Kajal, kohl, eyeliner and mascara are cosmetics applied to the most sensitive area of the face, and CDSCO registers them under the Fourth Schedule category of eye preparations with correspondingly tight controls. Every one must be registered under the Cosmetics Rules, 2020 before import.
The application runs through Form COS-1 to Form COS-2 like any cosmetic, but eye products carry two special constraints: colourants are restricted to those permitted specifically for the eye area, and traditional kohl formulations are a known lead risk that CDSCO scrutinises very closely.
📌 Several coal-tar colours permitted elsewhere on the body are not permitted around the eye. And mercury is allowed only as a preservative in eye-area products, capped at 70 ppm (0.007%) — the single exception to the general mercury prohibition.
📋 Is CDSCO Registration Mandatory for Kajal, Kohl, Eyeliner & Mascara?
Yes. Kajal, kohl, eyeliner and mascara are cosmetics within the Fourth Schedule category of eye preparations, and import registration is mandatory. Kajal is covered by IS 15154 and cosmetic pencils by IS 9832.
Because the eye area is high-risk, the dossier is expected to carry ophthalmological safety data in addition to the usual chemistry and microbiology, and sterility data for mascara and liquid liners.
📘 The Indian Standard That Applies
The Ninth Schedule points kajal to IS 15154 and cosmetic pencils (eyeliner pencils) to IS 9832. The Certificate of Analysis against IS 15154 must report pH, heavy metals, freedom from grittiness and microbiological limits.
Colourants are the pinch point: the colourant declaration must be restricted to colours permitted for use in the eye area under IS 4707 (Part 1), which is a narrower list than for other cosmetics. Mercury, if used, is permitted only as a preservative and only up to 70 ppm.
🗂️ Documents Required for Kajal, Kohl, Eyeliner & Mascara
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 15154 for kajal — pH, heavy metals, freedom from grittiness and microbiological limits.
- Colourant declaration restricted to colours permitted for use in the eye area under IS 4707 (Part 1).
- Mercury declaration — permitted only as a preservative in eye-area products, and only up to 70 ppm (0.007%).
- Lead test report — scrutinised closely for traditional kohl formulations.
- Ophthalmological safety / eye-irritation assessment.
- Sterility and preservative-efficacy data for mascara and liquid liners.
🏷️ Product-Specific Label Requirements
Eye-cosmetic labels are checked for these product-specific points:
- Directions for safe use and warnings on eye contact.
- Recommended period-after-opening for mascara and liquid formats.
- Batch number and expiry — mandatory on the inner label.
- The general Chapter VI content — manufacturer or “Made in”, ingredient list where required, 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
Eye-cosmetic queries concentrate on safety and colourants:
- Detectable lead in traditional kohl formulations.
- Colourants that are not on the eye-area permitted list under IS 4707 (Part 1).
- Missing eye-irritation or ophthalmological safety data.
- Missing sterility or preservative-efficacy data for mascara and liquid liners.
🔗 Related Approvals Alongside CDSCO
Alongside the CDSCO registration, imported eye cosmetics usually need:
- 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.
- 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
Why is traditional kohl so heavily scrutinised?
Because traditional kohl is a recognised lead risk. CDSCO examines the lead test report closely, and detectable lead is a common reason for rejection, so the formulation must demonstrably meet the heavy-metal limits.
Can I use the same colours as my face makeup range?
Not necessarily. The eye area has a narrower permitted-colourant list under IS 4707 (Part 1). Several coal-tar colours allowed elsewhere on the body are not permitted around the eye.
Is mercury ever allowed in eye cosmetics?
Only as a preservative, and only up to 70 ppm (0.007%). This is the single exception to the general rule that finished products must not contain more than 1 ppm of unintentional mercury.
Is CDSCO registration mandatory to import kajal, kohl, eyeliner & mascara 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.
Eye-Cosmetic Import Registration, With the Lead Risk Managed
Global Approbation manages CDSCO registration for imported kajal, kohl, eyeliner and mascara — IS 15154 review, eye-area colourant screening, lead and mercury verification and ophthalmological data — so a high-scrutiny category clears cleanly.
Talk to Our CDSCO Team Global Market Access