Lipstick and lip colour are cosmetics under the Cosmetics Rules, 2020 and must be registered with CDSCO before import. Because lip products are ingested in small quantities over time, the category attracts particular attention to colourants and heavy metals, and every shade is treated as a chargeable variant.
The application is Form COS-1 on SUGAM, granted as Form COS-2. For lip colour, the two make-or-break issues are a Certificate of Analysis against IS 9875 and a colourant declaration that maps every Colour Index number to the Indian permitted list — a shade that is legal in the EU or US can still be rejected in India.
📌 A colour permitted in the EU or US is not automatically permitted in India. Every colourant must appear in IS 4707 (Part 1) and the Tenth Schedule, and lead and arsenic compounds may never be used as colourants.
📋 Is CDSCO Registration Mandatory for Lipstick & Lip Colour?
Yes. Lipstick and lip colour sit in the Fourth Schedule category of colour cosmetics / lip-care preparations, and import registration is mandatory. Lipsalve is covered by IS 10284.
Each shade is a separate variant that must be declared and paid for, so the shade range drives both the fee and the documentation load for this category more than for most others.
📘 The Indian Standard That Applies
The Ninth Schedule points lipstick to IS 9875 and lipsalve to IS 10284. The Certificate of Analysis against IS 9875 must report melting point, breaking point, the drop test, perfume and rancidity, and freedom from grittiness.
Alongside the CoA, lip colour needs a colourant declaration listing every colour by its Colour Index (CI) number, mapped to IS 4707 (Part 1) and the Tenth Schedule, together with a heavy-metals report on the colourants: arsenic not more than 2 ppm, lead not more than 20 ppm, and other heavy metals not more than 100 ppm in total.
🗂️ Documents Required for Lipstick & Lip Colour
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 9875 reporting melting point, breaking point, drop test, perfume and rancidity, and freedom from grittiness.
- Colourant declaration listing every colour by Colour Index (CI) number, mapped to IS 4707 (Part 1) and the Tenth Schedule.
- Heavy-metals test report on the colourants — arsenic not more than 2 ppm, lead not more than 20 ppm, other heavy metals not more than 100 ppm in total.
- Shade-wise composition sheet — each shade is a separate variant attracting a USD 50 fee.
- Declaration that no lead or arsenic compounds have been used for colouring.
- Microbiological report.
🏷️ Product-Specific Label Requirements
Lip-colour labels are checked for these product-specific points:
- Shade name and shade number on the unit pack.
- Ingredient list — not mandatory where net content is 30 g or less, but recommended.
- Registration Certificate number preceded by “RC” or “Reg. Cert. No.” on the unit pack.
- The general Chapter VI content — manufacturer or “Made in”, batch number and expiry.
🛠️ 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
Lipstick queries almost always concern colourants or shade reconciliation:
- Use of a CI number permitted in the EU or US but not listed in IS 4707 (Part 1).
- Shade lists in the authorisation, the Free Sale Certificate and Form COS-1 that do not reconcile.
- Heavy-metal results on colourants that exceed the arsenic, lead or total-metal limits.
- Shades under-declared as variants, understating both the record and the fee.
🔗 Related Approvals Alongside CDSCO
Alongside the CDSCO registration, imported lip colour usually needs:
- 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 was my imported shade rejected when it is legal abroad?
Because India maintains its own permitted-colourant list. A Colour Index number allowed in the EU or US must still appear in IS 4707 (Part 1) and the Tenth Schedule to be used in India; if it does not, the shade cannot be registered.
Do I pay a fee for every lipstick shade?
Yes. Each shade is a variant charged at USD 50 and must be declared in the authorisation, the Free Sale Certificate and Form COS-1. A large shade range materially affects the fee and the documentation.
What standard applies to lipstick?
IS 9875 for lipstick and IS 10284 for lipsalve, under the Ninth Schedule. The Certificate of Analysis must report the IS 9875 parameters.
Is CDSCO registration mandatory to import lipstick & lip colour 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.
Lipstick Import Registration, Shade by Shade
Global Approbation manages CDSCO registration for imported lipstick and lip colour — IS 9875 review, colourant mapping to the Indian list, heavy-metal screening and shade reconciliation across every document — so your full range clears together.
Talk to Our CDSCO Team Global Market Access