Cosmetics × India
Private label cosmetics in India: third-party manufacturing
India lets a brand make cosmetics without building a factory: a loan licence allows production on another licensee’s site. The licence, the label and the Indian Standards still have to be right.
Private label cosmetics in India: third-party manufacturing or import
To launch private label cosmetics in India, you either manufacture locally through a licensed third-party manufacturer or import finished products registered with CDSCO. Under the Cosmetics Rules 2020, manufacture is licensed by the State Licensing Authority: you apply online in Form COS-5 for a licence or Form COS-6 for a loan licence, which lets you use the manufacturing site of another licensee, and the licence is granted in Form COS-8 or COS-9. The rules set 45 days for the decision, and the authority inspects the site within 30 days of grant. Import instead needs registration by the Central Licensing Authority, covering pack size, variants and manufacturing premises, before any consignment arrives.
The label is detailed. Rule 34 requires the product name, the name and full address of the actual manufacturing premises, a use-before or expiry date, a batch number, the manufacturing licence number, net contents on the outer label, and an ingredient list headed ‘INGREDIENTS’, with those above one per cent in descending order. Imported products also carry the import registration number and the importer’s name and address. Products covered by the Ninth Schedule must meet the relevant Bureau of Indian Standards specification, and no cosmetic may make false or misleading claims. Imports of cosmetics tested on animals after 12 November 2014 are prohibited.
An Ayurvedic positioning raises a separate question. The Drugs and Cosmetics Act and its rules have exclusive provisions for Ayurvedic, Siddha and Unani drugs, with GMP under Schedule T and proof of safety and effectiveness, so a product presented as an Ayurvedic medicine follows that licensing route rather than the cosmetic one. Our India market guide covers packaging declarations, EPR and channels, and private label cosmetics explains formula routes. The content is general information, and an Indian regulatory adviser confirms each licence and label point in a project.
Two routes to a private label cosmetic in India
Local third-party manufacturing compared with importing a finished product.
| Requirement | What it means | Who is responsible | Timing or cost driver |
|---|---|---|---|
| Manufacturing licence | COS-5 application, COS-8 licence for the site | The manufacturer holding the site | Decision within 45 days of application |
| Loan licence | COS-6 application, COS-9 licence to manufacture on another licensee’s site | Brand owner as loan licensee | Falls if the host site’s licence is cancelled or suspended |
| GMP and premises | Self-declaration in Form COS-7 against the Seventh Schedule; inspection within 30 days of grant | Licensee | Site upgrades if inspection finds gaps |
| Import registration | Registration with pack sizes, variants and premises before import, in Form COS-2; decision within six months | Foreign manufacturer, its Indian agent, importer or subsidiary | Product testing where the Fifth Schedule requires it |
| Label | Rule 34 content; RC number and importer for imports; BIS labelling where a standard applies | Licensee or importer | Indian artwork, not a sticker over foreign text |
| Animal testing and claims | No import of cosmetics tested on animals after 12 November 2014; no false or misleading claims | Brand owner and importer | Supplier declarations and claims evidence |
Legal Metrology declarations, including maximum retail price, and plastic packaging EPR sit on top of these rules.
Before the first Indian batch is sold
Licences decide your earliest date, so start here.
- Route chosen: manufacturer’s own licence, your loan licence, or import registration
- Product classified as cosmetic or as an Ayurvedic, Siddha or Unani drug
- Formula checked against the relevant BIS standard under the Ninth Schedule
- Licence or loan licence granted, or import registration certificate issued
- Label with rule 34 content, licence or RC number, and Legal Metrology declarations
- Contract terms on formula ownership and artwork rights
- Indian trademark filing, as covered under trademark registration in India
Launch sequence for a cosmetics brand made in India
Statutory periods are shown where the rules set them.
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1
Classify the product
Decide whether each product is a cosmetic or an Ayurvedic drug, since the licensing route follows that answer.
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2
Choose the manufacturer
We assess selected third-party manufacturers on their licence, site condition, testing capacity and willingness to host a loan licence. See our <a href="/services/private-label-manufacturing/">manufacturing stage</a>.
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3
Develop and test
Fix the formula against the BIS standard and test stability.
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4
Licence
Apply for the loan licence or confirm the manufacturer’s licence covers the product category.
Decision within 45 days; inspection within 30 days of grant -
5
Label and price
Finalise rule 34 content and Legal Metrology declarations, including maximum retail price.
Frequently asked questions
What is a loan licence for cosmetics in India?
A licence from the State Licensing Authority that allows a person to manufacture a cosmetic on the site of another licensee. You apply in Form COS-6 and receive it in Form COS-9. It is deemed cancelled or suspended if the host site’s own licence is.
How long does a cosmetics manufacturing licence take in India?
The Cosmetics Rules 2020 require the State Licensing Authority to grant or refuse a licence or loan licence within 45 days of application, and to inspect the site within 30 days of grant.
Do imported cosmetics need registration in India?
Yes. Every imported cosmetic must be registered by the Central Licensing Authority with its pack sizes, variants and manufacturing premises before import. The rules allow up to six months for the decision, and the registration number goes on the label.
Is an Ayurvedic skincare product a cosmetic?
It depends on its composition and claims. Ayurvedic, Siddha and Unani drugs have their own licensing provisions, GMP under Schedule T and proof of safety and effectiveness. A product presented as an Ayurvedic medicine is not licensed as a cosmetic.
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