Nail polish and nail enamel are cosmetics under the Cosmetics Rules, 2020 and must be registered with CDSCO before import. The registration itself turns on IS 9245 and a full solvent-and-resin declaration, but nail enamel carries a second, parallel compliance track that catches importers out: it is flammable, and it ships as dangerous goods.
The application is Form COS-1, granted as Form COS-2. A registration that is entirely in order will still see the consignment held at the port if the dangerous-goods documentation is not equally in order — so nail enamel is a category where CDSCO and logistics compliance have to be planned together.
📌 Nitrocellulose-based enamels are flammable and travel as dangerous goods. A perfectly valid CDSCO registration does not clear a shipment on its own — the DG paperwork and Safety Data Sheet have to be right too.
📋 Is CDSCO Registration Mandatory for Nail Polish & Nail Enamel?
Yes. Nail polish and nail enamel are cosmetics within the Fourth Schedule category of nail preparations, and import registration is mandatory. IS 9245 is the applicable Indian Standard.
As with lip colour, each shade is a chargeable variant, so large shade ranges drive both the fee and the documentation, and must be fully declared to avoid an under-declaration query.
📘 The Indian Standard That Applies
The Ninth Schedule points nail polish and nail enamel to IS 9245. The Certificate of Analysis against IS 9245 must report drying time, adhesion, gloss, non-volatile matter, flexibility and resistance to water.
Because nail enamel is a solvent system, CDSCO also expects a full solvent-and-resin composition sheet and a declaration on toluene, formaldehyde, formaldehyde resin, dibutyl phthalate and camphor content — the ingredients most restricted or scrutinised in this category.
🗂️ Documents Required for Nail Polish & Nail Enamel
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 9245 — drying time, adhesion, gloss, non-volatile matter, flexibility and resistance to water.
- Full solvent-and-resin composition sheet.
- Declaration on toluene, formaldehyde, formaldehyde resin, dibutyl phthalate and camphor content.
- Colourant declaration by CI number against IS 4707 (Part 1) and the Tenth Schedule.
- Safety Data Sheet (SDS) — nitrocellulose-based enamels are flammable and travel as dangerous goods.
- Shade-wise variant list for fee computation.
🏷️ Product-Specific Label Requirements
Nail-enamel labels are checked for these product-specific points:
- Flammability caution and storage direction.
- Directions for safe use — keep away from eyes and out of reach of children.
- Net content stated by fluid measure.
- 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
Nail-enamel problems split between the registration and the port:
- Dangerous-goods documentation missing at the port even though the CDSCO registration is in order.
- Large shade ranges under-declared as variants.
- Restricted-solvent content (toluene, formaldehyde, dibutyl phthalate) not declared or over the accepted level.
- Colourants not mapped to IS 4707 (Part 1) and the Tenth Schedule.
🔗 Related Approvals Alongside CDSCO
Nail enamel touches more than one regulator — plan for:
- 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.
- PESO / dangerous-goods handling — flammable nail enamel needs storage, transport and handling that comply with the applicable dangerous-goods rules; get the DG documentation and SDS right or the consignment is held regardless of the CDSCO 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
My CDSCO registration is approved — why is my nail polish stuck at the port?
Almost certainly a dangerous-goods issue. Nitrocellulose nail enamel is flammable and ships as dangerous goods; if the Safety Data Sheet and DG declarations are missing or wrong, the consignment is held even though the cosmetic registration is valid.
Which standard applies to nail polish?
IS 9245 under the Ninth Schedule. The Certificate of Analysis must report drying time, adhesion, gloss, non-volatile matter, flexibility and resistance to water.
Do I need to declare each nail-polish shade?
Yes. Each shade is a variant charged at USD 50 and must appear in the authorisation, the Free Sale Certificate and Form COS-1. Under-declaring a large shade range is a common query.
Is CDSCO registration mandatory to import nail polish & nail enamel 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.
Nail-Enamel Import: Registration and Dangerous-Goods, Together
Global Approbation manages CDSCO registration for imported nail polish and nail enamel — IS 9245 review, solvent and colourant declarations, shade reconciliation and the dangerous-goods documentation — so the registration and the shipment both clear.
Talk to Our CDSCO Team Global Market Access