Back to Blog

License to sell cosmetics online india

The licence to sell cosmetics online in India depends on what you do with the product. Under the Cosmetics Rules, 2020, manufacturing needs a State licence, importing needs a central registration, and reselling Indian-made goods needs no sale licence if the maker is licensed. This guide maps each route, the label content, the claim limits and the records to keep.

S
ShopMate Team · Nov 07, 2026 · 28 mins read
License to sell cosmetics online india

The licence to sell cosmetics online in India depends on what you do with the product. Under the Cosmetics Rules, 2020, manufacturing needs a State licence, importing needs a central registration, and reselling Indian-made goods needs no sale licence if the maker is licensed. This guide maps each route, the label content, the claim limits and the records to keep.

Quick answer: For a licence to sell cosmetics online in India, first decide whether you manufacture (State licence, Form COS-5 and COS-8), use another maker's site (loan licence, COS-6 and COS-9), import (registration, Form COS-1) or only resell Indian-made goods from licensed manufacturers (no sale licence under the Twelfth Schedule). Then label to rule 34 and avoid drug or treatment claims. All rules below were read from official copies on 12 October 2026.

What counts as a cosmetic, and where the drug boundary sits

CDSCO's guidance document on import registration quotes section 3(aaa) of the Drugs and Cosmetics Act, 1940: a cosmetic is any article intended to be rubbed, poured, sprinkled or sprayed on, or introduced into, or otherwise applied to the human body or any part of it for cleansing, beautifying, promoting attractiveness or altering the appearance, including any component of a cosmetic (CDSCO guidance document, 19 January 2021). Wikipedia gives neutral background on cosmetics and on the Drugs and Cosmetics Act, 1940.

The purposes in that definition are the boundary. CDSCO's own FAQ on registration and import answers the drug-claim question directly: cosmetics and drugs are defined separately in section 3 of the Act, and products with a drug claim on the label or in literature do not come under the definition of a cosmetic and cannot be registered as one (CDSCO FAQ, question 54). In practice, a face wash that cleanses is a cosmetic, while the same face wash sold as a treatment for a skin disease is on the other side of the line. The regulator for central matters is the Central Drugs Standard Control Organisation; State drug authorities issue manufacturing licences.

The regulatory pathway: which route are you on?

The Cosmetics Rules, 2020 were notified under G.S.R. 763(E) on 15 December 2020 and are hosted by CDSCO (Cosmetics Rules, 2020, CDSCO copy). The Rules were amended in July 2025; see the section on changes to track below. Find your row first.

What you doAuthority and form (as read in the Rules)Sale licence needed?
Manufacture in your own premisesState Licensing Authority; application in Form COS-5; licence in Form COS-8 (rules 23, 25)Not under the Twelfth Schedule if goods are from licensed manufacturers
Manufacture at another licensee's site under your brandState Licensing Authority; loan licence application in Form COS-6; licence in Form COS-9As above
Import cosmetics not yet registeredCentral Licensing Authority (CDSCO); registration application in Form COS-1 on SUGAM (rule 12); certificate in Form COS-2Import registration is required before import
Import a cosmetic already registered by another partyForm COS-4 for an Import Registration Number in Form COS-4A, valid three years, per CDSCO's FAQAs above
Resell Indian-made cosmeticsNo licence of your own, but rule 33 requires that Indian-origin goods be made by a licensed manufacturer and labelled and packed per the RulesThe Twelfth Schedule exempts the sale licence requirement on that condition

The last row rests on item 1 of the Twelfth Schedule, read with rule 64(1). It exempts cosmetics from the provisions of Chapter IV of the Act and the Rules that require a licence for sale, "provided that the cosmetics sold, if of Indian origin, are manufactured by licensed manufacturers". A reseller's duty is therefore to check the maker, not to hold a sale licence. If the maker is unlicensed, the goods fail rule 33 and are not lawfully saleable.

A second point from the same schedule: some imports are exempt from registration, but only if they are not used for domestic sale (bulk for 100 percent export, research and development samples, duty-free airport shops, international passenger amenity kits and hotel captive use). CDSCO's FAQ lists them in question 67. None of these helps an online seller who wants Indian customers.

Route 1: A manufacturing licence from the State

Rule 23 requires anyone intending to manufacture cosmetics for sale or distribution to apply to the State Licensing Authority through an identified online portal in Form COS-5 (COS-6 for a loan licence), with the fee in the Third Schedule and the documents in Part II of the Second Schedule, plus a self-declaration in Form COS-7 on good manufacturing practices, premises, plant and equipment under the Seventh Schedule. The Rules allow offline applications until the portal is operational in the State.

  • Technical staff. Rule 26 requires manufacture under the supervision of at least one whole-time employee with a qualifying credential, such as a pharmacy diploma, registration under the Pharmacy Act, an intermediate exam with chemistry or a bachelor's degree in cosmetic technology.
  • Timeline. Rule 23(5): the authority shall grant the licence within 45 days of the application if the requirements are met, or convey the deficiencies within 45 days.
  • Starting. Under rule 23(6) you may manufacture after receiving the licence and uploading a copy to the CDSCO website. Rule 23(7) requires an inspection within 30 days of grant, and rule 23(8) says the licence is deemed valid if the inspection does not happen in that time. Rule 23(9) allows cancellation after a show-cause opportunity if the self-certificate contained false information.
  • New cosmetics. A new cosmetic needs prior permission in Form COS-3 from the Central Licensing Authority, applied for in Form COS-12 (rule 32). CDSCO's FAQ describes a new cosmetic as one containing a novel ingredient not used anywhere in the world or not recognised in national or international literature (question 30).
  • Validity. Rule 30: a licence in Form COS-8 or COS-9 stays valid in perpetuity subject to payment of a retention fee before five years from issue, with a late fee of 2 percent a month for up to 180 days, after which it is deemed cancelled.

Route 2: The loan licence, the usual route for a first brand

A loan licence (rule 3(p)) is a licence for manufacturing a cosmetic granted to a person who intends to use the manufacturing site of another licensee. For a first-time brand this resembles private labelling: you own the brand and the formulation brief, and a licensed contract manufacturer produces the goods. You apply in Form COS-6 and receive Form COS-9. Our sibling guides on private label versus white label and on finding a manufacturer cover partner choice.

Questions to put to a contract manufacturer

QuestionWhy it matters
Which licence (COS-8) do you hold, and for which categories?Rule 33 requires Indian-origin goods to come from a licensed manufacturer; a licence for one category may not cover another
Has your licence copy been uploaded to the CDSCO website?Rule 23(6) ties starting manufacture to that upload
Will you support my loan licence application in Form COS-6?The application is made by the brand owner using the maker's site
How do you record batches and for how long do you keep them?Records are what an inspector asks for; the 2025 amendment, as reported, sets three years or six months after expiry, whichever is later
Who tests stability and safety, and where are the records?Rule 36 and your claims need evidence behind them
Do you manufacture to the relevant Indian Standard?Rule 39 and the Ninth Schedule make listed standards mandatory

Route 3: Importing cosmetics

Rule 12(1) states that no cosmetic shall be imported into India unless the product has been registered under the Rules by the Central Licensing Authority. The application is made in Form COS-1 on the SUGAM portal by the manufacturer, its authorised agent, the importer or an Indian subsidiary (CDSCO FAQ, question 6). CDSCO's guidance lists the documents: a covering letter, the manufacturer's authorisation in the First Schedule format and legalised or apostilled, Part I of the Second Schedule information, ingredients with percentages, original labels (a copy showing all details is acceptable per the FAQ), specifications, a pack insert if any, manufacturing licences from the country of origin, a free sale certificate for all variants, a non-animal testing declaration and heavy-metal declarations.

Fees, validity and import rules

  • The Third Schedule fees are US$1,000 for grant or retention of registration for each category, US$500 for each manufacturing site, US$50 for each variant and US$1,000 for each additional category, paid through Bharatkosh (CDSCO FAQ, questions 15 and 16). A variant is a different colour, shade or flavour; a different pack size is not a variant (questions 18 and 66).
  • Rule 14: the registration certificate stays valid in perpetuity subject to a retention fee before five years from issue. The Central Licensing Authority has up to six months to decide, and CDSCO's FAQ says its targeted timeline is 90 days (question 25).
  • Rule 18(2), quoted in CDSCO's FAQ (question 76): no cosmetic shall be imported unless the use-before date is later than six months from the date of import.
  • Animal testing: rule 39(7) states that no person shall use any animal for testing of cosmetics, and the FAQ says cosmetics tested on animals are not allowed for import (question 55).
  • Rule 34(5) and (9) require the registration certificate number on the label, preceded by "RC", with the importer's name and address; India-specific labelling may be stickered at bonded warehouses.
  • Rule 21 allows small quantities for personal use in a passenger's baggage; it does not cover goods bought for sale.

Worked example, with assumed quantities: one category, one manufacturing site and six variants would cost US$1,000 + US$500 + (6 × US$50) = US$1,800 in the Third Schedule fees above, before legalisation, testing and agent costs. A fresh registration is also needed for a change in the constitution of the registration holder or overseas manufacturer, to be applied for within 180 days (FAQ, question 38).

Retention example, also assumed: suppose the single-category registration above was granted in January and the retention fee of US$1,000 is paid 70 days after the five-year due date. The late fee is 2 percent of US$1,000 for every month or part of a month, so US$20 a month. Seventy days spans three months or part, so 3 × US$20 = US$60, on top of the retention fee, and the certificate is deemed cancelled if nothing is paid within 180 days.

Route 4: Reselling Indian-made products

If you buy finished cosmetics from a manufacturer and sell them on your store, you do not need a manufacturing licence, and the Twelfth Schedule removes the sale licence on the condition above. Your checks are about the maker and the product:

  • Ask for the manufacturer's licence number, form (COS-8 or COS-9) and the product list it covers.
  • Look for the manufacturing licence number on the label, preceded by "M", "M. L. No" or "Mfg. Lic. No." (rule 34(2)(b)).
  • Check batch number, expiry and ingredients against the label rules.
  • Do not alter, obliterate or deface the manufacturer's inscriptions on the container or label (rule 35). Re-labelling or re-packing someone else's product is a different activity and may put you in the manufacturer category.
  • Keep the manufacturer's invoice for every batch you sell.

Our live guide on GST compliance for ecommerce sellers covers the tax side of reselling.

Illustrative scenario: a home-textile seller in Surat adds a small range of lip balms and body butters from a licensed manufacturer in Gujarat. She asks the maker for its licence copy, finds the "Mfg. Lic. No." on the unit pack, files the licence copy and invoices against each batch, and lists only the products named in the maker's licence. Because she neither changes the label nor repacks, she relies on the Twelfth Schedule exemption. When the maker later introduces a new category, she asks for fresh licence evidence before listing it.

Verifying a manufacturer: a step-by-step check and a message to send

  1. Request a clear copy of the licence in Form COS-8 or COS-9 with the licence number, categories and validity details.
  2. Match the number against the "M" number on a sample pack.
  3. Find the licence on the CDSCO site, where rule 23(6) requires it to be uploaded before manufacture starts, and ask the maker for the link to it.
  4. Match each product you plan to sell against the licensed categories and ask for the batch record reference for your first lot.
  5. File everything with dates. If an authority asks, you need to show the check was made.

A message template you can adapt: "We plan to sell your products [names] online. Please send (1) your current manufacturing licence in Form COS-8 or COS-9, (2) the list of cosmetics it covers, (3) the label artwork showing licence number, batch and expiry, (4) your batch-record retention practice, and (5) written confirmation of the Indian Standards each product meets. We will keep these on file for each batch we sell."

What must be on the label: rule 34

Rule 34 of the Cosmetics Rules sets out label content for cosmetics sold in India, online or offline. The summary follows the text of the Rules on the CDSCO site.

Label itemWhat the rule says, in summary
Name of the cosmeticOn both inner and outer labels
Manufacturer name and addressComplete address of the premises where made; "Made in (country)" or the actual manufacturer where not made in the manufacturer's own factory; for packs of 30 g or less (solid, semi-solid) or 60 ml or less (liquid), name and principal place with pin code is enough
Use before or expiryMonth and year, or an expiry expression of the kinds listed in rule 34(1)(c)
Batch or lot numberPreceded by "B", "Batch No." or "Lot No."; not required for 10 g or less (solid, semi-solid) or 25 ml or less (liquid); soaps show month and year of manufacture instead
Manufacturing licence numberPreceded by "M", "M. L. No" or "Mfg. Lic. No."; imported products may omit it if not mandatory in the country of origin
Net contentsOn the outer label, by weight for solids and fluid measure for liquids; not required for perfume or toilet water up to 60 ml or solid and semi-solid packs up to 30 g
Directions and warningsWhere a hazard exists, every inner label must give directions for safe use, warnings and the names and quantities of hazardous or poisonous ingredients
IngredientsUnder the heading "INGREDIENTS": those above one percent in descending order of weight or volume, then the rest in any order; not required for packs of 60 ml or less (liquid) or 30 g or less (solid, semi-solid)
Imported productsRegistration certificate number preceded by "RC" with the importer's name and address

Single-label packs must carry everything required on both labels (rule 34(6)). Rule 34(8) adds labelling requirements in the relevant Indian Standard for products in the Ninth Schedule, and rule 37 has extra labelling for hair dyes. Hexachlorophene soap carries a cautionary note under rule 39(4).

Worked example: what four assumed pack sizes must show

The exemptions are tied to pack size and state of matter, which is easy to misapply. The table applies rule 34 to four assumed products. It shows the legal minimum on the label, not what a good product page should show.

Assumed productShort address allowed?Batch number?Ingredients list?Net contents?
15 g lip balm (solid)Yes (30 g or less)Required (more than 10 g)Not required (30 g or less)Not required (30 g or less)
25 ml face serum (liquid)Yes (60 ml or less)Not required (25 ml or less)Not required (60 ml or less)Required (not a perfume)
100 ml shampoo (liquid)No, full addressRequiredRequiredRequired
50 g body cream (semi-solid)No, full addressRequiredRequiredRequired

Note the trap in the serum row: a 25 ml liquid is exempt from batch number and ingredients on the pack, but a customer reading a listing still expects both. Put them on the product page anyway, and keep the batch records, since the batch number is what links a complaint to a production record.

Legal metrology: the other label regime

The Legal Metrology (Packaged Commodities) Rules, 2011 sit beside the Cosmetics Rules. Rule 6(1) requires a declaration of the name and address of the manufacturer or packer (and importer for imports), the generic name, the net quantity, the retail sale price as a maximum retail price inclusive of all taxes, and consumer care details (Packaged Commodities Rules with amendments). The same rule's proviso says that for cosmetics the manufacture-date declaration follows the Drugs and Cosmetics Rules, 1945.

For online sellers, rule 6(10) says an e-commerce entity shall ensure the mandatory declarations, except the month and year of manufacture or packing, are displayed on the digital and electronic network used for e-commerce transactions. In the marketplace model, responsibility for the correctness of the declarations lies with the manufacturer, seller, dealer or importer under the conditions in that sub-rule. In plain terms, your own store should show the MRP, net quantity, manufacturer or importer details, country of origin where imported, and consumer care details.

Ingredients and standards: what the Rules restrict

Rule 39 is the quality gate. A cosmetic shall comply with the Ninth Schedule specifications or other applicable quality and safety standards, and if it is not in that Schedule it must meet the Rules and the standards applicable in the country of origin. The Ninth Schedule lists 37 products with BIS standards, including skin creams (IS 6608), shampoo (IS 7884), lipstick (IS 9875), kajal (IS 15154), face pack (IS 15153), nail polish (IS 9245) and toilet soap (IS 2888). A note in the Schedule makes new or amended standards mandatory six months after BIS publishes them. The Bureau of Indian Standards sells and publishes the standards, so a manufacturer should be able to say which edition it follows.

  • Rule 39(2) bars ingredients in Annex A of IS 4707 Part 2.
  • Rule 39(3) allows only dyes, colours and pigments in IS 4707 Part 1 or Part 2 and the Tenth Schedule, with limits of 2 ppm arsenic, 20 ppm lead and 100 ppm other heavy metals in permitted colours.
  • Rule 39(5): mercury only as a preservative in eye-area products up to 70 ppm (0.007 percent); in other products unintentional mercury must not exceed 1 ppm.
  • Rule 39(6): lead and arsenic compounds for colouring are prohibited.

Fragrance is a common question. CDSCO's FAQ (question 62) says IS 4707 Part 2:2017 requires a fragrance substance to be listed once above 0.001 percent in leave-on products or 0.01 percent in rinse-off products. A BIS ingredient standard is not the same as a BIS product certification mark.

Claims: what you can and cannot say

Rule 36 is short: no cosmetic may purport or claim to purport or convey any idea which is false or misleading to the intending user. Under section 17C of the Act (PRS copy), a cosmetic is misbranded if it contains a colour which is not prescribed, is not labelled in the prescribed manner, or if the label, container or anything accompanying it bears any statement that is false or misleading in any particular (Drugs and Cosmetics Act, 1940, PRS copy). "Anything accompanying the cosmetic" is wide enough to include leaflets.

Use the table as a screening tool, not a legal classification. Medical and disease claims in the middle rows take a product out of the cosmetic definition.

Claim typeExamplesOur screening advice
Descriptive and sensory"Gentle cleanser", "matte finish", "lightly scented"Generally within cosmetic purposes; keep it true
Result claims"Visibly brighter in two weeks", "hair looks thicker"Keep documented evidence on file; avoid numbers you cannot support
Medical or disease claims"Treats acne", "cures dandruff", "prevents hair loss"CDSCO says drug claims take a product out of the cosmetic definition; avoid such wording
Safety and origin claims"Dermatologist tested", "not tested on animals", "100 percent natural"Need records; the Rules ban animal testing and require undertakings for imports
Environmental claims"Eco-friendly", "green", "sustainable"Covered by the CCPA greenwashing guidelines; substantiate before use
Standards claims"Meets BIS standards"Only if true for the specific product and standard

The advertising and consumer-law layer

The Central Consumer Protection Authority's Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022 (CCPA notification, 9 June 2022) apply to all advertisements in any medium, and to manufacturers, service providers, traders, agencies and endorsers. Points that matter to a cosmetics page:

  • Guideline 4: an advertisement must be truthful and honest, must not exaggerate scientific validity or performance, and must not suggest claims are universally accepted where informed opinion is divided.
  • Guideline 12(a): descriptions and comparisons about objectively ascertainable facts must be capable of substantiation, and you must produce it if the authority asks. Where a claim is based on research, guideline 12(b) requires the advertisement to indicate the source and date of the research.
  • Guideline 11: a disclaimer may clarify a claim but must not contradict it, hide material information or attempt to correct a misleading claim, and it must be in the same language and font as the claim, placed prominently.
  • Guideline 7: do not call a product "free" if the buyer pays for packing or the price of the main product was raised.

The CCPA also lists Greenwashing guidelines (2024) and Dark Patterns guidelines (2023) on its guidelines and advisories page; its greenwashing PDF (text on the CCPA site) is published as a PDF on the CCPA site. The page also lists an advisory on e-commerce sale of certain Ayurvedic, Siddha and Unani drugs.

The Consumer Protection Act, 2019 adds penalties for misleading advertisements (section 21, up to ten lakh rupees on a manufacturer or endorser) and offences for false or misleading advertisements (section 89), as printed in the Act. Self-regulation also matters: the Advertising Standards Council of India publishes its code and handles complaints.

A claim-substantiation file: a ready-to-use layout

Build one sheet per product, with one row per claim you make on the label, product page, social posts or ads. Suggested columns:

  1. Claim wording exactly as published, with the page or ad where it appears.
  2. Claim type from the table above (sensory, result, safety, origin, environmental, standards).
  3. Evidence: test report, consumer study summary, supplier certificate or standard reference, with date and who produced it.
  4. Evidence gap: what you would need before repeating the claim in an advertisement.
  5. Reviewer and date of last review; re-review whenever the formulation, supplier or label changes.
  6. Status: approved, hold, or withdrawn.

The 2022 guidelines expect substantiation to be produced on request, which is much easier if this sheet exists before a complaint arrives.

What happens if you get it wrong

Section 18 of the Act prohibits manufacturing for sale, selling, stocking, exhibiting or offering for sale any cosmetic which is not of standard quality or is misbranded or spurious. In the PRS copy of the Act we read, section 27A provides imprisonment up to three years and a fine for spurious cosmetics, and imprisonment up to one year or a fine up to one thousand rupees or both for other contraventions of the Chapter. Section 17D defines spurious cosmetics to include one sold under a name that belongs to another cosmetic, an imitation, or one whose label names a fictitious manufacturer. Those figures are as printed in that 2007 compilation.

The Rules also give inspectors the power to sample, seize and order that stock not be disposed of; rule 47 bars sale of stock subject to such an order. A purchaser may apply to a Government Analyst for testing under rule 40 in Form COS-13. In a dispute the customer can also use the National Consumer Helpline (consumerhelpline.gov.in).

Rule 65 requires voluntary recall: if a manufacturer or authorised agent believes a cosmetic is likely to pose a risk to health, it must immediately start withdrawal and inform the State or Central Licensing Authority. A reseller is not named in rule 65, but should still pause sales, notify buyers it can reach and inform the manufacturer.

Marketplaces and your own store

A marketplace may ask for more than the law: licence copies, test reports or brand authorisation. Amazon's seller FAQ lists beauty among categories with their own documentation requirements (Amazon seller FAQ). Read each platform's category page on its own site before you list.

On your own store, the Consumer Protection (E-Commerce) Rules, 2020 set duties for inventory entities and marketplace sellers (E-Commerce Rules). Rule 6(5) for marketplace sellers lists information to display, including the total price with the breakup, the expiry date of the good where applicable, country of origin, importer details, and a grievance officer; rule 7 gives similar duties to inventory entities, and rule 7(3) requires advertisements to be consistent with the goods' actual characteristics.

Product page checklist for a cosmetic

  • Full product name matching the label, with variant (shade or flavour) clearly named.
  • Net quantity and MRP inclusive of taxes, and the price breakup including delivery.
  • Manufacturer or importer name and address, and country of origin where imported.
  • Manufacturing licence number, and RC number for imports.
  • Full ingredient list, even where a small pack is exempt on the label.
  • Expiry or use-before guidance, batch practice and storage instructions.
  • Directions for use, warnings and a patch-test note where the maker advises one.
  • Return and refund terms and grievance contact.
  • Only claims that appear in your substantiation file.

Our live launch checklist covers the rest of the store set-up, the GST invoice guide covers invoices, and delivering to all pincodes covers shipping reach.

Import notes for resellers of foreign brands

  • You need a registered product before import. Either the brand owner or its agent holds the registration certificate in Form COS-2, or you apply yourself.
  • If the product is already registered by another party, an Import Registration Number in Form COS-4A, valid for three years, is available on an application in Form COS-4 with the Sixth Schedule undertaking (FAQ, questions 22 and 23). Old Form 43 certificates do not qualify (question 74).
  • Single kits made only of already-registered products are exempt from registration (question 68).
  • Labels must show the RC number and importer details; India-specific labelling may be stickered at bonded warehouses.
  • Allow the six-month expiry margin at import; a short-dated consignment cannot be imported.
  • Keep the registration certificate, brand authorisation and animal-testing undertaking on file.

Illustrative scenario: a Pune seller wants to stock a foreign skincare brand. The brand's Indian agent already holds a Form COS-2 certificate for the products. The seller checks the certificate lists each variant she wants, applies for an Import Registration Number in Form COS-4 with the undertaking, and, once she has it, orders only goods with a use-before date more than six months beyond the expected import date. She expects India-specific stickers to be applied at the bonded warehouse and asks the agent to include the RC number and her name and address as importer in the sticker text.

A first-brand timeline and budget: an assumed scenario

Take a founder launching six skin-care products through a licensed contract manufacturer on a loan licence. Durations are assumed planning figures except where a rule sets the time, and the fee uses the Third Schedule amount read above.

StepAssumed durationNote
Choose manufacturer, verify licence and product list2 weeksUse the questions table above
Formulation, samples and stability observation8 weeksDepends on the products and the maker
Label design and rule 34 check1 weekOverlaps with sampling
Loan licence application and grantUp to 6.5 weeksRule 23(5) allows 45 days; 45 days is 6.4 weeks
First production batch and packing3 weeksSubject to the maker's schedule
Store set-up and test orders2 weeksCan run in parallel with production

Run strictly one after another, the total is 2 + 8 + 1 + 6.5 + 3 + 2 = 22.5 weeks, about five months. Overlapping label design with sampling and store set-up with production removes 1 + 2 = 3 weeks, leaving 22.5 − 3 = 19.5 weeks, about four and a half months, before any delay at the maker's end. The loan licence fee for six items in one category is ₹10,000, since the Third Schedule covers up to ten items; beyond ten, add ₹500 per item, so 14 items would cost 10,000 + (4 × 500) = ₹12,000. This is an illustration, not a quote, and State-specific charges may apply.

Mistakes and how to avoid them

  • Assuming "resale means no checks". The sale-licence exemption depends on the maker being licensed. Keep the licence evidence for every supplier.
  • Using a treatment word on the product page. "Cures", "treats" or "prevents hair loss" can move a product toward drug territory. Rewrite to cosmetic purposes or take advice.
  • Misreading pack-size exemptions. The batch exemption (10 g or 25 ml) is not the same as the ingredients exemption (30 g or 60 ml). Use the table above.
  • Treating a disclaimer as a fix. Under guideline 11 of the 2022 CCPA guidelines, a disclaimer cannot correct a misleading claim.
  • Importing short-dated stock. Rule 18(2) bars import unless use-before is more than six months away.
  • Re-labelling someone else's goods. Rule 35 bars altering manufacturer inscriptions.
  • Ignoring Legal Metrology declarations. MRP, net quantity and consumer care details need to be on the pack and, for MRP and most other declarations, on your store.
  • Letting the licence lapse. A manufacturing licence or registration is perpetual only if the five-year retention fee is paid; the authority can deem it cancelled after 180 days.
  • Using "natural" or "dermatologist tested" without records. Add the claim to the substantiation file first.

The document file to build before launch

  • Manufacturer's licence copy and product list, or your own licence and Form COS-7 declaration.
  • Formulation and ingredient list per product, with supplier certificates for colours and preservatives.
  • Label proofs checked against rule 34, the relevant Indian Standard and Legal Metrology declarations.
  • Safety and stability records and the evidence behind each claim.
  • Batch records and manufacturer invoices.
  • For imports: registration certificate or import registration number, authorisation, free sale certificate, animal-testing undertaking, labels.
  • A complaint log and a written withdrawal plan, with contact details of the manufacturer and the authority.

Changes to track

Law-firm and industry notes report that the Rules were amended in July 2025: Fox Mandal cites G.S.R. 513(E) dated 29 July 2025, and ChemLinked says it was published on 31 July 2025. The reported changes include defined "use before" and "date of expiry" (use before means before the first day of the stated month; expiry means the last day of that month), the Central Drugs Laboratory becoming the Central Cosmetics Laboratory, batch records in hard copy or electronic form, a new rule 31A on suspension or cancellation of licences with a 90-day appeal to the State Government, and revised export-label provisions.

Frequently asked questions

Do I need a licence to sell cosmetics online in India?

If you manufacture, you need a State licence; if you import, CDSCO registration. If you only resell Indian-made cosmetics, the Twelfth Schedule exempts the sale licence, provided the maker is licensed. Check each product against its maker's licence and keep records, because the exemption depends on that condition and on correct labelling.

What is a loan licence for cosmetics?

A loan licence lets a person manufacture under their own brand at another licensee's manufacturing site. Rule 3(p) defines it, the application is in Form COS-6, and the licence is in Form COS-9, granted by the State Licensing Authority. It suits brand owners who use a contract manufacturer.

What must a cosmetic label contain?

Under rule 34: product name, manufacturer name and address, use-before or expiry, batch number, manufacturing licence number, net contents, directions and warnings where a hazard exists, and an ingredients list, with exemptions for small packs. Imported products add the RC number and importer details. Check any Indian Standard labelling as well.

Can I say my cosmetic treats acne or hair fall?

Treat these as high risk. CDSCO's FAQ says products with a drug claim do not fall within the cosmetic definition, and rule 36 bars false or misleading claims. Leave treatment wording out of cosmetic listings, and keep evidence for every result claim in a substantiation file.

How long does a cosmetic import registration last?

Rule 14 says the registration certificate remains valid in perpetuity subject to a retention fee before five years from issue. An Import Registration Number in Form COS-4A is valid for three years, per CDSCO's FAQ. Late retention attracts a 2 percent monthly late fee for up to 180 days.

Can I sell homemade cosmetics online?

Making cosmetics for sale or distribution is manufacturing, which rule 23 says needs a State licence and a premises and staff declaration. Selling unlicensed homemade goods would fail rule 33. If you want to start small, a loan licence with a licensed contract manufacturer is one route.

Do I need BIS certification to sell cosmetics?

The Rules make BIS standards in the Ninth Schedule mandatory for the listed products, such as skin creams, shampoos and lipsticks, and reference IS 4707 ingredient lists.

What are the penalties for selling misbranded cosmetics?

Section 18 of the Act prohibits selling misbranded or spurious cosmetics. In the 2007 PRS copy we read, section 27A sets up to three years' imprisonment and a fine for spurious cosmetics, and up to one year or a fine up to ₹1,000, or both, for other contraventions.

Is a disclaimer enough to fix a doubtful claim?

No. Guideline 11 of the CCPA's 2022 guidelines says a disclaimer must not contradict the claim, hide material information or attempt to correct a misleading claim, and must match the claim's language and font and sit prominently. If the claim is not supportable, remove it rather than footnoting it.

Do I need to display licence details on my own store?

The Rules require the licence number on the label, and Legal Metrology and E-Commerce Rules require specified declarations and information to be displayed online. Showing the manufacturer's licence number, importer details, expiry guidance and ingredients on the product page, matching the pack, is a sensible practice.

Next step: a licence to sell cosmetics online, then a store to sell from

Once your licence to sell cosmetics online is in order, a store lets you show ingredients, warnings and licence details on each product page, take payments and ship. You can book a ShopMate demo, review the pricing page, and read about ShopMate.

Disclaimer: This article is for general information only and is not legal, tax or financial advice. ShopMate is the publisher of this guide and has a commercial interest in the platform it describes. Rules, thresholds, fees and platform terms change, and your situation may differ. Consult a qualified chartered accountant or legal professional before making decisions.

S

Written by ShopMate Team

Published Nov 07, 2026
Share