CDSCO Import Registration for Eyebrow & Brow Products in India: Standards, Documents and the Complete Process
Brow pencils, brow gels, tinted brow mascaras and brow pomades are the fastest-growing eye-makeup segment, and each must be registered with CDSCO under the Cosmetics Rules, 2020 before import. Registration is product-level and tied to the specific formulation, its shades and the factory.
The pencil format has its own Indian Standard, while gels and pomades are assessed against country-of-origin specs — and all of them inherit the eye-area colour rules.
Is CDSCO Registration Mandatory for Eyebrow & Brow Products?
Yes. Eyebrow and brow products are Fourth Schedule eye preparations and require CDSCO registration before import. The certificate covers the declared shades and formats.
The application is filed by the overseas manufacturer or, in practice, its Authorised Indian Agent.
Applicable Standard for Eyebrow & Brow Products
A brow pencil is a cosmetic pencil and is assessed against IS 9832 (cosmetic pencils); brow gels, pomades and tinted mascaras have no product-specific IS and are assessed against the country-of-origin standard plus the Cosmetics Rules, 2020. The CoA is drawn against the applicable standard or the manufacturer’s finished-product specification.
Because brows sit at the eye area, the colourants must be from the eye-area permitted list under IS 4707 (Part 1), mercury is limited to the 70 ppm preservative allowance, and an eye-irritation assessment strengthens the file — the same discipline as eyeliner and eyeshadow.
Pencils, Gels and the Eye-Area Rules
Brow products raise no drug question. The two things that decide the filing are the standard route — IS 9832 for a pencil versus country-of-origin for a gel or pomade — and the eye-area colour list, which is narrower than the general one. A brow product using a non-eye-area colour, or a tinted mascara without eye-irritation data, is the usual query.
Documents Required for Eyebrow & Brow Products CDSCO Registration
Every Form COS-1 application needs the core document set — covering letter; First Schedule authorisation; Second Schedule Part-I; ingredient list with percentages; inner and outer labels; specification and method of testing; finished-product Certificate of Analysis; country-of-origin manufacturing licence or marketing authorisation; original Free Sale Certificate; non-animal-testing declaration; heavy-metal and hexachlorophene declaration; GMP / ISO 22716 certificate; correlation chart; Bharatkosh receipt; and the signed Form COS-1. On top of this base, Eyebrow & Brow Products needs:
- Certificate of Analysis against IS 9832 for pencils, or the country-of-origin specification for gels and pomades.
- Colourant declaration restricted to the eye-area permitted list under IS 4707 (Part 1).
- Mercury declaration — permitted only as a preservative in eye-area products, up to 70 ppm.
- Ophthalmological safety / eye-irritation assessment.
- Shade-wise composition sheet — each shade is a separate variant at USD 50.
- Preservative-efficacy data for water-based brow gels and tinted mascaras.
Label Requirements Specific to Eyebrow & Brow Products
- Directions for safe use and an eye-area caution.
- Shade name; batch number and expiry on the inner label.
- Period-after-opening for water-based gels and tinted mascaras.
- Net content by weight or fluid measure.
Step-by-Step: CDSCO Import Registration Process
- Classify the product. Confirm it meets the definition of a cosmetic under Section 3(aaa) and map it to the eye preparations category under the Fourth Schedule — this drives the fee and the certificate scope.
- Appoint the Authorised Indian Agent. Execute the First Schedule authorisation, signed jointly by manufacturer and agent, then notarised and apostilled (Hague states) or embassy-attested.
- Assemble the technical dossier. Ingredient list with INCI names and percentages, the finished-product CoA against the applicable standard, inner and outer labels, GMP / ISO 22716 evidence and the Free Sale Certificate.
- Align the label to Chapter VI. Indian labelling is a top rejection reason; India-specific content may be stickered onto the unit pack at a bonded warehouse before clearance.
- Pay the fee on Bharatkosh. Compute category + site + variant fees, pay online under head 0210041040000-00-1 and retain the acknowledgement receipt.
- File Form COS-1 on SUGAM. Upload the full checklist, including the correlation chart that ties each product serial number in COS-1 to the Free Sale Certificate and the authorisation.
- Respond to CDSCO queries. Reply within the stipulated period — each query effectively restarts the clock, so a clean first filing is the biggest lever on timeline.
- Receive Form COS-2. Print the Registration Certificate number on every unit pack, with the holder’s name and address, before the goods are cleared for sale.
Fees and Timeline
Government fees are paid online via Bharatkosh under head 0210041040000-00-1: USD 1,000 for the eye preparations category, USD 500 per manufacturing site and USD 50 per variant (shade, fragrance or formulation). A duplicate certificate is USD 200, permission for a novel ingredient is USD 500, and inspection of an overseas manufacturing site, if ordered, is USD 5,000.
Typical approval time is four to six months from acceptance of a complete application, and each CDSCO query effectively restarts the clock. The Registration Certificate is valid for five years from the date of issue and must be re-registered before it lapses.
Common Mistakes That Trigger a CDSCO Query
- A brow pencil filed without a CoA against IS 9832.
- Colourants not on the eye-area permitted list under IS 4707 (Part 1).
- Missing eye-irritation data for a tinted brow gel or mascara.
- Shades under-declared for the USD 50 variant fee.
Related Approvals to Plan Alongside CDSCO
- DGFT Importer-Exporter Code — mandatory for any importer of record before the first consignment.
- LMPC registration (Legal Metrology) — eyebrow & brow products is a pre-packaged commodity requiring MRP, net quantity, importer details, country of origin and consumer-care details on the pack.
- Wholesale licence (Form 20B / 21B) — where the Indian agent also distributes drugs alongside cosmetics.
- Drug import licence (Form 10) — where a therapeutic claim or a pharmacologically active ingredient makes the product a drug rather than a cosmetic.
Frequently Asked Questions
Is CDSCO registration mandatory for imported eyebrow products?
Yes. Brow pencils, gels and pomades are Fourth Schedule eye preparations and cannot be imported until registered under Rule 12(1) of the Cosmetics Rules, 2020, with the certificate issued in Form COS-2.
Which Indian Standard applies to a brow pencil?
IS 9832 for cosmetic pencils. Brow gels, pomades and tinted mascaras have no product-specific IS and are assessed against the country-of-origin specification plus the Cosmetics Rules.
Do brow products face eye-area colour rules?
Yes. Because brows are at the eye area, colourants must be from the eye-area permitted list under IS 4707 (Part 1), and mercury is limited to the 70 ppm preservative allowance.
How are brow shades charged?
Each shade is a separate variant at USD 50 and must appear in the authorisation, the Free Sale Certificate and Form COS-1.
How long does registration take and how long is it valid?
Around four to six months for a complete application; the certificate is valid for five years and must be re-registered before expiry.
Do we need an Authorised Indian Agent?
In practice yes — the agent files on the First Schedule format and carries statutory liability for the product in India.
Why Choose PCN India Global
- Claims triage — we confirm upfront whether your eyebrow & brow products is cleanly cosmetic or at risk of drug reclassification.
- Category mapping — the correct Fourth Schedule category and test scope confirmed for your formulation.
- Dossier assembly — the full core document set prepared and cross-checked against the CDSCO checklist.
- Label compliance — a Chapter VI review to correct any non-compliant or therapeutic wording before you print packaging.
- End-to-end SUGAM filing — application, query response and the Form COS-2 grant managed for you.
- Adjacent approvals — LMPC, DGFT/IEC and, where relevant, PESO/AYUSH coordinated alongside your CDSCO registration.
PCN India Global manages the complete CDSCO import registration process for eyebrow & brow products — from claims triage and category mapping to dossier assembly, SUGAM filing and the Form COS-2 grant. WhatsApp or call +91 9289587478, or email admin@pcnindiaglobal.com, to get your import registration underway.
