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Introduction
Cosmetic labelling in India is not just a packaging design step. It is a legal compliance step that can affect product approval, retail readiness, marketplace listing, customer trust, and brand liability.
For cosmetic brand founders, especially those using private label or contract manufacturing, the label must clearly state who made the product, what it contains, when it expires, how much it contains, and what warnings apply.
The Cosmetics Rules, 2020 form the core framework for cosmetic labelling in India, with Chapter VI covering labelling, packing, and standards for the sale or distribution of cosmetics.
Which Laws Actually Govern Cosmetic Labelling in India?
Cosmetic labelling in India does not sit under one single rule. The core regulation comes from the Cosmetics Rules, 2020, framed under the Drugs and Cosmetics Act, 1940. These rules define how a cosmetic must be labelled, packed, manufactured, imported, and sold.
The Cosmetics Rules state that no person should sell or distribute a cosmetic unless, for Indian-origin products, it is manufactured by a licensed manufacturer and labelled and packed according to the rules.
Is It Only the Cosmetics Rules 2020, or Do Other Regulations Apply Too?
No. The Cosmetics Rules, 2020 are central, but they are not the only layer.
A cosmetic label may also need to follow:
- Drugs and Cosmetics Act, 1940, especially provisions around misbranded cosmetics.
- Legal Metrology (Packaged Commodities) Rules, 2011, for retail pack declarations such as MRP, net quantity, manufacturer or packer details, and consumer complaint information.
- BIS standards, where the product category appears under the Ninth Schedule of the Cosmetics Rules.
- Plastic Waste Management Rules, 2016 and later amendments, where plastic packaging, multilayered packaging, recycled plastic, or EPR obligations apply.
This means a shampoo, baby soap, sunscreen, hair dye, or intimate hygiene wash may need more than a basic cosmetic label checklist.
What Are the Mandatory Declarations on Every Cosmetic Label?
The Cosmetics Rules separate certain declarations between both inner and outer labels, and some declarations that may appear on either the inner or outer label.
What Information Must Appear on Both the Inner and Outer Label?
Under Rule 34 of the Cosmetics Rules, 2020, the following must appear on both the inner and outer labels:
- Product name
- Name of the cosmetic.
- Name of the manufacturer.
- Complete address of the manufacturing premises.
- Any applicable cautionary or hazard warnings
- Use-before date, expiry date, use-by date, or expiry period from manufacturing, as applicable.
If the product is not manufactured in a factory owned by the brand or principal manufacturer, the label must mention the actual manufacturer’s name and address or the country of manufacture, such as “Made in India”.
What Information Can Appear on Either the Inner or Outer Label?
The following can appear on either label:
- Batch number, with terms such as “Batch No.”, “B. No.”, “Lot No.” or “Lot”
- Manufacturing licence number, with “M”, “M.L. No.” or “Mfg. Lic. No.”
- Net contents by weight, volume, or count, as applicable
- Ingredient list, preceded by “INGREDIENTS”
Ingredients above 1% should appear in descending order, followed by ingredients at 1% or below in any order. Small packs of 60 ml or less for liquids and 30 g or less for solids or semi-solids are exempt from ingredient declaration.
Where a product has any hazard, the inner label must clearly mention safe-use directions, warnings, cautions, special instructions, and names and quantities of hazardous or poisonous ingredients.
What's the Difference Between “Manufactured By” and “Marketed By” on a Label, and Why Does It Matter for Brand Owners?
“Manufactured by” identifies the licensed manufacturer and the actual manufacturing premises responsible for producing the cosmetic.
“Marketed by” usually identifies the brand owner, distributor, or company selling the product under its own brand name.
For contract and private label manufacturing, this distinction matters because your brand may own the product concept, packaging design, and sales channel, but the actual manufacturing must still trace back to the licensed manufacturer.
If I'm Using a Contract Manufacturer, Whose Name Goes on the Label?
If you use a contract manufacturer, the label should not hide the actual manufacturer. The Cosmetics Rules require the name and address of the manufacturer and the complete address of the premises where the cosmetic has been manufactured.
If the product is not manufactured in a factory owned by the manufacturer named on the label, the label must show the actual manufacturer’s name and address or the country of actual manufacture, as applicable.
Legal Metrology adds another important point. If a brand owner’s name and address appear as the marketer, the brand owner may be held responsible for violations under the Legal Metrology rules.
So, for brand founders, the right structure usually looks like this:
- Manufactured by: Licensed cosmetic manufacturer with full manufacturing address
- Marketed by: Brand owner or marketing company with address, where applicable
- “Packed by” applies when a separate entity handles packaging.
What Are the Category-Specific Labelling Rules Brands Often Miss?
Many founders make the mistake of using one label format for every cosmetic category. That can create risk. Hair dye, toothpaste, baby products, sunscreen products, and BIS-listed cosmetics may need additional checks.
Do Hair Dyes and Toothpastes Have Different Labelling Requirements?
Yes.
Hair dyes containing para-phenylenediamine or other dyes, colours, and pigments must carry a specific caution in English and local languages on both inner and outer labels. The caution must warn about possible skin irritation, the need for a preliminary test, and the danger of using the product for eyelashes or eyebrows.
Fluoride toothpaste has a separate rule. The fluoride content must not exceed 1000 ppm, and the fluoride content in ppm must appear on both the tube and carton. The expiry date must also appear on both the tube and carton.
What Labelling Rules Apply to Sunscreen and SPF-claim Products?
Sunscreen products need careful claim control because SPF, UVA protection, broad spectrum, water resistance, and protection claims must be supported by testing and relevant standards.
BIS has introduced IS 19685:2026 for Sunscreen Cosmetic Products. BIS describes it as a specification covering safety, performance, labelling, and methods for evaluating SPF and UVA protection. It also defines sunscreen products as preparations intended to contact skin or lips and absorb, reflect, or scatter UV radiation between 290 nm and 400 nm.
For brand owners, this means sunscreen label claims should never be added only for marketing appeal. Claims such as SPF 50, PA++++, broad spectrum, water resistant, sweat resistant, or anti-tan should be backed by proper technical testing and supporting documentation.
Are There Specific Requirements for Baby Care or Intimate Hygiene Products?
Baby care and intimate hygiene products need a conservative labelling approach. The Cosmetics Rules do not allow false or misleading cosmetic claims, and every cosmetic must comply with applicable safety and quality standards.
For baby products, check whether the product falls under a BIS-listed category. For example, the Ninth Schedule includes skin powder for infants, baby toilet soap, and hair shampoo for babies.
For intimate hygiene products, avoid medical, therapeutic, infection-cure, pH-cure, or disease-treatment claims unless the product has the correct regulatory basis. A cosmetic can cleanse, freshen, or support hygiene, but it should not sound like a drug.
Are There Any BIS Certification Requirements that Affect the Label?
The Cosmetics Rules require cosmetics covered under the Ninth Schedule to comply with relevant Indian Standards laid down by BIS.
The Ninth Schedule includes categories such as skin powders, toothpaste, skin creams, hair oils, shampoos, hair creams, oxidation hair dyes, nail polish, aftershave lotion, lipstick, toilet soap, baby toilet soap, kajal, cream bleach, baby shampoo, and others.
If BIS updates or publishes new standards, the Cosmetics Rules state that the new or amended standard becomes mandatory after six months from publication.
What Are the Most Common Labelling Mistakes That Lead to Misbranding?
Labelling mistakes can turn into compliance issues quickly. A missing batch number or wrong claim may look small, but regulators may view it differently.
What Counts as a “Misbranded” Cosmetic Under Indian Law?
Under Section 17C of the Drugs and Cosmetics Act, 1940, a cosmetic is deemed misbranded if it contains a colour that is not prescribed, if it is not labelled in the prescribed manner, or if its label, container, or anything accompanying it carries a false or misleading statement.
The Cosmetics Rules also prohibit false or misleading claims.
Which Labelling Errors Do New Brand Founders Make Most Often?
New founders often make these mistakes:
- They mention only the brand name and skip the actual manufacturer’s full details.
- They write “natural”, “chemical-free”, “clinically proven”, or “dermatologist recommended” without substantiation.
- They miss the manufacturing licence number.
- They add SPF, anti-dandruff, anti-acne, pigmentation, fairness, or anti-hair fall claims without checking claim risk.
- They use imported packaging templates without adapting them to Indian rules.
- They forget the inner label requirements when the product has both a tube and a carton.
- They place MRP, net quantity, or consumer care details in a hard-to-read area.
- They miss local language caution requirements for hair dyes.
The safest approach is simple: finalise claims, formula, pack size, ingredient list, warnings, and manufacturer details before artwork approval.
What Additional Compliance Layers Apply Under Legal Metrology and Plastic Waste Rules?
Cosmetic brands usually focus on CDSCO and the Cosmetics Rules, but retail packs also need Legal Metrology checks.
What Does the Legal Metrology (Packaged Commodities) Rules 2011 Require on a Cosmetic label?
The Legal Metrology rules require every retail package to carry clear and conspicuous declarations. These include the name and address of the manufacturer, or the manufacturer and packer where they differ, the common or generic name of the commodity, the net quantity, month and year of manufacture or pre-packing or import, retail sale price, and other prescribed declarations.
The rules also require consumer complaint contact details, including name, address, telephone number, and email address if available.
Declarations must be legible and prominent. The retail sale price and net quantity should contrast clearly with the label background, and required declarations should generally appear on the principal display panel.
Does Plastic Packaging on Cosmetic Products Require Any Label Declaration?
Yes, in certain cases.
Under the Plastic Waste Management Rules, each plastic carry bag and multilayered packaging must carry prescribed information such as manufacturer name, registration number, and thickness or related details, depending on the packaging type.
The rules also place EPR obligations on producers, importers, and brand owners. EPR targets are determined category-wise, and brand owners need to track their plastic packaging responsibility.
Recent Plastic Waste Management amendments have also strengthened recycled plastic content and marking expectations. Reports on the 2026 amendment state that recycled plastic packaging must conform to IS 14534:2023 and carry labelling or marking indicating recycled content.
How Should a Brand Owner Approach Label Finalisation Before Launch?
Do not finalise label artwork at the end of product development. Make compliance part of the launch workflow from the first sampling stage.
What is the Right Process for Locking a Compliant Label Before Your Product Goes to Market?
Follow this practical process:
- Confirm product classification: Decide whether the product is a cosmetic, drug, ayurvedic product, personal hygiene product, or another regulated category.
- Freeze formula and ingredient list: Do not approve the label until the final formula, INCI-style ingredient list, fragrance allergens if applicable, colours, actives, and preservatives are confirmed.
- Check category-specific rules: Review special rules for hair dyes, fluoride toothpaste, sunscreen, baby products, intimate care, colour cosmetics, and BIS-covered products.
- Confirm manufacturer and licence details: Add the correct “Manufactured by” details, manufacturing premises address, and manufacturing licence number.
- Validate claims: Remove claims that sound medical, exaggerated, unverified, or misleading. Keep claims specific and evidence-backed.
- Check Legal Metrology declarations: Verify MRP, net quantity, consumer care details, date format, pack size, and principal display panel readability.
- Review packaging compliance: Check plastic packaging, multilayered packaging, recycled content, EPR, and disposal-related requirements.
- Approve artwork only after compliance review: Keep an approved artwork PDF, label checklist, batch coding plan, and packaging specification on record.
Conclusion
Cosmetic labelling requirements in India are detailed because a label identifies the product, protects the consumer, supports traceability, and proves manufacturing accountability.
For a cosmetic brand founder, the label is not just a design file. It is a compliance document printed on your product, so it must be checked with the same seriousness as the formula.
Arise Cosmetic supports private label, contract, custom formulation, and cosmetic manufacturing across skincare, haircare, baby care, intimate hygiene, men’s grooming, and salon product categories.
Planning to launch a compliant cosmetic product? Contact Arise Cosmetic today to discuss your formulation, packaging, and labelling requirements.
About the Author
Arise Cosmetic
Arise Cosmetic is a GMP-certified, ISO-compliant, FDCA-approved private label cosmetic manufacturer based in Gandhinagar, Gujarat. Founded in 2017, the team has developed 2,000+ formulations across hair care, skin care, baby care, men's grooming, and intimate hygiene. Arise Cosmetic works with D2C brand founders, salon owners, direct selling companies, and first-time beauty entrepreneurs across Globally, guiding them from formulation brief to bulk delivery under one roof.
1.What is a private label in cosmetics?
A private label in cosmetics means a third-party manufacturer produces products sold under another brand’s name, letting businesses offer their own cosmetic lines without needing their own factories.
2. Can I launch a cosmetic brand without manufacturing?
Yes, you can launch a cosmetic brand without manufacturing by using private label services. This lets you focus on branding and sales while a third party handles production.
3. How long does it take to launch a private label cosmetic line?
Launching a private label cosmetic line typically takes 3 to 9 months, depending on product complexity, customisation, and regulatory approvals.
4. What’s the minimum order quantity for private label cosmetics?
The minimum order quantity (MOQ) for private label cosmetics is typically 1000 units per variant, though this can vary by manufacturer and product.