold a valid digital signature and access to the SUGAM portal for online filing.
Key Responsibilities of the Importer or Authorised Agent
Before submitting Form COS-1, the importer or authorised agent must ensure:
- Verification of all legal documents for authenticity and validity.
- Consistency of details (product name, manufacturer’s address, importer’s name) across all documents.
- Compliance with language requirements—all documents must be in English.
- Provision of supplementary data—including heavy metal declarations, ingredient lists, and product specifications.
- Adherence to BIS standards under the Ninth Schedule of the Cosmetics Rules, 2020.
Failure to meet any of these points may result in file rejection or queries from CDSCO.
Eligibility and Product Classification
Cosmetics imported into India must conform to Indian regulatory requirements related to:
- Ingredient restrictions
- Heavy metal and microbial limits
- Packaging and labelling standards
- Product category classification
The Bureau of Indian Standards (BIS) has issued detailed specifications under IS 4707 (Part 1 and 2) covering permissible ingredients, colours, and preservatives.
CDSCO classifies cosmetics broadly into:
- Skin care products (creams, lotions, sunscreens)
- Hair care products (shampoos, conditioners, dyes)
- Nail care and make-up items
- Fragrance and oral care products
Each product category must be declared precisely during COS-1 application.
Documents Required for Form COS-1 and COS-2 Filing
To obtain the cosmetic import registration certificate, the following documents must be submitted:
- Covering letter and authorisation from the manufacturer.
- Product specification and testing methods.
- Certificate of Free Sale (CFS) from the country of origin.
- Product labels and packaging artwork in English.
- Ingredient list and percentage composition.
- Heavy metal and microbiological test reports.
- Manufacturer’s licence copy and manufacturing site details.
- Power of Attorney in favour of the Indian authorised agent.
- Import–export code (IEC) of the importer.
- Proof of payment (Challan) of government fee.
These documents support the regulatory evaluation and safety validation process by CDSCO.
Step-by-Step Procedure to File Form COS-1 and Obtain COS-2
Step 1: Preparation and Login
- Visit the SUGAM Portal of CDSCO.
- Create an applicant profile (manufacturer, agent, or importer).
- Ensure DSC registration of authorised signatory.
Step 2: Fill Form COS-1
Enter the following information:
- Applicant and manufacturer details.
- Product category, brand name, and variants.
- Pack sizes, formulations, and intended use.
- Manufacturing site information.
Step 3: Upload Documents
Attach all necessary documents listed above, ensuring proper formatting (PDF under 10 MB each).
Step 4: Payment of Fee
A registration fee must be paid online via Bharatkosh (INR challan). Each product category attracts a separate fee as per Rule 13(2).
Step 5: Submit Application
Once verified, submit the form online. CDSCO acknowledges submission with a Service Request Number (SRN).
Step 6: CDSCO Review
The Central Licensing Authority reviews the dossier for:
- Safety and quality compliance
- BIS conformity
- Authenticity of documentation
Step 7: Grant of COS-2
If found satisfactory, CDSCO issues Form COS-2 — the Registration Certificate for Import of Cosmetics.
This certificate authorises the import and distribution of approved cosmetic products in India.
Processing Timeline
As per Rule 13(5) of the Cosmetics Rules, 2020, the licensing authority aims to process applications within 180 working days of submission, subject to the completeness of documentation.
Delays typically arise due to:
- Incomplete dossiers
- Incorrect or mismatched product information
- Pending clarifications from foreign manufacturers
Diligence Certifications assists applicants in responding promptly to such CDSCO queries to maintain review timelines.
Validity of Form COS-2 Registration Certificate
A Registration Certificate of COS-2 is valid for a period of five years from the date of issuance, unless it was suspended or cancelled before the expiration of the five years period.
A renewal application must be submitted six months before the expiration. The renewal application must be done via the same application portal and through the same documentation process.
How Proper Filing Saved a Brand Launch
A Korean skincare company aimed to sell its sheet masks and serums in India in 2023. Diligence Certifications was responsible for managing the COS-1 filing, and all variants were classified appropriately as skin care (non-medicated).
The client received approval within 120 days of application submission, and the first consignment cleared customs with no regulatory challenges. One competitor, however, had its product held at customs for three months because the manufacturer addresses were not consistent across the different product documents. This is a relatively common, though easily avoidable issue.
Common Mistakes to Avoid
- Submitting incomplete documentation—missing Free Sale Certificate or Power of Attorney.
- Improper English translations of product labels or ingredient lists.
- Mismatch in product names between COS-1 and CFS.
- Ignoring BIS conformity for colouring agents and preservatives.
- Late renewal filings—leading to lapse in validity and import blockage.
Avoiding these mistakes ensures faster approval and uninterrupted imports.
Post-Registration Obligations
Once COS-2 is issued, the certificate holder must:
- Ensure that imported cosmetics comply with label and ingredient declarations.
- Retain all testing records and certificates.
- Provide samples to CDSCO if required for surveillance.
- Notify the authority of any product recall, formulation change, or discontinuation.
- Display the registration number on product labels.
Non-compliance can lead to suspension or cancellation under Rule 19 of the Cosmetics Rules, 2020.
Validity, Renewal, and Change Applications
| Particulars | Timeline / Rule | Remarks |
| COS-2 Validity | 5 years | From the date of issue |
| Renewal Filing | 6 months before expiry | Through SUGAM portal |
| Variation / Addition of Product | Separate COS-1 submission | Same manufacturer can include multiple products |
| Transfer / Amendment | Allowed with supporting documents | Subject to CDSCO approval |
Why Choose Diligence Certifications
Our regulatory experts manage every stage of the cosmetic import registration process—from dossier preparation to final COS-2 approval.
We specialise in:
- Mapping product classification to CDSCO norms.
- Preparing compliant product labels and heavy metal declarations.
- Coordinating with manufacturers abroad for documentation.
- Submitting COS-1 applications through SUGAM with minimal errors.
- Handling CDSCO queries efficiently for faster clearance.
Our clients include international beauty houses, niche organic brands, and FMCG leaders expanding into India’s rapidly growing cosmetic market.
Conclusion
Understanding the functions of Form COS-1 and COS-2 is very important for every cosmetic brand thinking of entering the Indian market. These forms are not simply administrative forms, but the base of compliance, safety to consumers and trust of consumers, and the industry as a whole. By aligning to CDSCO and BIS standards, your application for importation will have a much smoother import and clearance process and long term trust with your brands.
Diligence Certifications Regulatory group works with worldwide beauty brands to manage the registration of cosmetics with regulators and to ensure that every product that enters India meets all compliance requirements and transparency.
So, are you ready to register your cosmetics with CDSCO?
Please contact our compliance desk today for a Form COS-1/COS-2 pre-filing review and fee variable audit of your documentation.
Frequently Asked Questions
What is Form COS-1?
Form COS-1 is the application form submitted to (CDSCO) for the grant of registration for import of cosmetics under the Cosmetics Rules, 2020.
What is Form COS-2?
Form COS-2 is the registration certificate issued by CDSCO after approval of Form COS-1.
Who can apply for COS-1 registration?
Manufacturers, importers, or authorised Indian agents of cosmetic brands may apply for COS-1 registration.
Is registration of cosmetics import mandatory?
Yes, no cosmetic can be imported into India as per Rule 12 of the Cosmetics Rules, 2020 without registration.
How long is the certificate valid?
The certificate is valid for a period of 5 years from the date of issue.
How long does CDSCO take to approve the application?
CDSCO takes typically around 180 working days, depending on the completeness of the documents presented.
Can one certificate cover multiple products?
Yes, if the products belong to the same category and manufacturer, one certificate can cover multiple products.
Is there any requirement for animal testing data?
No, India prohibits the submission of any animal testing data for cosmetics.
What are the BIS requirements?
The products must conform to BIS specifications in accordance with Schedule IX of the Cosmetics Rules, 2020.
How can Diligence Certifications assist with this process?
We provide end to end support in filing, preparing documentation, and liaisoning with the appropriate regulatory body for COS-1 and COS-2 registration.
