Hair oil is a cosmetic under the Cosmetics Rules, 2020 and must be registered with CDSCO before import. Chemically it is one of the more straightforward categories — the Certificate of Analysis against IS 7123 covers most of the technical case — but it sits on two regulatory fault lines that catch importers out.
The first is therapeutic claims: a hair oil that promises to cure hair fall or promote growth is making a drug claim. The second is Ayurvedic positioning: a product with Ayurvedic, Siddha or Unani claims falls under the Ministry of AYUSH, not CDSCO, and takes a completely different route to market.
📌 Hair-fall and hair-growth claims are therapeutic claims. They will either be struck from the label or push the product out of the cosmetic route entirely — and an Ayurvedic, Siddha or Unani claim sends it to AYUSH rather than CDSCO.
📋 Is CDSCO Registration Mandatory for Hair Oil?
Yes. Hair oil is a cosmetic within the Fourth Schedule category of hair-care preparations, provided it is presented as a cosmetic and not with therapeutic or Ayurvedic claims. IS 7123 is the applicable Indian Standard.
Where the product carries Ayurvedic, Siddha or Unani claims, it is regulated by the Ministry of AYUSH instead and cannot be registered under the CDSCO cosmetic route — confirming its positioning up front avoids a wasted application.
📘 The Indian Standard That Applies
The Ninth Schedule points hair oil to IS 7123. The Certificate of Analysis must report acid value, saponification value, unsaponifiable matter, refractive index, rancidity and mineral-oil content — the parameters that characterise the oil base and its stability.
Beyond the CoA, CDSCO expects a declaration of the base-oil composition and any added vitamins or plant extracts, and stability and rancidity data. Where fragrance is added, an allergen declaration is expected as well.
🗂️ Documents Required for Hair Oil
Every Form COS-1 application carries the same core set — covering letter; First Schedule authorisation; Part-I of the Second Schedule; ingredient list with percentages; inner and outer labels; specification and method of testing; finished-product Certificate of Analysis; country-of-origin manufacturing licence or marketing authorisation; original Free Sale Certificate; non-animal-testing declaration; heavy-metal and hexachlorophene declaration; GMP / ISO 22716 certificate; correlation chart; Bharatkosh receipt; and the signed Form COS-1. On top of that base, this product needs:
- Certificate of Analysis against IS 7123 — acid value, saponification value, unsaponifiable matter, refractive index, rancidity and mineral-oil content.
- Declaration of the base-oil composition and any added vitamins or plant extracts.
- Stability and rancidity data.
- Where therapeutic or Ayurvedic claims appear: confirmation that the product is being placed as a cosmetic (Ayurvedic, Siddha or Unani claims fall under AYUSH, not CDSCO).
- Allergen declaration for any added fragrance.
🏷️ Product-Specific Label Requirements
Hair-oil labels are checked for these product-specific points:
- Type of oil and directions for use.
- Net content stated by weight or fluid measure.
- Manufacturing licence number preceded by “M” or “Mfg. Lic. No.” where the country of origin issues one; otherwise the omission is permitted.
- The general Chapter VI content — manufacturer or “Made in”, batch number, expiry and RC number.
🛠️ 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 category under the Fourth Schedule — this drives both the fee and the certificate scope.
- Appoint the Authorised Indian AgentExecute the authorisation in the format of the First Schedule, signed jointly by the manufacturer and the 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 Bharatkosh 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.
- 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 product-family by product-family, 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 of cosmetic 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 by the certificate.
Fees are paid online through the Bharatkosh gateway under head of account 0210041040000-00-1, and the acknowledgement receipt is uploaded with the application. As a worked example, an importer registering one category from a single factory with six shade or fragrance variants would pay USD 1,000 (category) + USD 500 (site) + 6 × USD 50 (variants) = USD 1,800 in government fees, before professional and testing costs. Inspection of an overseas 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.
⚠️ Where Applications Usually Get Queried
Hair-oil queries are nearly always about claims:
- Hair-fall or hair-growth claims, which are therapeutic and will be struck from the label or push the product out of the cosmetic route.
- Ayurvedic, Siddha or Unani claims, which move the product to AYUSH regulation entirely.
- Certificate of Analysis parameters that do not match the IS 7123 set, or missing rancidity and mineral-oil data.
- Added fragrance with no allergen declaration.
🔗 Related Approvals Alongside CDSCO
Alongside the CDSCO registration, imported hair oil may involve:
- Importer-Exporter Code (DGFT) — mandatory for any importer of record, obtained before the first consignment.
- LMPC registration (Legal Metrology) — importers of pre-packaged commodities must 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 drug licence (Form 20B / 21B) — where the Indian agent also distributes drugs alongside cosmetics.
- AYUSH licence — where the product carries Ayurvedic, Siddha or Unani claims, it is regulated by the Ministry of AYUSH and takes an AYUSH licence rather than a CDSCO cosmetic registration.
- Drug import licence (Form 10) — if the product contains a pharmacologically active ingredient or carries a therapeutic claim, it is a drug, not a cosmetic, and this route no longer applies.
❓ Frequently Asked Questions
Can my hair oil say it stops hair fall or promotes growth?
No, not as a cosmetic. Hair-fall and hair-growth claims are therapeutic claims; they will be struck from the label or take the product out of the cosmetic route entirely, requiring a different regulatory approval.
What if my hair oil is Ayurvedic?
Then it is regulated by the Ministry of AYUSH, not CDSCO. A product with Ayurvedic, Siddha or Unani claims takes an AYUSH licence and cannot be registered under the CDSCO cosmetic route.
Which standard applies to hair oil?
IS 7123 under the Ninth Schedule. The Certificate of Analysis must report acid value, saponification value, unsaponifiable matter, refractive index, rancidity and mineral-oil content.
Is CDSCO registration mandatory to import hair oil into India?
Yes. Under Rule 12(1) of the Cosmetics Rules, 2020, no cosmetic may be imported into India unless the product is registered with the Central Licensing Authority. The registration is granted product by product in Form COS-2 and must be in place before the first consignment lands.
Which form and portal are used?
The application is Form COS-1, filed online on the CDSCO SUGAM portal by the overseas manufacturer or, far more commonly, by an Authorised Indian Agent. The approval is issued as an Import Registration Certificate in Form COS-2.
How long does registration take and how long is it valid?
A complete application is usually cleared in about four to six months, and each CDSCO query effectively restarts the clock. The certificate is valid for five years from the date of issue and must be re-registered before it lapses.
Do we need an Indian agent?
Almost every application is filed through an Authorised Indian Agent, appointed on the First Schedule format. The agent carries statutory liability for the product in India even after the power of attorney is withdrawn, so this is a substantive appointment, not a formality.
Hair-Oil Import Registration, on the Right Regulatory Route
Global Approbation manages CDSCO registration for imported hair oil — IS 7123 review, claim vetting and the cosmetic-versus-AYUSH decision — so your product is filed on the route that actually gets it to market.
Talk to Our CDSCO Team Global Market Access