Aloe vera gels, after-sun soothing gels and cooling gels are a high-volume summer category, and each must be registered with CDSCO under the Cosmetics Rules, 2020 before import. Registration is product-level and tied to the specific formulation, its variants and the factory.
There is no dedicated Indian Standard, so the file rests on the country-of-origin specification — and the single thing to watch is the claim, because "soothes after sun" is cosmetic while "treats sunburn" is not.
📌 Under Rule 12(1) of the Cosmetics Rules, 2020, no Aloe Vera & After-Sun Gel may be imported into India unless the product is registered by the Central Licensing Authority. The application is Form COS-1 on the CDSCO SUGAM portal, and the approval is issued as an Import Registration Certificate in Form COS-2 — it must be in place before the first consignment lands.
📋 Is CDSCO Registration Mandatory for Aloe Vera & After-Sun Gel?
Yes, where the product is a cosmetic. A soothing or moisturising aloe/after-sun gel is a Fourth Schedule skin-care preparation and needs CDSCO registration before import. A gel that claims to treat burns or a medical condition is a drug and needs a Form 10 import licence instead.
The application is filed by the overseas manufacturer or, in practice, its Authorised Indian Agent.
📘 The Indian Standard in Detail
No Ninth Schedule Indian Standard applies to an aloe or after-sun gel, so it is assessed against the country-of-origin standard plus the Cosmetics Rules, 2020, with the CoA drawn against the manufacturer's finished-product specification — pH, appearance, aloe content where claimed, preservative content and microbiological limits.
A high-water gel is a microbiological-risk format, so preservative-efficacy data is read closely, and where an aloe percentage is claimed it should be supported. Any menthol or cooling active is declared, and a sunburn-treatment claim moves the product off the cosmetic route.
🗂️ The Core Document Set — Required for Every Application
Whatever the product, Form COS-1 carries the same core dossier. Getting this base right is what decides whether the file clears in one pass or comes back as a query letter; the product-specific documents in the next section sit on top of it.
- Covering letter — states the purpose (fresh registration, endorsement of a product, site or pack size, or re-registration), references any earlier certificate and points to the correlation charts.
- Authorisation from the manufacturer (First Schedule) — names the manufacturer, every manufacturing premises, the Authorised Indian Agent and each product, variant and pack size; signed jointly on every page, then notarised and apostilled (Hague states) or embassy-attested.
- Part-I of the Second Schedule — company and product particulars, chemical information and the nine statutory undertakings, completed afresh for each COS-1.
- Ingredient list with percentages — INCI nomenclature, percentage of each ingredient, signed by a competent person; must exclude anything listed in Annex A of IS 4707 (Part 2).
- Inner and outer labels — legible originals for the product and every variant, compliant with Chapter VI.
- Specification and method of testing — the finished-product specification and test method, signed and stamped.
- Finished-product Certificate of Analysis — a batch CoA against the applicable Ninth Schedule Indian Standard, or against country-of-origin standards where no Indian Standard exists.
- Manufacturing licence / marketing authorisation — an authenticated copy from the country-of-origin regulator, or a manufacturer's undertaking where no such regime exists.
- Free Sale Certificate (FSC) — original, from the National Regulatory Authority of the country of origin; if issued by a chamber of commerce, apostilled or embassy-attested, and the product list signed and stamped.
- Non-animal-testing declaration — that the products have not been tested on animals after 12 November 2014.
- Heavy-metal and hexachlorophene declaration — a test report for Pb, As, Hg and other heavy metals plus microbiological results, or a manufacturer's undertaking of compliance.
- GMP / ISO 22716 certificate — evidence of cosmetic Good Manufacturing Practice at the overseas site.
- Correlation chart — maps each product serial number in COS-1 against the FSC and the Authorisation; missing or inconsistent charts are among the most common causes of query letters.
- Bharatkosh fee receipt — acknowledgement of the fee paid under head of account 0210041040000-00-1.
- Duly signed Form COS-1 — original, with every detail matching the Authorisation and Second Schedule Part-I exactly.
➕ Extra Documents for Aloe Vera & After-Sun Gel
On top of the core dossier above, an aloe / after-sun gel application needs:
- Certificate of Analysis against the country-of-origin specification — pH, appearance, preservative content and microbiological limits.
- Preservative-efficacy (challenge) data — important for a high-water gel.
- Aloe-content substantiation where an aloe percentage is claimed.
- Declaration of any cooling active (menthol, camphor) and its concentration.
- Country-of-origin standard and specification, since no Ninth Schedule Indian Standard applies.
- Microbiological report.
⚗️ Composition & Safety Limits
Regardless of category, the finished cosmetic must respect the composition limits in the Cosmetics Rules, 2020. CDSCO checks these against the heavy-metal report or the manufacturer's undertaking:
- Arsenic (in permitted colours) — not more than 2 ppm, as arsenic trioxide.
- Lead (in permitted colours) — not more than 20 ppm, as lead.
- Other heavy metals (in permitted colours) — not more than 100 ppm as the total of the respective metals.
- Mercury — up to 70 ppm (0.007%) as a preservative in eye-area products only; unintentional mercury not to exceed 1 ppm in all other products.
- Hexachlorophene — prohibited, except in soaps up to 1% w/w with the prescribed caution.
- Lead and arsenic compounds as colourants — prohibited outright.
- Dyes, colours and pigments — only those specified in IS 4707 (Part 1) / IS 4707 (Part 2) and the Tenth Schedule.
Preservation of a high-water gel is the key composition control, alongside the declared aloe percentage and any cooling active. A camphor/menthol level that is pharmacological rather than cosmetic would raise the drug question.
🏷️ Aloe Vera & After-Sun Gel Label Requirements
In addition to the general Chapter VI requirements, aloe / after-sun labels are checked for these product-specific points:
- Directions for use and any skin-sensitivity caution.
- Aloe content or percentage consistent with the substantiation on file.
- Claims framed as soothing/cooling rather than treating sunburn.
- Net content by weight or fluid measure.
⚖️ “Soothes After Sun” versus “Treats Sunburn”
This category is defined by one claim line. An after-sun gel that cools, hydrates and soothes the feel of sun-exposed skin is a cosmetic. A gel that claims to treat, heal or relieve sunburn — a medical condition — is a drug requiring a Form 10 import licence. The same applies to a cooling gel that claims to relieve pain or inflammation.
Keep the claim to cooling, soothing and hydration; hold the preservative-efficacy data for the water-based format; and route any genuine burn-treatment product to the drug route.
🛠️ Step-by-Step Registration Process
- Classify the productConfirm the article meets the definition of a cosmetic under Section 3(aaa) and is not a drug, then map it to the correct Fourth Schedule category — this drives both the fee and the certificate scope.
- Appoint the Authorised Indian AgentExecute the authorisation in the First Schedule format, signed jointly by manufacturer and agent on every page, then notarised and apostilled (Hague states) or attested by the Indian Embassy.
- Assemble the technical dossierIngredient list with percentages, specification and method of testing, finished-product test reports, inner and outer labels, GMP / ISO 22716 evidence and the Free Sale Certificate.
- Align the label to Chapter VIIndian labelling is one of the top rejection reasons. India-specific content may be stickered onto the unit pack at a bonded warehouse before clearance.
- Pay the fee on BharatkoshCompute the category, site and variant fees, pay online under head 0210041040000-00-1 and retain the acknowledgement receipt for upload.
- File Form COS-1 on SUGAMUpload the full checklist, including the correlation chart that ties each product serial number in COS-1 to the Free Sale Certificate and the authorisation.
- Respond to CDSCO queriesQueries typically concern apostille defects, Free Sale Certificate scope mismatch, ingredient limits and label non-compliance. Reply within the stipulated period, as each query restarts the effective clock.
- Receive Form COS-2Print the Registration Certificate number on every unit pack, alongside the holder's name and address, before the goods are cleared for sale.
💰 Government Fees
CDSCO cosmetic registration is priced under the Third Schedule and paid category by category, not as a single flat licence. The headline components are:
Each cosmetic category
USD 1,000 for the grant or retention of the Registration Certificate, per Fourth Schedule category.
Each additional category
USD 1,000 for every further category added to the same application.
Each variant
USD 50 for each shade, fragrance or formulation variant declared.
Each manufacturing site
USD 500 for every overseas manufacturing premises covered.
Fees are paid online through the Bharatkosh gateway under head of account 0210041040000-00-1, and the acknowledgement receipt is uploaded with the application. A duplicate certificate is USD 200, permission for a novel ingredient not previously used in India is USD 500, and inspection of an overseas manufacturing site, if ordered, is a further USD 5,000.
⏱️ Timeline & Validity at a Glance
A complete, well-drafted application is typically cleared in about four to six months. The single biggest lever on that timeline is the quality of the first filing: every query CDSCO raises effectively restarts the clock, so a dossier that pre-empts the common objections is worth far more than one filed quickly and corrected later. The certificate is valid for five years and should be re-registered before expiry — an application filed after lapse is treated as a fresh registration, and a retention fee keeps the certificate alive across the term.
⚠️ Where Aloe Vera & After-Sun Gel Applications Get Queried
Most aloe / after-sun queries concern claims and preservation:
- A sunburn-treatment or pain-relief claim that converts the product into a drug.
- Preservative-efficacy data missing for a high-water gel.
- An aloe percentage claimed without substantiation.
- A CoA with no country-of-origin specification behind it.
🔗 Related Approvals Alongside CDSCO
CDSCO registration rarely travels alone. Depending on the product and the importer, plan for these adjacent approvals in parallel, because any one of them can hold a consignment at the port even when the CDSCO certificate is in order:
- Importer-Exporter Code (DGFT) — mandatory for any importer of record, obtained before the first consignment.
- LMPC registration (Legal Metrology) — importers of pre-packaged commodities register under the Legal Metrology (Packaged Commodities) Rules, 2011 and carry MRP, net quantity, importer details, country of origin, consumer-care details and date of import on the pack.
- Wholesale licence (Form 20B / 21B) — where the Indian agent also distributes drugs alongside cosmetics.
- Drug import licence (Form 10) — where the product contains a pharmacologically active ingredient or makes a therapeutic claim, it is a drug, not a cosmetic, and this route replaces COS-1.
✅ Post-Approval Obligations
The certificate is the start of an ongoing compliance duty, not the end of it. After grant, the registration holder must:
- Print the Registration Certificate number on every unit pack, with the name and address of the certificate holder.
- Report any change in labelling, composition, testing or specification within 30 days, with an undertaking of continued compliance with the Ninth Schedule standards.
- Report any market withdrawal, regulatory restriction, cancellation of authorisation or not-of-standard-quality finding in any country where the product is sold, and stop dispatch and marketing immediately.
- Allow the Licensing Authority to draw samples for testing and to inspect the overseas manufacturing premises.
- Track BIS standard revisions — a new or amended Indian Standard becomes mandatory six months after publication.
- Diarise re-registration well before the five-year expiry.
❓ Frequently Asked Questions
Is CDSCO registration mandatory for imported aloe vera and after-sun gel?
Yes, where they are cosmetics. A soothing/moisturising gel is a Fourth Schedule skin-care preparation and must be registered under Rule 12(1) of the Cosmetics Rules, 2020. A gel that treats sunburn is a drug.
Is there an Indian Standard for aloe vera gel?
No. There is no product-specific Ninth Schedule standard, so it is assessed against the country-of-origin specification plus the Cosmetics Rules.
When does an after-sun gel become a drug?
When it claims to treat, heal or relieve sunburn or another medical condition. Cooling, soothing and hydration claims keep it a cosmetic.
What safety data does a high-water gel need?
Preservative-efficacy (challenge) data and the microbiological report, because a high-water gel is a higher microbiological risk.
How long does registration take and how long is it valid?
Around four to six months for a complete application; the certificate is valid for five years and must be re-registered before expiry.
Do we need an Authorised Indian Agent?
In practice yes — the agent files on the First Schedule format and carries statutory liability for the product in India.
Aloe Vera & After-Sun Gel Import Registration, Handled End to End
Global Approbation manages the complete CDSCO cosmetic registration for imported aloe vera & after-sun gel — classification, standard mapping, CoA and label review, dossier assembly and query response — so your first consignment clears without avoidable delay.
Talk to Our CDSCO Team Global Market Access