CDSCO Tightens Vigilance on Imported Cosmetics Sold Without Valid Import Registration (COS-2) — July 2026 Circular

On 23 July 2026, CDSCO issued a circular directing its zonal and sub-zonal offices, and State/UT drug controllers, to intensify vigilance on imported cosmetics being sold in the domestic market without a valid Import Registration Certificate. In plain terms: imported cosmetics on Indian shelves and marketplaces that are not backed by a valid COS-2 registration are now squarely in the enforcement spotlight.

For importers, distributors and online sellers of international beauty and personal-care brands, this is a signal to audit compliance now — before a market inspection does it for you.

What the circular actually says

The circular reiterates that under the Cosmetics Rules, 2020, no cosmetic may be imported into India without a registration certificate. It instructs field formations to carry out market surveillance, identify imported cosmetics being sold without valid registration, and take appropriate regulatory action against such products. It is an enforcement and vigilance instruction — the underlying legal requirement is not new, but the intent to actively police it in the market is.

The legal basis: COS-1 and COS-2

Import of cosmetics into India is registration-based:

• Form COS-1 — the application for registration of an imported cosmetic, filed by the importer or the manufacturer's Authorised Indian Agent on the CDSCO portal.
• Form COS-2 — the Import Registration Certificate granted by CDSCO. It lists the specific brands, categories, variants and shades permitted for import.

If a product, variant or shade on sale is not covered by the COS-2 certificate, it is treated as an unregistered import — regardless of whether the brand holds a certificate for other products.

Who is affected

• Importers bringing in international cosmetic brands.
• Distributors and wholesalers supplying imported cosmetics to retail.
• Retailers and beauty chains stocking imported products.
• E-commerce and marketplace sellers — online listings of imported cosmetics are visible and easily checked against the registration database.

What you must do now

1. Inventory every imported SKU currently on sale, including each variant and shade.
2. Reconcile that list against your valid COS-2 certificate(s) — check brand, category, variant and shade coverage, and the validity date.
3. Register the gaps — file COS-1 applications for any un-registered products or variants.
4. Quarantine non-compliant stock and pull unregistered listings from shelves and online platforms until registration is granted.
5. Keep documentation ready — registration certificates, invoices and import records — for inspection.

How to check if an imported cosmetic is registered

Registration is product-specific, so a brand-level assumption is not enough. To confirm a product is compliant, check that: (1) a valid COS-2 certificate exists for that manufacturer and brand; (2) the specific category, variant and shade on sale is listed on the certificate; (3) the certificate is within validity; and (4) the Authorised Indian Agent named on the certificate matches your import channel. A single un-listed shade in a range can make that SKU non-compliant even when the rest of the range is registered.

E-commerce and marketplace sellers: specific exposure

Online listings are the easiest target for market surveillance because they are public and searchable. Marketplace sellers of imported cosmetics should treat their live catalogue as an enforcement surface: de-list any SKU you cannot tie to a valid COS-2, keep certificate references ready for platform compliance teams, and avoid drop-shipping imported cosmetics that were never registered for the Indian market. Platforms themselves are increasingly asking sellers to evidence registration before allowing imported cosmetics to stay listed.

Why it matters

Selling an imported cosmetic without a valid registration certificate can lead to seizure of stock and prosecution under the Drugs and Cosmetics Act, 1940 and the Cosmetics Rules, 2020. With CDSCO now directing coordinated market vigilance, the practical risk of enforcement — including at the e-commerce level — has risen sharply. Acting now, while it is a compliance exercise rather than a seizure notice, is far cheaper than reacting later.

How MedRegX helps

MedRegX manages CDSCO cosmetic import registration end-to-end — COS-1 filing to COS-2 grant — and runs compliance audits to confirm that every product you sell is properly covered. If you are unsure whether your current registration matches your live catalogue, we can reconcile it quickly and close any gaps. Explore our cosmetic import registration and cosmetic registration services.

Frequently asked questions

What did the CDSCO circular of 23 July 2026 say?

CDSCO directed its zonal offices and State/UT drug controllers to step up vigilance against imported cosmetics being sold in the domestic market without a valid Import Registration Certificate, and to take action against such non-compliant products under the Cosmetics Rules, 2020.

What is the Import Registration Certificate for cosmetics?

Under the Cosmetics Rules, 2020, no cosmetic can be imported into India without a registration certificate (Form COS-2), granted by CDSCO on an application made in Form COS-1 by the importer or the manufacturer's Authorised Indian Agent.

Who is affected by this enforcement drive?

Importers, distributors, retailers and e-commerce/marketplace sellers of imported cosmetics. Selling an imported cosmetic that is not covered by a valid COS-2 registration certificate now carries a real risk of seizure and prosecution.

What should importers and sellers do now?

Verify that every imported cosmetic SKU on sale is covered by a valid COS-2 registration, reconcile brand/variant/shade lists against the certificate, register any un-registered products, and remove non-compliant stock from shelves and online listings until it is registered.

Source: CDSCO circular dated 23 July 2026, "Vigilance on imported cosmetics products sold in the domestic market without valid Import Registration certificate" — published on the CDSCO Latest Circulars page, cdsco.gov.in.