80 Categories, One Product: How to Get Cosmetic Product Categorisation Right in India

The Categorisation Problem

Of all the challenges in India’s Cosmetic Import registration process, product categorisation is one of the most underestimated. Under the Cosmetics Rules, 2020, CDSCO has prescribed 80 Cosmetic categories under the Fourth Schedule. Every product included in a COS-1 application must be mapped to the appropriate category before submission of an application.

Get it right, and the application proceeds. Get it wrong — or assign a product to an ambiguous category without justification — and the application is likely to receive a query, creates additional documentation burden, and adds weeks or months to the timeline.

This article explains the categorisation principles generally applied during CDSCO Cosmetic registration reviews, discusses major category clusters with examples, addresses borderline and dual-category situations, and provides a practical decision framework for regulatory teams.

Why Does CDSCO Require Cosmetic Products to Be Categorised

Approximately 80 categories classified under Cosmetics Rules, 2020 CDSCO serve three regulatory purposes:

• They determine the fee applicable to each application, 
• They define the ingredient and specification standards against which the product will be reviewed, and 
• They establish the labelling requirements relevant to the product type.

Categories are not arbitrary groupings. They reflect the intended use, the region of the body where the product is applied, and — in some cases — the product’s physical form or delivery mechanism. A product that is applied to the lips is in a different regulatory category from a product applied to the face, even if both carry moisturising claims.

The Major Category Clusters

1. Skin Care Products

The skin care cluster is the largest category group and includes sub-categories such as face creams and moisturisers, eye creams, body lotions, hand creams, serums, face masks and peel-off products, and scrubs and exfoliants. The primary categorisation criterion is the site of application (face, eye area, body, hands) combined with the primary function (moisturising, cleansing and care).

2. Colour Cosmetics

Foundation, lipstick, lip gloss, mascara, eyeshadow, eyeliner, blush, bronzer, highlighter, nail makeup, and related products. Products intended for application around sensitive areas such as the lips and eyes often receive additional regulatory attention

3. Hair Care Products

Shampoos, conditioners, hair oils, hair colourants and bleaches, hair styling products (gels, sprays, waxes), anti-dandruff, and anti-hair loss products. Hair dyes and bleaching products require particular attention to ingredient declarations, formulation and Label compliance.

4. Oral Hygiene Products

Toothpastes, mouthwashes, teeth whitening products, and breath fresheners. These products are often assessed against specific BIS requirements and product standards, and the ingredient requirements are notably more specific than other Cosmetic categories.

5. Sun Care Products

Sunscreens (SPF products), after-sun preparations, self-tanning products, and bronzing lotions. Sunscreens in India are a regulated sub-category that requires declaration of UV filter types, SPF values, and compliance with permitted UV filter lists.

6. Nail Care Products

Nail lacquers, nail hardeners, nail polish removers, nail care creams, and cuticle products.

7. Perfumes and Deodorants

Fragrances, eau de toilette, eau de parfum, deodorant sticks, sprays, and antiperspirants. Product claims should be carefully reviewed to ensure they remain within the scope of Cosmetic regulations.

8. Shaving and Grooming Products

Shaving creams, aftershave lotions, shaving gels, and men’s grooming preparations.

9. Baby and Child Products

Baby shampoos, baby oils, baby powders, baby lotions, and nappy creams. These products typically require careful evaluation of ingredient suitability and safety 

Categorisation Criteria: The Decision Logic

1. When reviewing a Cosmetic product for import registration, categorisation should be based on regulatory principles—not marketing descriptions. A practical decision framework is:
2. Identify the primary intended use — what is the product’s main function?
3. Identify the area of application — Is the product intended for the face, lips, eyes, hair, scalp, nails, oral or body?
4. Identify the product form — rinse-off or leave-on? This matters for certain ingredient limits.
5. Review any special claims — SPF, hair loss, anti-dandruff, hair dye. Each may trigger a specific sub-category or additional regulatory requirements.
6. Confirm the Product Falls Within the Cosmetic Definition — any therapeutic or medicinal claim disqualifies the product from Cosmetic registration.

Figure1

Borderline and Dual-Category Situations

The borderline cases — products that could reasonably sit in two categories — are where experienced regulatory judgment becomes essential. Some common examples:

Table 1

Impact of Mis categorisation

Mis categorisation at the application stage has a cascade of consequences:

• CDSCO raises a query requesting justification for the selected category or requesting re-categorisation
• Requests to revise application documents, product specifications, labels, Cover letter and Part 1.
• Additional review cycles and extended approval timelines 

Based on practical experience with Cosmetic registration applications, categorisation-related queries can add an average of two to four months to the approval timeline. In many cases, these delays can be avoided through a thorough pre-filing categorisation review

Key Takeaways

• CDSCO has defined approximately 80 product categories; every COS-1 application must correctly assign each product to the right category
• Categorisation is based on intended use, area of application, product form, and any special claims (SPF, anti-dandruff, anti-hair loss, tooth whitening)

Conducting a thorough categorisation review before submission is one of the most effective ways to minimise regulatory risk and facilitate a smoother approval process.

How CliniExperts Can Help

CliniExperts’ Cosmetic regulatory team conducts pre-filing product categorisation reviews for every COS-2 application — drawing on our experience with 350+ product types across 30+ countries of origin. If you are unsure whether your product falls into one category or two, or if a special claim might push it toward drug classification, contact us before filing at contact@cliniexperts.com.