Who This Is For

This checklist is for brand owners launching cosmetics in India, including herbal and Ayurvedic-positioned personal care products such as gels, creams, oils, face washes and shampoos, and for direct selling companies adding personal care to a range.

It is a planning framework rather than legal advice. Cosmetics rules and their interpretation are updated over time, and requirements vary with pack size and product type, so confirm current specifics with a qualified professional before launch.

Stage One: Licensing and Manufacturing

Get this settled before anything else, because everything downstream depends on it.

1. Confirm your product is appropriately classified as a cosmetic, given its intended use and the claims you plan to make.
2. Confirm the manufacturing facility holds a valid cosmetic manufacturing licence issued by the State Licensing Authority.
3. Obtain a copy of that licence and verify it covers your product category.
4. If importing rather than manufacturing domestically, confirm the separate registration pathway that applies.
5. If manufacturing for export, confirm destination requirements separately, as they are independent of your Indian licence.
6. Agree per-batch documentation with the manufacturer before the first order.

Stage Two: Product Safety and Testing

Cosmetics are applied to skin, which makes safety documentation a commercial asset as well as a compliance obligation.

Stability data must be in your pack, not a generic figure. A formulation stable in a laboratory jar can separate or discolour in your tube during an Indian summer.

Stage Three: Labelling

Requirements vary with pack size and are updated over time, so treat this as a verification list to confirm rather than a final specification.

1. Product name and clear indication of what the product is.
2. Name and full address of the manufacturer.
3. Manufacturing licence number.
4. Net quantity in the required units and placement.
5. Batch number, on the primary pack and not only the carton.
6. Manufacturing date and use-by or best-before as applicable.
7. Ingredient list as required for your pack size.
8. Directions for use and any required cautionary statements, including external use statements where applicable.
9. MRP and consumer care contact details.
10. Written sign-off from the manufacturer that every declaration is correct before printing.

Stage Four: Claims

This is where most cosmetic brands create avoidable risk, usually through ambition rather than ignorance.

A cosmetic may make claims about cleansing, beautifying and altering or improving appearance: moisturisation, softness, smoothness, shine, soothing or cooling sensation, and similar sensory and appearance outcomes. It may not claim to treat, cure, prevent or mitigate a condition. Healing, anti-bacterial function, curing acne or eczema, and preventing hair fall are therapeutic claims outside cosmetic scope.

Absolute and unverifiable claims create a second category of risk: chemical free, one hundred percent natural, no side effects and dermatologically proven are all difficult or impossible to substantiate and increasingly challenged. Replace them with accurate statements about your actual formulation.

Apply the same rules to imagery. Before-and-after visuals implying a condition improved are therapeutic claims made pictorially.

Stage Five: Channels and Sellers

Compliance extends to everyone who speaks about your product.

1. Write an approved and prohibited phrase list specific to your products.
2. Translate it into the languages your sellers actually use.
3. Build an approved marketing material library and require sellers to use it.
4. Define a testimonial policy excluding condition-improvement stories.
5. Assemble marketplace documentation: licence copy, invoices, test reports.
6. Audit your live listings for claims you did not approve.
7. Set a monitoring routine with a named owner and defined consequences.

Pre-Launch Checklist Summary

Every line should have a written answer before you print or list.

1. Classification confirmed as cosmetic for your intended use and claims.
2. Manufacturer cosmetic licence copy on file and scope verified.
3. Per-batch testing panel agreed in writing.
4. Preservative efficacy position confirmed.
5. Stability data obtained in your actual pack.
6. Pack and liner compatibility confirmed.
7. All mandatory label declarations verified and signed off.
8. Batch and date coding specified for the primary pack.
9. Claim set written, with approved and prohibited phrases listed.
10. Imagery reviewed against the claim set.
11. Seller guidance issued and marketing material library built.
12. Current requirements confirmed with a qualified professional.

Frequently Asked Questions