Most first-time skincare founders spend weeks on the formula and packaging, then discover the paperwork only when a marketplace rejects their listing. The good news: the licence stack for a small skincare brand in India is predictable. Here is what you need, in the order that avoids rework.
1. A business entity, PAN and GST
You can start as a sole proprietor, but most founders who plan to raise money or sell on marketplaces pick a Private Limited Company or LLP. Once registered, get your PAN, a current account and GST registration. Marketplaces and payment gateways ask for GST before they onboard you, so do this first.
2. Trademark search and filing, before you print anything
Do a proper search in Class 3 (cosmetics and non-medicated toiletries) and file your application before you design packaging. Changing a name after 5,000 printed cartons is the most expensive mistake we see. Filing gives you a date of priority and lets you use the ™ symbol; the ® comes only after registration.
3. The cosmetics manufacturing licence (Cosmetics Rules, 2020)
In India, cosmetics are regulated under the Drugs and Cosmetics Act and the Cosmetics Rules, 2020. Anyone who manufactures cosmetics for sale needs a manufacturing licence from the State Licensing Authority (your state’s FDA or Drugs Control department). Domestic manufacturing is applied for in Form COS-5 and granted in Form COS-8.
Small brands usually take one of two routes:
- Own facility: you set up a unit that meets the premises, equipment and technical-staff requirements and apply for your own licence. This makes sense only at scale.
- Loan licence with a contract manufacturer: you work with a manufacturer that already holds a cosmetics manufacturing licence and apply for a loan licence to make your products at their facility, under your brand. This is how most D2C skincare brands start.
Either way, each product (and its variants) is listed on the licence. Choose a manufacturer who has done this before and will share their licence copy, product list and batch records with you.
4. Importing instead of manufacturing?
If you import finished cosmetics, you need an import registration from CDSCO (the central regulator) under the same rules, applied for through the SUGAM portal, before goods arrive at customs. Plan for this well ahead of your first shipment.
5. Labelling that passes both the regulator and the marketplace
Cosmetic labels in India need, among other things: the product name, full ingredient list, manufacturer name and address, manufacturing licence number, batch number, manufacturing date and use-before date, net quantity and MRP. Marketplaces check these at listing, so get your artwork reviewed before it goes to print.
6. Legal Metrology (packaged commodities)
Under the Legal Metrology (Packaged Commodities) Rules, 2011, packaged goods must carry declarations like net quantity, MRP (inclusive of taxes), month and year of manufacture and consumer-care details. Packers and importers generally need registration with the Legal Metrology department. Missing this is one of the most common reasons for marketplace takedowns.
7. Claims: where most brands get into trouble
A cosmetic can cleanse, beautify or alter appearance. It cannot claim to treat acne, eczema or hair loss; those are drug claims. Words like “cures”, “heals” or “clinically proven” need either a drug licence or real evidence. Advertising is also self-regulated by ASCI, and influencer posts count as advertising. Build a claims sheet that maps every claim to a test report before you launch.
8. Testing you should budget for
- Microbial and heavy-metal testing on each batch
- Stability testing to support your shelf life
- Preservative efficacy (challenge) testing for water-based products
- Dermatological or safety-in-use testing if you want “dermatologically tested” on the pack
Use NABL-accredited labs so your reports are accepted by marketplaces and retailers.
The launch order that saves months
- Company, PAN, bank account, GST
- Trademark search and filing
- Shortlist a licensed contract manufacturer; finalise formula
- Loan licence application with the manufacturer
- Testing, claims sheet and label review
- Legal Metrology registration and final artwork
- Marketplace and website onboarding
Rules and forms change. Treat this as a founder’s checklist, not legal advice, and confirm current requirements with your State Licensing Authority or a regulatory consultant before you file.
Want the paperwork handled while you build the brand? Zobo runs trademark, licences, manufacturer sourcing, testing and marketplace onboarding for skincare founders as one project. Book a free call and we’ll send you the exact list for your products.
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