Published: 30 Jul 2026
CDSCO Directs Enhanced Vigilance Against Unregistered Imported Cosmetics: What Importers, Brands & Distributors Need to Know
Omega QMS Compliance Insights
Omega QMS
The Central Drugs Standard Control Organization (CDSCO) has issued a nationwide enforcement circular directing authorities to intensify surveillance against imported cosmetic products being sold in India without a valid Import Registration Certificate.
The circular does not introduce a new regulatory requirement, but it signals a significant increase in enforcement of the Cosmetics Rules, 2020. CDSCO has instructed both its field inspectorate and port authorities to strengthen checks on imported cosmetics, targeting products that are imported without registration or continue to be sold after their registration has expired or lapsed.
For cosmetic importers, brand owners, distributors, retailers and e-commerce sellers, this is a clear sign that compliance with India’s cosmetic import regulations is under closer scrutiny.
Key Takeaways
CDSCO has directed enhanced surveillance on imported cosmetics across the country.
Imported cosmetics must have a valid Import Registration Certificate before entering or being sold in India.
Port Officers have been instructed to strengthen checks at ports of entry.
State Licensing Authorities and CDSCO inspectorates will conduct increased market surveillance.
Businesses should immediately verify the registration status of every imported cosmetic product they market.
The circular is effective immediately.
What Is the Legal Requirement?
The circular reinforces the existing requirement under Rule 12(1) of the Cosmetics Rules, 2020, notified under the Drugs and Cosmetics Act, 1940. Under this provision:
- No cosmetic may be imported into India unless registered by the Central Licensing Authority or an officer delegated under Rule 5(1)
- Import registration is obtained by applying in Form COS-1 through CDSCO’s SUGAM Portal
- Registration is mandatory before imported cosmetics can legally enter the Indian market
Why Did CDSCO Issue This Circular?
CDSCO has observed that imported cosmetic products are being sold in the domestic market without valid Import Registration Certificates. This indicates that some products may have:
- Entered India without completing the mandatory registration process
- Continued to be sold after registration had expired
- Been marketed despite never obtaining registration
To address these compliance gaps, CDSCO has instructed enforcement authorities across India to significantly strengthen surveillance.
What Has CDSCO Directed?
The circular sets up a two-tier enforcement approach covering both border controls and domestic market surveillance.
Enhanced Market Surveillance
All State Licensing Authorities (SLAs) and CDSCO Zonal and Sub-Zonal Offices must direct their inspectorates to intensify surveillance of imported cosmetics in the domestic market. Inspectors will verify whether products being sold have a valid Import Registration Certificate.
Strengthened Port-Level Checks
Port Officers must maintain strict vigilance to prevent imported cosmetics without valid registration from entering India. This is expected to bring increased scrutiny of cosmetic consignments arriving at Indian ports.
Who Should Be Concerned?
The circular is relevant to businesses across the cosmetics supply chain, including:
- Cosmetic importers
- International cosmetic brands entering India
- Authorized Indian representatives
- Distributors and wholesalers
- Retail chains
- E-commerce marketplaces
- Third-party importers
- Contract manufacturers importing finished cosmetic products
Even businesses that do not import directly should make sure the products they distribute or sell have valid registration.
Why This Matters for Businesses
The legal requirement has existed since the Cosmetics Rules, 2020 came into force, but this circular shows CDSCO is placing greater emphasis on enforcement.
Businesses should review whether:
- Every imported cosmetic SKU has a valid Import Registration Certificate
- Registration certificates are current and not expired
- Imported products match the registered formulation, packaging and labelling
- Suppliers and third-party importers have maintained regulatory compliance
- Internal compliance records can be produced during inspections
Failure to maintain valid registration may expose businesses to increased regulatory scrutiny and enforcement.
Potential Business Impact
Businesses that fail to comply may face the following consequences. Companies importing multiple brands or large portfolios should review their registration status proactively to minimize risk.
- Increased inspections by CDSCO and State authorities
- Enhanced scrutiny at ports of entry
- Delays in customs clearance
- Product detention or seizure
- Market withdrawal of non-compliant products
- Regulatory action under the Drugs and Cosmetics Act, 1940
- Business disruption from non-compliant inventory
Recommended Actions
Verify Every Product’s Registration
Confirm that every imported cosmetic product has a valid Import Registration Certificate.
Check Active Status and Variants
Confirm registrations remain active and cover all marketed variants.
Review Customs Documentation
Review the documentation maintained for customs clearance.
Audit Distributors and Importers
Audit distributor and importer compliance records.
Train Your Teams
Train regulatory and logistics teams on current CDSCO requirements.
Close Gaps Before Future Imports
Address any compliance gaps before your next imports.
Taking these steps now can significantly reduce the risk of enforcement action during inspections.
How Omega QMS Can Help
Navigating India’s cosmetics import regulations takes careful attention to registration, documentation and ongoing compliance. Omega QMS provides end-to-end regulatory support for cosmetic manufacturers, importers and brand owners, including:
- CDSCO Cosmetic Import Registration
- Form COS-1 application support
- SUGAM Portal documentation
- Import compliance advisory
- Regulatory documentation review
- Label compliance guidance
- Product classification assistance
- End-to-end CDSCO regulatory consulting
Our regulatory professionals help businesses obtain and maintain cosmetic import registrations while ensuring continued compliance with India’s evolving regulatory framework.
Conclusion
CDSCO’s latest circular is not a change in law. It is a clear sign that enforcement of the existing Cosmetics Rules, 2020 is being intensified.
With enhanced surveillance at both ports and in the domestic market, businesses that import, distribute or sell cosmetics should verify that every imported product is supported by a valid Import Registration Certificate. Proactive compliance today can help prevent customs delays, enforcement actions and business disruption tomorrow.
Frequently Asked Questions
No. The circular reinforces the existing registration requirement under Rule 12(1) of the Cosmetics Rules, 2020.
Yes. Imported cosmetic products must have a valid Import Registration Certificate before they can legally be imported into India.
Form COS-1 is the application form used to obtain an Import Registration Certificate through CDSCO’s SUGAM Portal.
CDSCO’s Zonal and Sub-Zonal Offices, State Licensing Authorities and Port Officers have all been directed to strengthen enforcement.
Yes. Since surveillance extends to products already in the domestic market, retailers and online sellers should verify that the imported cosmetics they stock are supported by valid registrations.
Importing or Selling Cosmetics in India?
Need help checking Import Registration Certificates or filing Form COS-1 on the SUGAM Portal?
Official Reference: Central Drugs Standard Control Organization (CDSCO), Cosmetics Division. File No. COS-11018/3/2026-eOffice. Issued: July 2026.
Subject: Vigilance on imported cosmetics products sold in the domestic market without valid Import Registration Certificate.
Disclaimer: This article is for informational purposes only and should not be construed as legal or regulatory advice. Businesses should seek professional guidance based on their specific products and regulatory obligations.
