Pressed eyeshadows, glitter shadows and multi-pan palettes are eye-area colour cosmetics, 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 shades and the factory.
Because they are applied to the eye area, eyeshadows face the strictest colour controls in colour cosmetics — and a palette multiplies the variant count.
📌 Under Rule 12(1) of the Cosmetics Rules, 2020, no Eyeshadow & Eye Palettes 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 Eyeshadow & Eye Palettes?
Yes. Eyeshadow and eye palettes are Fourth Schedule eye preparations and require CDSCO registration before import. Each shade in a palette is declared, and the eye-area colour and mercury rules apply throughout.
The application is filed by the overseas manufacturer or, in practice, its Authorised Indian Agent.
📘 The Indian Standard in Detail
No single product-specific Indian Standard applies to eyeshadow, 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. The colour rules, however, are the tightest of any category: colourants must be restricted to those permitted for use in the eye area under IS 4707 (Part 1) — several coal-tar colours permitted elsewhere are not allowed near the eye.
Mercury is permitted only as a preservative in eye-area products and only up to 70 ppm (0.007%), so a mercury declaration is expected, and an ophthalmological safety / eye-irritation assessment strengthens the file. A talc-based pressed shadow also needs the asbestos-free talc declaration, and glitter/effect pigments must carry eye-area-permitted CI numbers.
🗂️ 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 Eyeshadow & Eye Palettes
On top of the core dossier above, an eyeshadow / palette application needs:
- Colourant declaration restricted to colours permitted for the eye area under IS 4707 (Part 1) — several coal-tar colours permitted elsewhere are not permitted near the eye.
- Mercury declaration — permitted only as a preservative in eye-area products, up to 70 ppm (0.007%).
- Ophthalmological safety / eye-irritation assessment.
- Certificate of Analysis against the country-of-origin finished-product specification, plus microbiological limits.
- Asbestos-free talc declaration for talc-based pressed shadows.
- Shade-wise composition sheet — each shade (including every pan in a palette) is a separate variant at USD 50.
⚗️ 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.
The eye-area colour list is narrower than the general one, mercury is capped at 70 ppm as a preservative, and glitter/effect pigments must also be eye-area-permitted. Talc-based shadows need the asbestos-free report.
🏷️ Eyeshadow & Eye Palettes Label Requirements
In addition to the general Chapter VI requirements, eyeshadow labels are checked for these product-specific points:
- Directions for safe use and a caution to avoid direct contact with the eye.
- Shade names, and batch number and expiry on the inner label.
- Registration Certificate number preceded by “RC” or “Reg. Cert. No.”.
- Net content by weight.
⚖️ The Eye-Area Colour List and the Mercury Cap
Eyeshadow raises no drug question, but it faces the strictest safety gate in colour cosmetics. The recurring failures are eye-specific: colourants that are permitted on skin or lips but not on the eye area; mercury above the 70 ppm preservative allowance; and missing eye-irritation data. Glitter and effect pigments are the common trap — they must carry eye-area-permitted CI numbers.
Build the palette's colour list from the eye-area permitted colours from the outset, keep mercury within 70 ppm, and hold an eye-irritation assessment.
🛠️ 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.
Palettes are the biggest fee driver in makeup: a 12-pan eyeshadow palette from one factory is USD 1,000 (category) + USD 500 (site) + 12 × USD 50 (pans) = USD 2,100 in government fees, since each pan is a declarable shade variant.
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 Eyeshadow & Eye Palettes Applications Get Queried
Most eyeshadow queries are eye-area colour and safety driven:
- Colourants not on the eye-area permitted list under IS 4707 (Part 1).
- Glitter or effect pigments without eye-area-permitted CI numbers.
- Missing eye-irritation / ophthalmological safety data.
- Palette pans under-declared as variants at USD 50 each.
🔗 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 eyeshadow and palettes?
Yes. They are Fourth Schedule eye preparations and cannot be imported until registered under Rule 12(1) of the Cosmetics Rules, 2020, with the certificate issued in Form COS-2.
Which colours can an eyeshadow use?
Only colours permitted for the eye area under IS 4707 (Part 1). Several coal-tar colours permitted elsewhere on the body are not permitted near the eye, and glitter/effect pigments must also be eye-area-permitted.
Is mercury allowed in eyeshadow?
Only as a preservative in eye-area products, and only up to 70 ppm (0.007%). A mercury declaration is expected.
Is each pan in a palette charged separately?
Yes. Each shade, including every pan in a palette, is a variant at USD 50 and must be declared in the authorisation, the Free Sale Certificate and Form COS-1.
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.
Eyeshadow & Eye Palettes Import Registration, Handled End to End
Global Approbation manages the complete CDSCO cosmetic registration for imported eyeshadow & eye palettes — 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