Published: 30 Jul 2026
CDSCO Directs Enhanced Vigilance Against Unregistered Imported Cosmetics: What Importers, Brands & Distributors Need to Know
REGULATORY INTELLIGENCE
Published: 29 July 2026
Circular: File No. COS-11018/3/2026-eOffice
Effective: Immediate
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.
While the circular does not introduce a new regulatory requirement, 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 either 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 indication that compliance with India’s cosmetic import regulations is now under closer scrutiny.
Key Takeaways
- CDSCO has directed nationwide enhanced surveillance on imported cosmetics.
- 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.
- 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 product may be imported into India unless it has been registered by the Central Licensing Authority or an officer delegated under Rule 5(1).
- Import registration is obtained by submitting an application in Form COS-1 through CDSCO’s SUGAM Portal.
- This registration is mandatory before imported cosmetic products can legally enter the Indian market.
Why Did CDSCO Issue This Circular?
According to the 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 establishes a two-tier enforcement approach, covering both border controls and domestic market surveillance.
1. Enhanced Market Surveillance
All State Licensing Authorities (SLAs) and CDSCO Zonal and Sub-Zonal Offices have been instructed to direct their inspectorates to intensify surveillance of imported cosmetic products available in the domestic market.
Inspectors will focus on verifying whether products being sold possess a valid Import Registration Certificate.
2. Strengthened Port-Level Checks
CDSCO has also directed Port Officers to maintain strict vigilance to prevent imported cosmetics without valid registration from entering India.
This strengthens regulatory enforcement at the point of import and is expected to result in increased scrutiny of cosmetic consignments arriving at Indian ports.
Who Should Be Concerned?
This circular is relevant for 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 directly import cosmetics should ensure that the products they distribute or sell have valid registration.
Why This Matters for Businesses
Although the legal requirement has existed since the Cosmetics Rules, 2020 came into force, this circular demonstrates that CDSCO is placing greater emphasis on enforcement.
Businesses should review whether:
- Every imported cosmetic SKU has a valid Import Registration Certificate.
- Registration certificates remain current and have 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:
- 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 disruptions resulting from non-compliant inventory.
Companies importing multiple brands or large product portfolios should proactively review their registration status to minimize compliance risks.
Recommended Actions
To prepare for increased enforcement, businesses should:
- Verify that every imported cosmetic product has a valid Import Registration Certificate.
- Confirm that registrations remain active and cover all marketed variants.
- Review documentation maintained for customs clearance.
- Audit distributor and importer compliance records.
- Train regulatory and logistics teams on current CDSCO requirements.
- Address any compliance gaps before future 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 requires careful attention to registration, documentation, and ongoing regulatory 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 experienced 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 indication that enforcement of the existing Cosmetics Rules, 2020 is being intensified.
With enhanced surveillance at both ports and within the domestic market, businesses involved in importing, distributing, or selling cosmetic products 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 disruptions to business operations tomorrow.
Frequently Asked Questions
Is this a new regulation?
No. The circular reinforces the existing registration requirement under Rule 12(1) of the Cosmetics Rules, 2020.
Are all imported cosmetics required to be registered?
Yes. Imported cosmetic products must have a valid Import Registration Certificate before they can be legally imported into India.
What is Form COS-1?
Form COS-1 is the application form used to obtain an Import Registration Certificate through CDSCO’s SUGAM Portal.
Who will conduct inspections?
CDSCO’s Zonal and Sub-Zonal Offices, State Licensing Authorities, and Port Officers have all been directed to strengthen enforcement activities.
Does this affect retailers and e-commerce sellers?
Yes. Since surveillance extends to products already available in the domestic market, retailers and online sellers should verify that imported cosmetic products they stock are supported by valid registrations.
Official Reference
Central Drugs Standard Control Organization (CDSCO), Cosmetics Division
File No. COS-11018/3/2026-eOffice
Subject: Vigilance on imported cosmetics products sold in the domestic market without valid Import Registration Certificate
Issued: July 2026
Disclaimer: This article is intended 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.