Cosmetic Loan License in India: COS-6 Application, COS-9 Licence, Fees and Process

What Is a Cosmetic Loan License?

A cosmetic loan license is a licence granted under the Cosmetics Rules, 2020 that lets a brand owner manufacture its own cosmetics at another company's licensed manufacturing site. The brand owner applies on Form COS-6, and the State Licensing Authority grants the licence on Form COS-9. The host unit must already hold a cosmetic manufacturing licence on Form COS-8 for the same kind of products.

In simple words, a COS 9 loan licence puts your brand's products on a licence in your own name, while the machines, building and production staff belong to the host. It is the most common loan license for cosmetics route for D2C and private-label brands, because it gives legal ownership and control of the products without the cost of a factory. Every cosmetic loan licence in India is granted by the state where the host unit is located, not by CDSCO.

In India, the application is filed on ONDLS or your state drug licensing portal and decided by the State Drug Licensing Authority. The rules set a 45-day limit for the decision, and the fee is ₹10,000 for up to 10 items in each category of cosmetics. The licence has no expiry date as long as a retention fee is paid every five years.

Who Needs a Loan License for Cosmetic Manufacturing?

A loan license for cosmetic manufacturing suits any business that wants products made under its own licence but does not own a factory:

• D2C and online beauty brands selling skincare, haircare, colour cosmetics or fragrances under their own name
• Salon and dermatology clinic brands launching their own product range
• Ayurvedic-style and herbal personal care brands whose products are cosmetics rather than AYUSH medicines
• Pharma and FMCG companies adding a cosmetic range without building new cosmetic lines
• Exporters who want products made for them under their own licence
• Existing cosmetic manufacturers that need extra capacity or a product type their own plant cannot make

Can you start a cosmetic brand without a factory?

Yes. To start cosmetic brand without factory investment, you have two legal routes: get a cosmetic loan license and make your products in a licensed host unit, or have a licensed manufacturer make the products under its own licence for you (third-party or contract manufacturing). Both are legal. The difference is whose licence your products sit on, and that decides how much control you have.

Loan License vs Manufacturing License: Cosmetics Compared

The question of loan license vs manufacturing license cosmetics brands ask most often has a clear answer once you compare the three legal routes side by side. This is the core choice in contract manufacturing cosmetics India brands face:

When a loan licence is the better choice

Choose a cosmetic loan license when you want the products legally in your own name, intend to use more than one manufacturer over time, sell to buyers or marketplaces that ask for the brand owner's licence, or plan to build your own factory later and want regulatory history in your name. It is also useful for exporters whose buyers want the brand owner to be the licensee.

When third party cosmetic manufacturing is enough

Third party cosmetic manufacturing, where the manufacturer lists your products on its own COS-8, suits brands testing a small range, brands without staff to manage licensing, and private-label ranges where the manufacturer's formulas are used. The trade-off is control: if you switch manufacturers, your products must be added to the new manufacturer's licence, and your labels must change.

Is there a cosmetic brand owner license?

There is no separate "cosmetic brand owner license" in the rules. A brand owner who wants a licence of its own gets it through the COS-9 loan licence. A brand owner who only markets products made under someone else's COS-8 does not need a manufacturing licence, but its labels must correctly show the actual manufacturer and premises, and it must not make drug-like claims.

Choosing the Right Host Manufacturer

Your COS-9 is tied to the host's COS-8. Under Rule 26(g) of the Cosmetics Rules, if the host's licence is cancelled or suspended, your loan licence is deemed cancelled or suspended too. Choose the host carefully:

• Check the host's COS-8 licence: current, retention fee paid, and covering the same categories as your products
• Check capability: equipment and capacity for your product types, such as creams, emulsions, powders, aerosols or soaps
• Check testing: in-house laboratory or an approved testing laboratory for raw materials and finished products
• Check compliance history: past inspection findings, warnings or suspensions
• Visit the unit before signing, and confirm it meets the Seventh Schedule GMP requirements you will declare in COS-7

What the loan licence agreement should cover

• Products, categories and the right to use the host's premises, equipment and staff
• Who supplies raw materials and packaging, and who approves them
• Batch manufacturing records, testing, release and record retention for three years after batch expiry
• Access for your team and for regulators
• Notice if the host's licence is suspended, cancelled or changed, and an exit plan
• Responsibility for complaints, recalls and label accuracy

Regovex reviews the host's licence and the agreement before filing, because a weak host or a vague agreement is the biggest long-term risk in a loan licence.

Eligibility for a Cosmetic Loan License

To get a COS-9 loan licence, four things must be in place before you file:

1. A host unit with a valid COS-8 licence covering the categories of cosmetics you want to make
2. A written agreement with the host allowing you to use its manufacturing site, equipment and staff
3. Competent technical staff to supervise manufacture of your products, with a qualification accepted under Rule 26 of the Cosmetics Rules (a Diploma in Pharmacy, registration as a pharmacist, Intermediate with Chemistry, or a Bachelor's degree in Cosmetic Technology) and a consent letter for full-time work
4. Testing arrangements: the host's in-house laboratory or an approved testing laboratory for raw materials and finished products

Your products must also be cosmetics, not drugs or Ayurvedic medicines, and must not contain banned ingredients. A product that is new to India, such as one with a novel ingredient, needs prior permission from CDSCO on Form COS-3 before the state can grant the licence (Rule 23(3)).

Cosmetic Loan License Documents Required

The cosmetic loan license documents required are listed in Part II of the Second Schedule to the Cosmetics Rules, 2020. A complete COS-6 file usually contains:

Applicant documents

• Fee receipt or online payment challan
• Constitution of the firm: partnership deed, or certificate of incorporation with memorandum and articles, or LLP agreement
• Names, addresses and identity proof of proprietors, partners or directors
• Brand ownership documents, such as a trademark application or registration, where available
• Details of the competent technical staff, with qualification certificates and a consent letter for full-time employment

Host unit documents

• Copy of the host's valid COS-8 licence, with the latest retention fee receipt
• Loan licence agreement between the brand owner and the host
• Approved layout plan of the manufacturing area
• Proof of the host's lawful possession of the premises
• List of machinery and equipment available for your products

Product documents

• List of products with their full formulae, in the format the authority asks for
• Draft labels for each product, showing the brand owner and the manufacturing site correctly
• Undertaking that products meet the Bureau of Indian Standards specifications in the Ninth Schedule and contain no prohibited ingredients

Declarations

• Form COS-7 self-declaration that the site meets the Seventh Schedule good manufacturing practices
• Undertakings required by Part II of the Second Schedule, signed by the applicant

The most common reasons a file is returned are a host licence that does not cover the product category, formulae without percentages, labels that do not name the manufacturing premises, and an unsigned or vague agreement. Regovex checks each of these before filing.

Cosmetic Loan License Process: Step by Step

The cosmetic loan license process has eight steps, from choosing the host to starting production. In India, the application goes to the State Drug Licensing Authority through ONDLS or your state drug licensing portal.

How to get loan license for cosmetics

1. Classify the products. Confirm each product is a cosmetic and list its category (skin, hair, oral care, colour cosmetics, fragrance and so on).
2. Choose and check the host. Confirm its COS-8 covers your categories and that it can make your products.
3. Sign the loan licence agreement covering premises, equipment, staff, testing and records.
4. Finalise formulae and labels. Check every ingredient against banned lists and Indian standards, and draft labels that name the brand owner and manufacturing site.
5. Prepare the file: Form COS-6, Form COS-7 self-declaration, Second Schedule documents and undertakings.
6. File online and pay the fee. Rule 23 requires the application through the online portal; if the portal is not available, the authority may accept it offline.
7. Decision within 45 days. The State Licensing Authority grants the licence on Form COS-9 or refuses it with reasons within 45 days of the application.
8. Start production and inspection. Once a copy of the licence is uploaded to the CDSCO website, you may start manufacturing (Rule 23(6)). The authority inspects or authorises an inspection within 30 days of the grant to verify your COS-7 declaration.

The COS 6 form cosmetic loan applicants file

The COS 6 form cosmetic brands file asks for the applicant's details, the host unit's name, address and COS-8 licence number, the categories and items to be made, the technical staff, and the testing arrangements. It is filed with the COS-7 self-declaration and the documents listed above. Every item and variant you plan to make should be on the first application, because adding items later needs an amendment and an extra fee.

The COS 9 loan licence you receive

The COS 9 loan licence names the brand owner as licensee, the host's manufacturing site, the categories and items approved, and the technical staff. Keep a copy on file at the host unit and with your team; inspectors and buyers ask for it.

Cosmetic Loan License Fees

The cosmetic loan license fees are set in the Third Schedule to the Cosmetics Rules, 2020, and match the fee list published by the Delhi Drugs Control Department:

There is no separate inspection fee. Your total cost also includes the host's charges under your agreement, product testing, label design and our professional fee, which we quote in writing with government fees shown separately.

Worked example

A skincare brand in India planning 8 skin products and 4 hair products has 12 items in two categories, each within 10 items. Its loan licence fee is ₹10,000 for each category, or ₹20,000. If it later adds 3 more skin products, taking that category to 11 items, it pays ₹500 for the extra item.

Validity and Retention of a Cosmetic Loan License

A COS-9 loan licence does not expire on a fixed date. Under Rule 30, it remains valid as long as the retention fee is paid before the end of each five-year period from the date of issue, unless it is suspended or cancelled. If the fee is paid late, a late fee of 2% of the retention fee is charged for each month or part of a month, for up to 180 days; after that, the licence is deemed cancelled. Regovex records the retention date on the day your licence is granted.

Form 31A and Form 32A: The Old Loan Licence Forms

Before the Cosmetics Rules, 2020, cosmetic loan licences were issued under the Drugs and Cosmetics Rules, 1945: the application was Form 31-A and the licence Form 32-A. People still search for form 31A cosmetics loan license and form 32A cosmetic loan license, and some older licences carry these numbers. For new applications, Form 31-A has been replaced by COS-6 and Form 32-A by COS-9. Older loan licences continue under the transition provisions, but changes, retention and any new items now follow the Cosmetics Rules, 2020.

Cosmetic Loan License in Uttar Pradesh and Himachal Pradesh

The rules are national, but the licence is granted by the state where the host unit is located. That is why a brand based in India may hold a loan licence from another state.

Cosmetic loan license Uttar Pradesh

For a cosmetic loan license Uttar Pradesh applications go to the Food Safety and Drug Administration (FSDA), Uttar Pradesh, when the host unit is in the state, for example in the industrial areas of Noida, Ghaziabad, Kanpur or Lucknow. FSDA handles both food and drug licensing, so brands with food or supplement products can deal with one department for both.

Cosmetic loan license Himachal Pradesh

Many cosmetic and pharma manufacturers are based in Himachal Pradesh's Baddi–Barotiwala–Nalagarh industrial belt, so a cosmetic loan license Himachal Pradesh application is common for brands using hosts there. The licence is granted by the Himachal Pradesh drugs control authority, and the host's COS-8, inspection history and capacity should be checked like any other host.

A Typical Cosmetic Loan Licence Timeline

With a ready host, most brands move from first call to production in about two to three months:

The 45 days is the outer limit in the rules. A complete file, a host whose licence matches your categories and quick replies to any query keep you on schedule.

How Categories and Items Affect Your Loan Licence

The loan licence fee is charged per category of cosmetics and per item. Up to 10 items in one category cost ₹10,000; each item beyond 10 in that category costs ₹500. A second category, such as hair care alongside skin care, is charged separately. Variants of the same product, such as different shades of a lipstick, should be listed the way the authority expects, so plan your range before filing. Listing every product you expect to launch in the next year on the first application is usually cheaper and faster than adding items later.

Herbal and Ayurvedic-Style Products: Cosmetic or AYUSH?

Many brands that want a loan license for cosmetics sell herbal or "Ayurvedic" products. The label alone does not decide the licence. A product used to cleanse, beautify or improve appearance, such as a herbal face wash or hair oil sold for shine, is a cosmetic and fits a COS-9. A product made to a classical Ayurvedic formula, or one that claims to treat a condition such as hair fall due to a disease, may be an Ayurvedic medicine that needs a licence from the state AYUSH authority instead. We classify each product before filing so that your loan licence covers only products that are truly cosmetics.

What a Cosmetic Loan Licence Does Not Cover

• Selling drugs or medicated products, which need a drug licence
• Importing finished cosmetics, which needs CDSCO cosmetic import registration (COS-2)
• Manufacturing at a site not named on the licence, even if the same host owns it
• Products or categories not listed on the COS-9
• New cosmetics without the CDSCO permission required under Rule 23(3)

Loan Licences for Exporters and Marketplace Sellers

Overseas buyers and large marketplaces often ask who holds the manufacturing licence for a product. With a COS-9, the answer is the brand owner, which simplifies buyer audits, export documents and marketplace onboarding. Exporters should also check the destination country's rules, because a product legal in India may need a different formula or label abroad. Marketplaces in India typically ask for the licence copy, the manufacturer's details and product labels before listing.

Checklist Before You File for a Cosmetic Loan Licence

• Every product confirmed as a cosmetic, with no drug or AYUSH claims
• Host's COS-8 licence current and covering all your categories
• Host site visited and checked against the Seventh Schedule
• Loan licence agreement signed, including notice and exit terms
• Technical staff appointed, with qualifications and consent letter
• Testing arrangements confirmed for raw materials and finished products
• Full formulae with percentages, checked against banned ingredient lists
• Labels drafted with brand owner, manufacturing site and licence number placeholder
• Trademark application filed for the brand name, where possible
• Fee calculated per category and item

After the Loan Licence: Staying Compliant

As the loan licensee, you are responsible for your products even though they are made in someone else's unit. Inspectors can visit the host site at least once every three years, or more often on a risk basis, and will ask for your records as well as the host's.

Testing and batch records

Every batch of raw material and finished product must be tested, in the host's laboratory or an approved testing laboratory. Batch manufacturing records must follow the Eighth Schedule and be kept for three years after the batch's expiry, and test records for three years from manufacture. Agree in writing who keeps which records and how you can access them.

Labelling

Labels must carry the name of the product, the brand owner, the name and address of the actual manufacturing site with the licence number, batch number, manufacturing and expiry or use-before dates, net content, ingredients and any warnings required. Claims that a product cures, treats or heals a condition can turn a cosmetic into a drug, and the Cosmetics Rules prohibit testing cosmetics on animals.

Changes you must report

• Changes in labelling, composition, testing, specifications or documents: notify the authority within 30 days, with an undertaking on BIS compliance
• Change in the firm's constitution: notify in writing; the licence stays valid for up to six months unless a fresh licence is issued
• Change of name or address: apply for an amendment within 60 days
• New items or categories: apply to add them, with the fee, before manufacture
• Change of host unit: needs a fresh loan licence for the new site, because the COS-9 is site-specific

If the host's licence is suspended or cancelled

Because your COS-9 depends on the host's COS-8, a suspension or cancellation at the host stops your production too. Ask the host to notify you immediately of any notice from the authority, keep a second qualified host in view, and plan stock so you can move without a long gap.

Common Mistakes in Cosmetic Loan Licence Applications

• A host licence that does not cover your category. A host licensed for creams cannot make your aerosol deodorant under your loan licence.
• Applying before formulae are final. Changes after grant need notification and sometimes new items.
• Drug-like claims on labels. "Anti-acne treatment" or "hair regrowth" claims can push a product into drug regulation.
• No real technical person. The technical staff named must actually supervise your batches.
• Ignoring the host's compliance history. A host with past suspensions puts your licence at risk.
• Missing the retention date. After 180 days of non-payment, the licence is deemed cancelled.
• Mixing up loan and contract manufacturing. Your labels and documents must match the route you chose.

How to Choose a Cosmetic Loan License Consultant

A cosmetic loan license consultant should protect you from the long-term risks, not just file a form. Before you choose one, ask:

1. Will you check the host's COS-8 and compliance history before I sign?
2. Who reviews my formulae, ingredients and label claims?
3. Will you draft or review the loan licence agreement?
4. Do you prepare the COS-7 declaration so it matches the host site?
5. Will you track retention, item additions and changes after approval?
6. Are government fees shown separately from your fee?

Why Brands in India Choose Regovex for Their Cosmetic Loan License

• Host checks first: licence scope, retention status, capability and inspection history of the host unit
• Formula and label review against the Cosmetics Rules, BIS standards and banned ingredient lists, so products stay cosmetics and not drugs
• Complete COS-6 files with the COS-7 self-declaration, agreement and Second Schedule documents
• Query replies within 24–48 hours and support for the post-grant inspection
• After-care: retention dates, item additions, changes of host and constitution
• Drug, cosmetic, device and food expertise together, useful for brands with borderline products or supplements
• Transparent pricing, with government and professional fees shown separately in writing
• 99.8% approval rate across 100+ clients, rated 4.9/5 in verified client feedback

As a drug license consultant and drug regulatory consultant in India, Regovex also handles your own COS-8 licence if you later build a factory, and cosmetic import registration if you bring products in from abroad.

Cosmetic Loan License Services in India and Nearby Areas

Regovex helps D2C beauty brands, salon and clinic brands, herbal personal care brands, pharma and FMCG companies and exporters in India. Applications are filed on ONDLS or your state drug licensing portal and decided by the State Drug Licensing Authority where the host unit is in that state. Documents are collected digitally, and we coordinate with your host manufacturer directly.

We also serve brands in .

Related services:

• Cosmetic Manufacturing License in India
• Cosmetic Import Registration (COS-2)
• Drug License in India
• CDSCO Registration in India
• FSSAI Registration in India

What Our Clients Say

"I had great experience working with Regovex Consulting on the regulatory side of my product. Since the product category was relatively new and the guidelines were not very clearly defined, it required additional research and careful interpretation of the regulations." — Parichit Dhawan, Director, Feorah Wellness & Cosmetics

"I got my Drug Wholesale License through Regovex Consulting, and Devansh and his team provided complete end-to-end support, from premises selection to timely approval." — Bilal Ahmed Khan, Founder, Medwell Pharma

Cosmetic clients include Feorah Wellness & Cosmetics, Astro Naturelles, Nabu Trade and Jeevan Enterprises, across cosmetic licensing and imports.