Cosmetics and Personal Care Registration by Market

Getting a cosmetic made in India is the easy bit, and getting it onto a shelf abroad is where buyers come unstuck.

Between 2023 and 2024, regulators across Europe raised 22 alerts on Indian-made cosmetics for the same ingredient. It was BMHCA, a fragrance also known as lilial, banned in EU cosmetics since 2022. It turned up in perfumes, attars, body sprays, soaps and hair oils. Over 2021 to 2026 it accounts for 32 of the 62 EU Safety Gate alerts on Indian cosmetics, which makes one fragrance ingredient the biggest single reason Indian personal-care products get pulled in Europe (our analysis of EU Safety Gate (opens in a new tab) alerts, 2021 to 2026).

Nobody was making bad soap. The factories were following a formula that was legal somewhere else, and nobody on the buying side had checked it against the rules where it would be sold.

That's the shape of this whole industry. India has plenty of capable contract makers for skincare, hair oil, soap and ayurvedic ranges, but what stands between the factory and your shelf is registration, formula checks and claims, and those are your job as the importer and not the factory's. We'll walk through them by market. One honest caveat - India publishes no export figure for cosmetics or AYUSH products and we found no official cluster data, so this page sticks to the rules, which we can verify, rather than where the factories are.

Who Holds the Registration

One rule runs through all the market detail below. In every market, someone in that market is legally responsible for the product: an EU responsible person, a GB responsible person, the US company that lists the product, the Australian importer registered with AICIS, the UAE trade licence holder in Montaji. The Indian factory can supply the formula, the test results and the documents. It can't hold your registration for you. So when a supplier says their products are "export ready", ask which market they mean and who the responsible person is there.

Registration by Market

Here a table genuinely helps, because you're asking the same question of six markets.

The deeper rules sit on the destination pages: UK cosmetics rules, US cosmetics rules, Australia, New Zealand and the UAE, where registration typically needs one to two months before the first shipment.

Check the Formula Against Your Market, Not India's

Now, those lilial alerts. India's own cosmetics rules and the EU's banned list aren't the same, and Indian fragrance houses supply blends built for many markets. So the single most useful document you can ask for is the full ingredient list with the fragrance broken down, including the allergen declaration from the perfume house. Check it against your market's banned and restricted lists before the first sample is even approved. In our records the failures cluster in four places -

• Fragrance. BMHCA, and to a lesser degree other restricted allergens. Attars and hair oils are the repeat offenders.
• Hair dye. PPD must be paired with a coupler and kept within limits.
• Preservation. Five EU alerts were for microbial contamination, including Burkholderia cepacia. Ask for a preservative challenge test and a microbial count on production batches.
• Heavy metals. Kohl, kajal and powders. Test for lead every batch, not once.

Colour is the US version of the same problem. FDA permits only listed colour additives for each use, and the 97 Indian firms on Import Alert 53-06 tell you how often a colour that's fine elsewhere isn't allowed there. Test plans by product are on Quality control.

The Ayurvedic Question Is About the Claim, Not the Herb

Most buyers who come to India for personal care want something ayurvedic or herbal, and that's where India has a real edge in ingredients and know-how. The product page is Herbal and ayurvedic cosmetics. But here's what trips people up. In India, many ayurvedic personal-care products are made under ayurvedic medicine rules, and the label language follows that tradition: "heals", "treats", "cures dandruff", "for eczema". Put those words on a jar in your market and it may stop being a cosmetic.

The US numbers make the point. Indian cosmetics were refused 312 times for being unapproved drugs, and herbal supplements a further 945 times. The FDA reads the claim first and the ingredient list second. The EU and UK work the same way in principle, where a cosmetic is for cleaning, perfuming, protecting or changing appearance, and claims have to be honest and supported. In Australia, a claim to treat a condition can move a product toward therapeutic goods rules. The safe course is to rewrite the claims for your market before artwork goes to print, and have your regulatory adviser approve the wording. Exactly where the line falls for your product and your words is a question for that adviser, not for a generic list.

India does have a quality scheme worth knowing. The AYUSH Mark, run by the Quality Council of India, has a Standard level based on Indian compliance and a Premium level aligned to WHO good manufacturing practice and aimed at exporters (QCI (opens in a new tab)). A Premium Mark tells you something good about the factory's process, but it doesn't register anything in your market.

How It's Usually Sourced

Almost all of this is private label. You pick a base formula from the maker's library or brief a custom one, they fill it in your packaging, and you own the brand and the registrations. What changes when you buy this way is on private label, and the India-specific side, including label rules, is on Private label in India. Plenty of Indian brands sell through contract makers or traders rather than their own plant, which is perfectly normal. Just know which factory fills your product, because that's the facility your US registration and your EU product file will name.

Paperwork Before the First Order

Thirty-two alerts came from one fragrance, and in most cases from a formula that was legal in its home market. If you're sourcing personal care from India (or anywhere, really) then the paper work decides whether you reach the shelf, so get the full formula, check it against your market, rewrite the claims and appoint your responsible person before you order.

The formula review, the product file and the registration filings in your market are execution work, and they're fiddly. SourcingSync (opens in a new tab) can take them on if you'd rather not.