India's beauty boom has a gatekeeper: the Cosmetics Rules, 2020. Making creams, soaps (cosmetic-grade), shampoos or lipsticks for sale requires a state-issued manufacturing licence; importing them requires central registration — and D2C founders who contract-manufacture still need their names on the right forms. The regime is navigable and largely online (SUGAM portal); here is how it actually works.
Which form is yours
- COS-8 (application) → COS-9 (licence): manufacture for sale — your own factory
- COS-8/COS-9 loan licence route: you own the brand and formulations but manufacture at someone else's licensed premises — the standard D2C structure (the manufacturer holds their own licence; your loan licence puts you on the regulatory map)
- COS-1 → COS-2: import registration (central, via CDSCO) for foreign brands/products
- New cosmetics containing novel ingredients: separate permission pathways apply
- Pure trading/retail of licensed Indian cosmetics needs no cosmetics licence (general trade compliances apply)
The recurring founder confusion: 'my manufacturer has a licence, so I'm fine.' For pure contract buying with the manufacturer's own responsibility, arguably; but brand owners directing formulations should hold the loan licence — it is also what marketplaces and serious retailers increasingly ask brands to produce.
Premises and people: what the licence inspects
The state licensing authority (drugs control department) inspects against Schedule M-II — the cosmetics GMP annexure: adequate, separated manufacturing areas per product category (creams/powders/liquids each have space norms), sanitary construction (washable surfaces, pest exclusion, water systems), equipment suitable for the categories applied, a testing arrangement (in-house lab or an approved external lab agreement), and competent technical staff — the rules require qualified supervision under whose direction manufacturing occurs (pharmacy/chemistry qualifications per the rules). Applications name the categories you'll make; each category listed must be infrastructurally justified.
The application, step by step
- SUGAM portal (or state portal where directed): COS-8 with premises plans, equipment lists, technical staff credentials, water/test arrangements, constitution documents and fees
- Inspection by the state drugs control officers; comply with observations
- Grant of COS-9 (validity: licences now run perpetual subject to retention fees every five years under the 2020 Rules — calendar the retention)
- Post-grant: batch manufacturing records, quality testing per batch, complaint/recall records — the inspectable trail
Plan 2–4 months for a well-prepared unit: premises readiness dominates, inspections queue, and technical-staff documentation invites queries. Loan licences ride faster where the host facility is already clean. Launch calendars should put the licence on the critical path, not after the packaging order.
Labelling and claims: where brands get caught
Cosmetics labels carry their own rulebook (alongside Legal Metrology): manufacturer/licence particulars with the licence number, batch number, manufacturing date, ingredients (INCI-style listing per standards), and 'use before'/best-before per category. Claims are policed at the border of drugs: 'fairness in 7 days', 'removes dandruff', 'regrows hair' — therapeutic claims convert your cosmetic into an unlicensed drug in an inspector's reading. Ad standards (ASCI) and the Drugs & Magic Remedies Act add further claim constraints. A claims-review SOP before every artwork release is cheaper than a misbranding proceeding.
Imports and the D2C stack
Importing finished cosmetics needs CDSCO registration (COS-1/2) with product dossiers, free-sale certificates and labelling compliance — plus the usual IEC/customs stack; grey-market 'imported' stock without registration is seizure-grade non-compliance. A typical Indian D2C brand's full stack reads: loan licence (or manufacturer agreement with their COS-9), trademark, Legal Metrology registration, GST, EPR-plastic registration for packaging, and claim-compliant artwork. Assembled once, it scales with every SKU.
How Aidwish helps
Aidwish builds cosmetics ventures end to end — licence strategy (own vs loan), SUGAM applications and inspection prep, technical-staff sourcing, label and claims review, and the surrounding EPR/metrology/trademark stack — so beauty brands launch with paperwork as clean as their packaging.