Cosmetics and Personal Care: Registration, Not Production, Is the Hard Part

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, and getting a sample made is easy. What stands between the factory and your shelf is registration, formula checks and claims, and those are your job as the importer, not the factory's. This page walks 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 is about the rules, which we can verify, rather than about where the factories are.

Who Holds the Registration

Before the market-by-market detail, the one rule that runs through all of it. In every market below, 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. When a supplier says their products are "export ready", ask: ready for which market, and who is the responsible person there?

Registration by Market

This is one place a table helps, because you're comparing the same question across 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

Back to the 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: It's 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. 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 show it. Indian cosmetics were refused 312 times for being unapproved drugs, and herbal supplements a further 945 times. The FDA reads the claim, not the ingredient list. The EU and UK work the same way in principle: 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. 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. That's normal. Just know which factory fills your product, because that's the facility your US registration and your EU product file will name.

Back to the Lilial

Thirty-two alerts, one fragrance, and in most cases a formula that would have been legal in its home market. The lesson for anyone sourcing personal care from India, or anywhere, is that the work you do on paper decides whether you reach the shelf. Get the full formula, check it against your market, rewrite the claims, and appoint your responsible person before you order, not after the first refusal.

Running the formula review, the product file and the registration filings in your market is execution work, and it's complex. SourcingSync (opens in a new tab) can take it on.