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September 12, 2026October 12, 2026
CDSCO, Compliance Guides, Cosmetics Compliance, Import Compliance

CDSCO Import Registration for Face & Body Scrub in India: Standards, Documents and the Complete Process

Face scrubs, body scrubs, sugar and salt polishes and cream exfoliators clean by physical abrasion, 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 variants and the factory. This guide explains CDSCO registration for face & body scrub in India — standards, documents, labelling, fees and timeline.

These differ from a peeling gel or exfoliating toner, which work chemically with acids: a scrub works mechanically, so the abrasive particle &mdash. And whether it is a banned plastic microbead — is the heart of the filing.

Is CDSCO Registration Mandatory for Face & Body Scrub?

Yes. A face or body scrub is a Fourth Schedule skin-care preparation and needs CDSCO registration before the first consignment. The absence of an Indian Standard changes the evidence base to the country-of-origin standard plus the Cosmetics Rules, not the duty to register.

The application is filed by the overseas manufacturer or, in practice, its Authorised Indian Agent.

Applicable Standard for Face & Body Scrub

No Ninth Schedule Indian Standard applies to a scrub, so it is assessed against the country-of-origin standard plus the Cosmetics Rules, 2020, with the CoA drawn against the manufacturer’s finished-product specification — pH, appearance, preservative content and microbiological limits.

The defining declaration is the exfoliant particle: its identity (sugar, salt, apricot kernel, jojoba beads, silica) and confirmation that it is not a plastic microbead. Solid plastic microbeads in rinse-off cosmetics face an environmental ban in many markets and are a scrutiny point. Natural and biodegradable abrasives are the compliant route. Any AHA/BHA added alongside the scrub is declared with its concentration.

No Ninth Schedule Indian Standard applies: with no product-specific IS, CDSCO assesses the finished product against the standards and specifications of the country of origin plus all the requirements of the Cosmetics Rules, 2020, drawing the Certificate of Analysis against the manufacturer’s finished-product specification.

Microbeads and the Mechanical-vs-Chemical Line

A scrub is a cosmetic. The classification question rarely arises unless it carries a medicated anti-acne active. The real watch-point is the particle: solid plastic microbeads in a rinse-off scrub are an environmental red flag, so declare a natural or biodegradable abrasive. Where the scrub doubles as a chemical exfoliant with added acids, keep those acids at cosmetic level so it does not tip toward a professional peel.

Documents Required for CDSCO Registration of Face & Body Scrub

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, Face & Body Scrub needs:

Certificate of Analysis against the country-of-origin specification &mdash. PH, appearance, preservative content and microbiological limits.
Exfoliant-particle declaration: identity, particle size and confirmation it is a natural / biodegradable abrasive (not a solid plastic microbead).
Declaration of any AHA/BHA added alongside the physical exfoliant, with concentration.
Preservative-system declaration.
Country-of-origin standard and specification, since no Ninth Schedule Indian Standard applies.
Fragrance-allergen declaration where perfumed.

Label Requirements Specific to Face & Body Scrub

Directions for use, frequency and a caution to avoid broken or irritated skin.
Full ingredient list preceded by “INGREDIENTS”.
Net content by weight or fluid measure.
Any sun-sensitivity caution where an AHA/BHA is included.

Step-by-Step CDSCO Import Registration Process for Face & Body Scrub

Classify the product. Confirm it meets the definition of a cosmetic under Section 3(aaa) and map it to the skin care preparations category under the Fourth Schedule &mdash. 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 &mdash. 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.

CDSCO Registration Fees and Timeline for Face & Body Scrub

Government fees are paid online via Bharatkosh under head 0210041040000-00-1: USD 1,000 for the skin care 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

Plastic microbeads declared (or the particle left undeclared) in a rinse-off scrub.
An added AHA/BHA without its concentration.
A CoA with no country-of-origin specification behind it.
Variants 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) — face & body scrub 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) &mdash. Where the Indian agent also distributes drugs alongside cosmetics.
Drug import licence (Form 10) &mdash. Where a therapeutic claim or a pharmacologically active ingredient makes the product a drug rather than a cosmetic.

FAQs on CDSCO Registration for Face & Body Scrub

Is CDSCO registration mandatory for imported face and body scrubs?

Yes. They are Fourth Schedule skin-care preparations and cannot be imported until registered under Rule 12(1) of the Cosmetics Rules, 2020, with the certificate issued in Form COS-2.

Is there an Indian Standard for a scrub?

No. There is no product-specific Ninth Schedule standard, so the scrub is assessed against the country-of-origin specification plus the Cosmetics Rules.

What is the main issue with a scrub filing?

The exfoliant particle. Solid plastic microbeads in a rinse-off scrub are an environmental red flag. A natural or biodegradable abrasive (sugar, salt, jojoba, silica) is the compliant route and should be declared.

How is a scrub different from a peeling gel for registration?

A scrub exfoliates mechanically (the particle is declared). A peeling gel exfoliates chemically (the AHA/BHA and pH are declared). A product doing both declares both.

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 face & body scrub 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 face & body scrub — from claims triage and category mapping to dossier assembly, SUGAM filing and the Form COS-2 grant. WhatsApp or call +91 80109 05029, or email admin@pcnindiaglobal.com, to get your import registration underway.

Related Compliance Guides

Legal Metrology (LMPC) Registration
DGFT License Services (Importer-Exporter Code)
CDSCO Registration for Peeling Gel & Exfoliator

Related CDSCO Registration Guides

Need end-to-end help? See our CDSCO registration services, or read these related guides:

Official references: Central Drugs Standard Control Organisation (CDSCO) and the CDSCO SUGAM online portal.