INTRODUCTION

If you plan to manufacture creams, serums, lipsticks, deodorants, soaps or fragrances in India, obtaining a CDSCO cosmetic manufacturing license is essential. Consumers demand safe products, online marketplaces require compliance and retailers will not list your brand without a valid license printed on labels. The license essentially acts as your passport to legitimacy and scale. Under the Cosmetics Rules, permissions are granted by the State Licensing Authority (SLA), while CDSCO oversees policy. Applications are made to the state drugs control department, followed by document review, facility inspection and issuance of COS-8 (manufacturing license).

If you plan to use another company’s approved premises, you can apply for a loan license, generally issued as COS-9. Both options are common—direct manufacturers opt for full control, while brand owners often use third-party plants to speed up operations. This guide simplifies eligibility norms, facility requirements, document checklists, inspection tips and post-license obligations, with practical insights from Lawfinity.

WHO NEEDS A COSMETIC MANUFACTURING LICENSE?

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You need a CDSCO cosmetic manufacturing license if you:

Formulate or blend cosmetics in India, even if in small batches.
Fill, pack or otherwise process a cosmetic where activities can affect safety/quality (for example, bulk import with local filling).
Wish to place your manufactured in India product on shelves or marketplaces with your brand name.

You don’t need a manufacturing license if you only import finished cosmetics (you would need import registration instead) or if you are purely a distributor/retailer. However, private-label brand owners who use a third-party facility still need a license—usually the loan-license route—because your brand’s product is being manufactured in India.

LICENSE ROUTES AND FORMS

COS-8: License to manufacture cosmetics for sale or distribution (granted after approval).
COS-5: Application for grant of license to manufacture cosmetics (what you file with SLA to get COS-8).
COS-6 / COS-9: Application and license for a loan license (manufacturing at an existing licensed unit owned by someone else).
COS-3 / COS-4: Approvals related to alterations or additional products (varies by state workflow; often handled as an endorsement to COS-8).
Test approvals for in-house labs may be sought separately if you plan to perform specified tests beyond routine QC.

Form names help you communicate crisply with inspectors and portals and they are often referenced in objection memos. Keep them handy.

WHAT THE AUTHORITIES EXPECT TO SEE

Premises & layout: A clean, well-lit, segregated facility with defined zones: raw-material store, primary processing room, filling/packing area, finished-goods quarantine and dispatch. Surfaces should be washable; floors without cracks; adequate ventilation or controlled air as appropriate for product type. Show separate hand-wash and sanitation points. For aerosols or solvent-heavy work (perfumes), provide flame-safe storage and exhaust.
Utilities & environment: Stable electricity, adequate lighting, pest-control contracts, calibrated weighing balances and water quality appropriate to the product (often RO/softened; for certain lines, demineralised or microbiological limits). Maintain cleaning logs and pest-control certificates.
Equipment & calibration: Mixers, homogenizers, filling machines, crimpers (for aerosols), filtration units and labellers should be maintained and identifiable. Keep a calibration schedule and records (balances, thermometers, pH meters, viscometers).
Quality control corner: A modest QC area with basic instrumentation: pH meter, viscometer (as applicable), microscope where needed, microbiological testing tie-up or in-house arrangement and retained-sample storage. Keep SOPs for incoming raw-material checks, in-process controls, finished-goods release and market complaint handling.
Technical personnel: A qualified technical in-charge (commonly with a science/pharma/cosmetic technology background) who understands GMP, batch documentation and labelling rules. Resume, qualification proof, appointment letter and specimen signature should be ready.
Documentation system: Master formula records (MFRs), batch manufacturing records (BMRs), batch packing records (BPRs), standard operating procedures (SOPs), sanitation schedules, vendor approvals and change-control forms. This is where many new applicants stumble—paperwork must reflect what you actually do.
Safety & compliance: Fire extinguishers, MSDS for hazardous raw materials, PPE availability and training records. For alcohol-based fragrances or sprays, add storage precautions and ventilation evidence.

Meet these basics and your cosmetic manufacturing license inspection becomes a confirmation, not an interrogation.

Document checklist (organise into one clean folder)

Constitution documents: Incorporation/Partnership/LLP papers, PAN, GST, factory/shop license as applicable.
Site documents: Rent/lease deed or ownership proof, latest property tax/utility bill, sanctioned layout.
NOC: Landlord NOC for manufacturing use (if rented).
Technical staff: Qualification, experience letters, appointment and photos.
Equipment list with capacity and serial numbers.
Water system schematic, last test report, sanitation & pest-control contracts.
Quality documents: SOP index, MFR templates, BMR/BPR templates, change-control and deviation formats.
Product list (initial SKUs) with category, pack size and broad composition ranges.
Label drafts meeting current cosmetic label rules.
Fee receipts and the filled COS-5 (or COS-6 for loan license) with declarations.

STEP-BY-STEP PROCESS TO OBTAIN COS-8

Step 1: Internal gap check

Walk through the above expectations. Fix visible issues: peeling paint, cluttered stores, missing PPE racks, uncalibrated balances. Draft your master SOP list and finalise the batch record templates.

Step 2: Register on the state portal

Most states run an online drugs control portal. Create an account, fill unit details and start the COS-5 application. Upload documents per the portal checklist and pay the fee online.

Step 3: Submit COS-5 with attachments

Fill constitution, premises, equipment and staff details. Attach the label drafts and your initial product list. Keep the product scope modest to start (a few SKUs in each category); you can add more via endorsement later without delaying the first approval.

Step 4: Scrutiny & inspection scheduling

The office assigns an inspector. You’ll receive a visit window; keep your technical in-charge present. Have originals of key documents ready and the facility operational enough to demonstrate process flow.

Step 5: Inspection day

Expect questions on SOPs, mixing parameters, cleaning cycles and how you segregate rejected goods. Inspectors often check calibration stickers, pest-control logbooks and whether your label drafts match rule requirements (batch no., Mfg. Lic. No., net quantity, Mfg. date, best-before, ingredients list by weight in descending order, name and address and caution notes where applicable).

Step 6: Deficiency closure

If you receive a deficiency memo, fix items swiftly—upload photos, revised SOP pages, calibration certificates or amended label drafts—with a short point-wise reply. Quick, factual closure impresses the office.

Step 7: Grant of license — COS-8

On compliance, the SLA grants the CDSCO cosmetic manufacturing license in COS-8. Download and archive the signed PDF and keep a printed copy near your QA board. Your license number will be used on every label as “Mfg. Lic. No. …”.

Step 8: Product endorsements & scale-up

After your first release, you can add new SKUs/categories as endorsements. Each change (new product line, extra room, replacement of technical in-charge) should be notified via the portal using the relevant amendment/endorsement form.

LABELS THAT PASS WITHOUT FUSS

Mandatory fields: Product name, manufacturer’s name and address, Mfg. Lic. No., batch number, manufacturing date, best-before or expiry (as the product demands), net quantity, directions for use and precautions where relevant.
Ingredients list: In descending order of weight at the time of manufacture (for packs above the small-pack exemption).
Claims sanity: Avoid drug-like or therapeutic claims (treats acne “disease”, cures dandruff “permanently”). Stay cosmetic.
Font & contrast: Readable size and contrast; batch and Mfg. Lic. No. should be legible, not hidden under folds.
Imported components: If you fill locally using imported bulk, ensure final labels reflect Indian manufacturer details and license number.

A clean label draft at the application stage prevents query loops later.

Timelines, validity and retention

Practical timeline: 4–12 weeks from first portal filing to COS-8, depending on your state’s workload, the completeness of your documents and how quickly you close deficiencies.
Validity: Licenses are valid perpetually subject to payment of retention fee at prescribed intervals (commonly every 5 years). Mark this in your compliance calendar.
Changes: Additions of products, layout changes or personnel updates require timely intimation and endorsement to keep your license clean.
Inspections: Post-grant inspections or surprise checks are normal. Keep logs updated.

COMMON MISTAKES (AND HOW TO AVOID THEM)

Over-ambitious product list on day one: Start lean. A huge first list invites label and dossier queries. Add more SKUs after you secure COS-8.
Paperwork that doesn’t match practice: Write SOPs you can actually follow. Inspectors quickly sense cut-paste manuals.
Weak water & sanitation evidence: Keep recent water test reports. Show cleaning schedules with signatures. Record pest visits and corrective actions.
Calibration gaps: Un-calibrated balances are the most frequent red flag. Set a monthly check routine and keep certificates handy.
Label non-compliance: Missing Mfg. Lic. No., tiny batch numbers or drug-like claims are instant objections. Fix labels early.
No defined QC role: Even in small units, define who releases the batch and on what basis. Keep minimal test records (pH/viscosity/appearance/odour).
Late replies to queries: Each day lost in replying stretches the file. Respond with a point-wise note and numbered attachments.
Ignoring endorsement housekeeping: New mixer? New room? New technical in-charge? File the endorsement. Silence creates trouble during surveillance.

HOW LAWFINITY SIMPLIFIES SUCH PROCEDURE?

At Lawfinity, we treat licensing like a mini-project with a clear finish line—COS-8 in your hands and a plant that can sail through audits. Here’s our playbook:

Pre-flight audit in 48 hours: We review your premises photos, layout, equipment list, water plan and documents against the state’s checklist. You get a gap report with prioritized fixes.
Document architecture: We build your licensing folder: index sheet, SOP set, MFR/BMR/BPR templates, calibration schedule, sanitation plan, product list matrix and label drafts that match rules. Everything is named cleanly and easy to upload.
Portal filing that sticks: We prepare and file COS-5 (or COS-6 for loan license), attach evidence in the right formats and track the file daily so small queries never become big delays.
Inspection coaching: A mock walk-through with your team so everyone knows where logs are kept, how to answer common questions and how to demonstrate a batch record.
Deficiency closure within days: If a memo lands, we draft a crisp, point-wise reply with photos, revised SOP pages and certificates and then upload the set with a professional cover letter.
Post-license handover: You receive a compliance calendar (retention fee dates, sanitation & calibration cycles), editable label templates with the license number and a one-pager explaining endorsement steps for new SKUs.

The outcome: a CDSCO cosmetic manufacturing license you can rely on and a plant that is inspection-ready not just once, but always.

MUSINGS FROM THE AUTHOR’S INK

In the world of cosmetics, creativity gets the spotlight, but compliance keeps the show running. I’ve seen tiny teams with one mixer and a handful of SKUs build trustworthy brands simply because they respected documentation and cleanliness from day one. A neat batch record and a sensible label don’t make headlines—but they unlock retail doors, marketplace approvals and repeat buyers who trust your consistency.

If I could give one piece of advice, it’s this: design for compliance the way you design for fragrance or texture. Choose claim language that won’t trip alarms, set up a simple QC corner that your team actually uses and create SOPs that match your reality—not a textbook. The reward is a smoother inspection, fewer objections and the quiet confidence of printing your license number on every pack.

And if the paperwork feels like a maze, hand us the compass. At Lawfinity, we’ll line up the forms, coach your team for inspection and stay on call through endorsements and retention. You keep crafting the formulas your customers love; we’ll make sure every jar and bottle carries a license that stands up to scrutiny.