UMSPCS-Compliance

What Is the CDSCO Approval Process for Chemical Exfoliation Products?

A chemical exfoliation product may seem like a skincare product, but once it hits the Indian market, its ingredients, claims, labelling, manufacturing source, and intended use, among other things, could land it under regulatory review.

With this in mind, businesses looking to manufacture or import chemical exfoliation products must understand the CDSCO Certification for Chemical Exfoliation Products before launch.

The CDSCO classifies chemical exfoliation products under skin products to skin care products in its guidelines for cosmetics import registration.

This blog will walk you through the CDSCO Certification Process for Chemical Exfoliation Products and highlight the legal requirements applicable to chemical exfoliation products in India.

Chemical Exfoliation Products: What Does CDSCO Consider?

In its guidelines for import registration of cosmetics, CDSCO classifies chemical exfoliation products under skin products to skin care products along with face masks, eye care products, lip care products, hand care products, foot care products, body care products, external intimate care products, and mechanical exfoliation products.

It should be noted that depending upon the indication, composition, presentation, and claims of the product, it may be categorized as either a cosmetic or a drug.

As per the Drugs and Cosmetics Act, 1940, a cosmetic means “An article intended to be applied to the human body for cleansing, beautifying, improving or altering appearance, or for keeping it in good condition, or an article intended for use as an ingredient or component of any such article as a cosmetic, or as defined by Section 3(aaa).

Therefore, it is relevant to understand the definition and category of your product so as to apply for CDSCO Certification for Cosmetics.

Legal Requirements for CDSCO Cosmetics Certification

The regulations governing the certification process are as mentioned below:

  • Drugs and Cosmetics Act, 1940
  • Cosmetics Rules, 2020
  • Applicable BIS standards referred to in the rules
  • CDSCO Guidelines on registration and import of cosmetics
  • Applicable label, safety, and quality requirements

The Cosmetics Rules, 2020 have been notified vide G.S.R. 763(E) dated 15th December 2020.

As per the CDSCO, for the import of cosmetics, the applicant needs to get their products registered before importing the products into India. The registration covers the cosmetic, its variants and pack sizes, and the manufacturing premises.

CDSCO Certification Mandate for Chemical Exfoliation Products

If the chemical exfoliation product qualifies as a cosmetic and is meant for import into India, then it must go through the CDSCO Certification for Cosmetics process.

As per Rule 12, no application for importing a cosmetic shall be made to the licensing authority in a state before the cosmetic has been registered with the Central Licensing Authority. The applicant must apply online using the Form COS-1 available on the CDSCO SUGAM portal.

For domestically manufactured cosmetics, the licensing authority in the state must be approached for a cosmetic manufacturing licence. In this case, the licence application must be made in Form COS-5, and a loan licence application must be made in Form COS-6.

This is an important consideration for businesses looking for CDSCO Certification in India since the regulatory pathway differs depending on the location of manufacturing.

CDSCO Certification Process for Chemical Exfoliation Products

An application for CDSCO Certification for Chemical Exfoliant Products commences with product assessment and regulatory eligibility determination long before an application is made on the SUGAM portal. Below are the key steps:

Step 1: Product Assessment & Regulatory Eligibility

The CDSCO Certification for Chemical Exfoliation Products process starts with a thorough product assessment to determine its eligibility for registration under the rules and the best regulatory pathway.

  • A detailed assessment of the candidate product and applicable regulations
  • Review of product formulation, claims, and intended use
  • Eligibility determination and identification of registration requirements

Step 2: Document Preparation & Compliance Review

Our experts can assist in compiling the documents required for regulatory submission and review.

  • Compilation and review of technical, product-related, and legal documents
  • Review of formulation, ingredients, and labelling
  • Verification against applicable CDSCO requirements
  • Identification and resolution of documentation gaps

Step 3: CDSCO Application Filing

After completing Step 2 successfully, the next step is to prepare and file the application with the CDSCO SUGAM Portal along with the applicable government fees.

  • Preparation of the application and supporting dossier
  • Uploading the required documents on the SUGAM Portal
  • Submission to the concerned authority
  • Clearance of applicable government fees

Step 4: CDSCO Review & Regulatory Coordination

Upon submission, the application and supporting documents are reviewed by the CDSCO. Where necessary, we handle the coordination and response to queries raised by the regulators.

  • Coordination with the concerned regulatory authorities
  • Review and response to CDSCO queries
  • Submission of additional information, if applicable
  • Follow-up during the regulatory review process

Step 5: Registration Certificate Issuance

After successful review, the CDSCO Certification for Chemical Exfoliation Products process moves to certificate issuance.

  • Assistance with obtaining the CDSCO registration certificate
  • Support with import and regulatory compliance, if applicable
  • Guidance with meeting other applicable regulatory requirements

Step 6: Post-Registration Compliance & Regulatory Support

At UMSPCS, we offer end-to-end support with regulatory compliance, even after certificate issuance. Our experts can support businesses with post-registration requirements to help them scale their cosmetic product portfolio in India.

  • Guidance with retention fee and other post-registration requirements, if applicable
  • Assistance with additional product registration
  • Support with amendments, if applicable
  • Continued regulatory support

Documents Required for CDSCO Certification for Chemical Exfoliation Products

Depending on the applicant and product, some of the key documents include:

  • Covering letter
  • Form COS 1
  • Authorization letter
  • Free sale certificate
  • Ingredients list
  • Specification
  • Labelling
  • Pack insert, where applicable
  • Product sample
  • Certificate of manufacturing
  • Product details
  • Declaration
  • Undertaking by the Indian agent
  • Company profile

CDSCO publishes guidelines on authorisation, composition, label, and manufacturing licences, Free Sale Certificate, animal testing, and test reports applicable to the product.

How Long Does CDSCO Certification Take?

It is important to understand that there is a difference between practical completion time and regulatory timelines.

StageEstimated Timeline
Product Assessment2 – 5 Working Days
Documentation Preparation1 – 2 Weeks
Application Submission2 – 5 Working Days
Regulatory ReviewDepends on the authority’s review process and any queries raised
Final ApprovalSubject to successful regulatory evaluation

It is noted that for Indian manufacturing, the State Licensing Authority shall issue or refuse the manufacturing licence within 45 days of the application, subject to inspection and verification as per the Rules.

Benefits of CDSCO Certification for Chemical Exfoliation Products

With a compliant regulatory pathway, businesses can:

  • Import eligible cosmetics with confidence
  • Demonstrate regulatory compliance
  • Gain the trust of distributors and other business partners
  • Ensure a systematic product dossier
  • Achieve smoother customs clearance
  • Avoid avoidable regulatory objections
  • Lay the groundwork for a wider range of cosmetic products in India

Notably, CDSCO has been very proactive in recent times with the enforcement of regulations governing imported cosmetics. In July 2026, CDSCO issued a circular regarding vigilance over imported cosmetics being sold in India without a valid Import Registration Certificate.

How UMSPCS Can Assist With CDSCO Certification for Cosmetics

Navigating the maze of cosmetic registration can be a daunting task, especially where formulation, foreign manufacturing documents, and labelling must be combined with other regulatory requirements. 

With our expertise in handling 600+ product compliance requirements and 6+ years of experience, we enable businesses to get the most out of their regulatory strategy.

UMSPCS can assist businesses with the CDSCO Certification Consultant process, ranging from eligibility determination to post-certificate issuance compliance support.

Some of the ways we can support include:

  • Assessment of regulatory applicability
  • Product categorisation
  • Review of ingredients and formulations
  • Preparation of dossiers
  • Manufacturer authorisation
  • Free Sale Certificate documentation
  • Review of labelling and claims
  • SUGAM application
  • Document coordination
  • Query support
  • Post-registration support

Conclusion

The CDSCO Certification for Chemical Exfoliation Products is not merely a case of clicking on an online application. This includes gaining an understanding of the product category and going through the composition, labelling, manufacturer information, quality control, safety parameters, and other relevant aspects of the product.

Additionally, it is also necessary to determine whether the product requires licensing or registration from the CDSCO or the State Licensing Authorities in India.

Therefore, any company that wishes to import the chemical exfoliator product into India or manufacture it within the country must get informed about the regulations beforehand and make the right choices.

Do you need help with CDSCO Certification for Chemical Exfoliation Products?

Connect with UMSPCS and let our experts assist you with all your regulatory and documentation-related queries.

Read more also: Why ISO 13485 Certification for Medical Device Manufacturers?

FAQs

  1. Is CDSCO certification required for chemical exfoliation products?

For imported goods, the Central Licensing Authorities require that the applicant must first register the imported product before granting the import license under the Cosmetics Rules, 2020, which is applicable to any product that falls under the definition of cosmetics under the Drugs and Cosmetics Act, 1940.

  1. What is the application form for CDSCO certification of imported cosmetics?

The application for import registration is required to be submitted in Form COS-1, with the registration certificate issued in Form COS-2.

  1. Can a foreign manufacturer apply for CDSCO certification?

Yes, as per the rules, an overseas manufacturer may make the application directly or through an authorised agent, importer in India, or an authorised Indian subsidiary.

  1. How long does CDSCO cosmetic registration take?

The Central Licensing Authority can approve or reject an application for import registration of cosmetics within 6 months of receipt of the application by them, as per Rule 13, and also based on the information and queries about the application.

  1. How long is a CDSCO Import Registration Certificate valid?

A certificate of registration issued under Rule 13 is valid for an indefinite period, subject to payment of the retention fee as specified under the Rules.

  1. Do I need a Free Sale Certificate for imported cosmetics in India?

A Free Sale Certificate is among the documents highlighted in CDSCO guidelines for import registration of cosmetics, subject to applicable requirements and acceptable authentication.

  1. Does a chemical exfoliation product require compliant labelling before registration?

Product labelling is integral to the application for registration and consequently must adhere to the requirements prescribed under the Cosmetics Rules, 2020.

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