Clarification of some aspects of CDSCO License for import of cosmetics

by Gaurav Bansal Company Registration Consultants in Delhi

When it comes to CDSCO license, and the process one has to go through to take it, there are several matters of confusion. “How does one prove that no tests were done on animals?” “How to get free sale certificate when the manufacturer is not available?”,“What to do if I am an Indian manufacturer but my factory is in another country?” - these are the types of questions that plague many hoping to get CDSCO license for import of cosmetics. And, the current guidelines don’t offer much clarification.

But that’s not entirely true. In the notification dated 15.10.2015, the CDSCO department did provide some clarifications. In this article, we are going to discuss them in a manner you can understand.

Clarification regarding undertaking that you’ve haven’t tested the product on animals

As for the undertaking regarding no animal testing, either the manufacturer, or the brand owner of the product, or it’s Indian subsidiary can submit it as a one-time declaration. The CDSCO would give you a new undertaking certifying that you in fact have not tested the products on animals. You can then use it as a way to prevent import from being halted at the ports.

Clarification about free sale certificate

The official CDSCO guidelines says that a free sale certificate from the manufacturer has to be presented. The clarification is only the responsible person, not the manufacturer is responsible for the job. As a responsible person, you can directly contact the National regulatory authority of the country you’re importing the cosmetic from and get the free sale certificate from them, without bothering the manufacturer.

Clarification regarding Letter of Authorization

In case you’re conducting third party manufacturing outside India, meaning that you’re an Indian brand owner but your manufacturing plant is outside India, you can opt for Letter of Authorization instead of power of attorney. That being said, the overseas manufacturer would also have to approve the letter of authorization.

Clarification regarding import of bulk cosmetics

If you’re importing cosmetics in bulk, you need to obtain Free sale certificate. However, you can either obtain it either from the country of origin OR you can obtain from any other major market where the product is sold freely. Or, bulk cosmetic importers can choose to get those bulk cosmetics tested in India and get custom clearance.

Clarification regarding documents required for CDSCO License renewal

If your CDSCO registration for import of cosmetics is expired, you can file the application for renewal of certification. The documents are as follows:

1. Original Power of attorney

2. The CDSCO License fee

3. Application form in FORM 42 and the list of products for which you’re renewing the CDSCO license.

4. Free sale certificate or Marketing Authorization Letter or Manufacturing License (one of three)

5. Original RC copy and endorsement certificates.

6. Undertaking stating that no changes have been made in the cosmetics.

Conclusion

With these clarifications, it’s now easy for to accumulate the documents required CDSCO License registration for cosmetics. For any further assistance, reach out to our experts at Registrationwala.