CDSCO Import Registration for Kajal, Kohl, Eyeliner and Mascara in India: IS 15154, IS 9832 and the Complete Process

Eye preparations sit closer to the body’s most sensitive tissue than almost any other cosmetic category, and CDSCO’s scrutiny reflects it. Traditional kohl formulations in particular carry a known lead-contamination risk, and the colourants permitted for general cosmetic use are not automatically permitted around the eye — several coal-tar colours accepted elsewhere on the face are specifically excluded here.

This guide covers CDSCO import registration for kajal, kohl, eyeliner and mascara under the Cosmetics Rules, 2020 — the applicable standards, eye-area colourant restrictions, lead and mercury limits, documents, labelling, the registration process, fees, timeline and the two issues that dominate query letters in this category.

How Kajal, Kohl, Eyeliner and Mascara Is Regulated Under CDSCO

No cosmetic — kajal, kohl, eyeliner and mascara included — may be imported into India unless it is registered by the Central Licensing Authority under Rule 12(1) of the Cosmetics Rules, 2020. Registration is tied to the specific brand, formulation, pack sizes and manufacturing premises, not granted at company level.

Every cosmetic imported into India is registered against the Fourth Schedule category it falls under, using Form COS-1 filed on the CDSCO SUGAM portal. Approval is issued as an Import Registration Certificate in Form COS-2, valid for five years. This product group falls under the Eye preparations category of the Fourth Schedule.

Applicable Indian Standards for Eye Preparations

Indian StandardProduct
IS 15154Kajal
IS 9832Cosmetic pencils

Eyeliner and mascara formulations are assessed against the closest applicable standard for their format, with additional eye-area-specific safety data layered on top regardless of the base standard used.

Documents Required for Eye Preparation CDSCO Registration

Every Form COS-1 application needs the core document set described above. On top of this base, kajal, kohl, eyeliner and mascara need:

  • CoA against IS 15154 for kajal — pH, heavy metals, freedom from grittiness, microbiological limits.
  • Colourant declaration restricted to colours permitted for use in the eye area under IS 4707 (Part 1). Several coal-tar colours permitted elsewhere are not permitted around the eye.
  • Mercury declaration — mercury is permitted only as a preservative in eye-area products, and only up to 70 ppm (0.007%).
  • Lead test report — traditional kohl formulations are a known lead risk and this report is scrutinised closely.
  • Ophthalmological safety / eye irritation assessment.
  • Sterility and preservative efficacy data for mascara and liquid liners.

Label Requirements Specific to Eye Preparations

  • Directions for safe use and warnings on eye contact.
  • Recommended period-after-opening for mascara and liquid formats.
  • Batch number and expiry — mandatory on the inner label.

Step-by-Step: CDSCO Import Registration Process

  1. Classify the product. Confirm it meets the definition of “cosmetic” and map it to the Eye preparations category of the Fourth Schedule.
  2. Appoint the Indian Agent. Execute the Authorisation, notarised and apostilled or embassy-attested.
  3. Assemble the technical dossier. Ingredient list with INCI names and percentages, the CoA against IS 15154 or the applicable standard, lead and mercury test reports, eye-area colourant declarations, ophthalmological safety data, labels for every variant and the Free Sale Certificate.
  4. Align the label to Chapter VI. Eye-contact warnings and period-after-opening guidance must appear correctly.
  5. Pay the fee on Bharatkosh. Compute category + site + variant fees and retain the challan.
  6. File Form COS-1 on SUGAM. Upload the full checklist including the correlation chart.
  7. Respond to CDSCO queries. For this category, queries most often concern detectable lead in traditional kohl formulations and colourants used that are not on the eye-area permitted list.
  8. Receive Form COS-2. Print the RC number on every unit pack before goods are cleared for sale.

Fees and Timeline

Government fees are paid online via Bharatkosh: USD 1,000 for the eye preparations category, USD 500 per manufacturing site, and USD 50 for each shade of kajal, eyeliner or mascara formulation.

Typical approval time is 4 to 6 months from acceptance of a complete application; missing eye-irritation or lead data is a common cause of added delay in this category. The Registration Certificate is valid for five years.

Common Mistakes That Trigger a CDSCO Query

  • Detectable lead in traditional kohl — kohl formulations are a known lead-contamination risk, and lead test reports for this category are scrutinised more closely than for almost any other cosmetic.
  • Colourants not on the eye-area permitted list — several coal-tar colours permitted for general cosmetic use elsewhere on the face are specifically excluded from eye-area products under IS 4707 (Part 1); missing eye-irritation data compounds the issue.
  • Free Sale Certificate scope mismatch across documents.
  • Missing sterility data for mascara and liquid liner formats.

Related Approvals to Plan Alongside CDSCO

  • LMPC registration — kajal, eyeliner and mascara are pre-packaged commodities requiring MRP and importer declarations on the pack.
  • DGFT Importer-Exporter Code — mandatory for any importer of record before the first consignment.
  • EPR registration for plastic waste — kajal sticks, eyeliner pens and mascara tubes fall under CPCB’s EPR framework.

Frequently Asked Questions

Is CDSCO registration mandatory for imported kajal and eyeliner?

Yes. Under Rule 12(1) of the Cosmetics Rules, 2020, no eye preparation — kajal, kohl, eyeliner or mascara — can be imported into India unless it is registered with CDSCO and holds a valid Import Registration Certificate (Form COS-2).

Which Indian Standard applies to kajal?

IS 15154 covers kajal, testing pH, heavy metals, grittiness and microbiological limits. IS 9832 covers cosmetic pencils, and eyeliner/mascara are assessed against the closest applicable standard for their format.

Why is lead testing so strict for kajal and kohl?

Traditional kohl formulations carry a documented lead-contamination risk, so CDSCO scrutinises lead test reports for this category more closely than for most other cosmetics.

Can any colour be used in an eyeliner or mascara?

No. Colourants for eye-area products must be on the specific eye-area permitted list under IS 4707 (Part 1) — several coal-tar colours allowed elsewhere on the face are excluded here.

Is mercury allowed in eye-area cosmetics?

Only as a preservative and only up to 70 ppm (0.007%) — this is a narrower allowance than for other cosmetic categories.

How long does CDSCO registration take for eye preparations?

Typically 4 to 6 months from acceptance of a complete application; missing eye-irritation or lead data is a common cause of added delay in this category.

Why Choose PCN India Global

  • Category mapping — we confirm the correct Fourth Schedule category and standard for kajal, cosmetic pencils, eyeliner and mascara.
  • Colourant compliance — eye-area-specific colourant checks against IS 4707 (Part 1) before filing.
  • Lead and mercury testing coordination — sourced from BIS-recognised laboratories.
  • Dossier assembly — the full core document set plus ophthalmological safety data prepared and cross-checked.
  • End-to-end SUGAM filing — application, query response and Form COS-2 grant managed for you.
  • Adjacent approvals — LMPC, DGFT/IEC and EPR coordinated alongside your CDSCO registration.

PCN India Global manages the complete CDSCO import registration process for kajal, kohl, eyeliner and mascara — from eye-area colourant compliance to Form COS-2 grant and five-year renewal tracking. Contact us: WhatsApp +91 80109 05029, email bdm@pcnindiaglobal.com, or start your application today.

Related Compliance Guides

  • Legal Metrology (LMPC) Registration
  • DGFT License Services (Importer-Exporter Code)
  • EPR Registration for Plastic Waste

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