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Cosmetic Loan License Registration
Introduction
A Cosmetic Loan License lets a brand manufacture cosmetics in India without owning a factory, by using another company's GMP-compliant premises under a formal agreement. The brand files Form COS-6 with the State Licensing Authority, and once the premises, documents, and technical staff are verified, the licence is granted as Form COS-9.
It covers the same products as a standard manufacturing licence but ties the approval to the borrowed facility. The licence remains valid indefinitely once granted, subject to a retention fee every five years, and the State Licensing Authority typically decides on the application within 45 days.
What Is a Cosmetic Loan License in India?
A cosmetic loan license is a manufacturing authorisation issued under the Cosmetics Rules, 2020 to a brand owner who does not have their own manufacturing premises but wants to get cosmetics made at a facility that already holds a valid license. Instead of building or leasing a factory, the applicant enters into a manufacturing arrangement with an existing licensed manufacturer and applies to the State Licensing Authority for approval to use that facility under their own brand name.
This is the route most private-label skincare and haircare brands, contract-manufactured cosmetic lines, and new entrants (including several K-beauty-inspired brands) use to reach the Indian market without the capital cost of setting up a plant. The application is made in Form COS-6, and once the State Licensing Authority is satisfied with the documentation and the borrowed premises, the license is granted in Form COS-9 — the loan license equivalent of the standard COS-8 manufacturing license.
Why Brands Choose the Loan License Route
The loan license model exists because setting up a GMP-compliant cosmetic manufacturing unit is expensive and time-consuming. It gives new and growing brands a legally recognised way to manufacture under their own name while relying on someone else's compliant infrastructure.
No capital outlay for factory land, machinery, or Seventh Schedule GMP infrastructure — the borrowed unit already meets those standards.
Faster market entry, since the manufacturing premises don't need to be built and inspected from scratch.
Full ownership of the brand, formulation, and packaging remains with the license holder, not the manufacturing partner.
Same product scope as a standard manufacturing license — the loan license is not a lesser or restricted category of approval.
Works well alongside contract-manufacturing agreements already common in the Indian skincare, haircare, and personal-care industry.
Who Needs a Cosmetic Loan License?
You need to apply for a loan license under Form COS-6 if you fall into any of the following categories:
D2C or private-label cosmetic brands that outsource production to a third-party manufacturer instead of owning a factory.
Startups launching skincare, haircare, or personal-care lines who want to test the market before investing in owned infrastructure.
Existing brands adding new product categories through a contract manufacturer rather than expanding their own plant.
Import-linked brands (including several K-beauty-style labels) that want an India-manufactured line alongside imported SKUs.
The manufacturing partner whose premises you intend to use must already hold — or simultaneously be applying for — a valid license or loan license of their own, and their unit must meet the Seventh Schedule premises, plant, and equipment norms under the Cosmetics Rules, 2020.
Eligibility Conditions for the Applicant and the Borrowed Premises
A formal manufacturing agreement or arrangement must exist between the applicant and the premises owner.
The manufacturing unit must comply with Seventh Schedule GMP norms for plant, equipment, and hygiene.
A qualified technical/competent person — holding a diploma or degree in pharmacy, chemistry, or an equivalent recognised qualification — must supervise production.
Every product intended for manufacture must be mapped to its correct category under the Fourth Schedule of the Cosmetics Rules, 2020.
For a genuinely new cosmetic (one not already covered by an existing standard), prior permission in Form COS-3 from the Central Licensing Authority is required before the loan license can be granted.
Documents Required for Cosmetic Loan License
The COS-6 application must be accompanied by the information and undertakings specified in Part II of the Second Schedule of the Cosmetics Rules, 2020, along with the prescribed fee under the Third Schedule. In practice, State Licensing Authorities typically ask for:
Duly filled Form COS-6 application, submitted through the identified online portal (or offline where the portal is not yet operational for the state).
Proof of the manufacturing arrangement — agreement or undertaking between the applicant and the premises-owning manufacturer.
Constitution documents of the applicant firm — Certificate of Incorporation, MOA/AOA for companies, or partnership deed/proprietorship proof, as applicable.
Proof of the manufacturing premises — ownership document or lease/rental agreement held by the licensed manufacturer.
Approved layout plan of the manufacturing unit along with the list of machinery and equipment installed.
List of cosmetics proposed to be manufactured, with composition/formula and draft labelling for each product.
Details of the nominated technical/competent person, along with their qualification and identity proof.
Identity proof of the applicant/authorised signatory.
Form COS-7 self-declaration confirming Good Manufacturing Practice compliance under the Seventh Schedule.
Receipt of the prescribed fee, paid online through the portal (net banking, card, or e-challan, depending on the state).
Step-by-Step Process: From COS-6 Application to COS-9 Grant
The loan license process runs through the State Licensing Authority of the state where the borrowed manufacturing unit is located, generally via CDSCO's SUGAM portal (or the state's designated portal, or offline where the online system isn't yet active for that category).
Finalise the manufacturing arrangement — sign the agreement with a manufacturer who already holds (or is concurrently applying for) a valid license for the relevant product category.
Confirm product categorisation under the Fourth Schedule and prepare composition, formula, and labelling details for every product you intend to manufacture.
Compile the Second Schedule Part II documents listed above, including the technical person's credentials and the COS-7 self-declaration.
Create or log into the SUGAM/state portal account and complete the Form COS-6 application online, uploading all supporting documents.
Pay the prescribed fee under the Third Schedule of the Cosmetics Rules, 2020, and retain the payment receipt for the application file.
Submit the application to the concerned State Licensing Authority for scrutiny.
Respond to any deficiency memo or query the authority raises — incomplete technical-person credentials and mismatched product categorisation are the most common reasons for a query.
The State Licensing Authority verifies the borrowed premises' compliance (often relying on the existing inspection record of the manufacturer's own license) and confirms all requirements are met.
On satisfactory verification, the loan license is granted in Form COS-9, typically within 45 days of the application, per Rule provisions of the Cosmetics Rules, 2020.
Upload a copy of the granted COS-9 license to the CDSCO/portal record as required, and retain it for all future product launches, endorsements, and compliance filings.
Cosmetic Loan License Registration Fees
Fees for grant or retention of a manufacturing license or loan license are prescribed under the Third Schedule of the Cosmetics Rules, 2020 and are commonly cited as follows for each cosmetic category:
| Component |
Typical Fee Structure |
| Grant of loan license (per product category, up to 10 items) |
Rs. 10,000 per category |
| Additional category of cosmetic beyond the first 10 items |
Rs. 500 per additional category |
| Retention fee (payable before completion of 5 years from issue) |
As per Third Schedule; keeps a perpetual license active |
| Late retention fee (if paid within the 180-day grace window) |
2% per month on the retention fee |
Validity, Retention, and Renewal of a Cosmetic Loan License
Unlike many other regulatory licenses in India, a cosmetic loan license granted in Form COS-9 does not carry a fixed expiry date. Under the Cosmetics Rules, 2020, both the standard license (COS-8) and the loan license (COS-9) remain valid in perpetuity, subject to payment of a retention fee before the completion of every five-year period from the date of issue.
There is no traditional "renewal" filing — instead, the license holder pays a retention fee every 5 years to keep the license active.
If the retention fee is missed on the due date, it can still be paid within a 180-day grace period, along with a late fee of 2% per month.
If the retention fee remains unpaid even after the 180-day grace window, the license is deemed cancelled and manufacturing under it must stop.
Any change in the manufacturing arrangement — for example, switching to a different loan-license premises — requires a fresh intimation or application, since the license is tied to the specific borrowed facility.
Cosmetic Loan License Timeline at a Glance
| Stage |
Typical Timeframe |
| Document preparation & manufacturing agreement |
Varies by applicant readiness |
| COS-6 application review by State Licensing Authority |
Up to 45 days from submission |
| Response to deficiency memo (if raised) |
As specified in the query; prompt response avoids delay |
| COS-9 grant of license |
On satisfactory verification, within the 45-day window |
| Retention fee due |
Before completion of every 5 years from date of issue |
Why Choose Silvereye Certifications Getting Your Cosmetic Loan License Right the First Time
A cosmetic loan license is one of the most practical routes for brands entering India's skincare, haircare, and personal-care market without heavy upfront investment in manufacturing infrastructure. But the COS-6 to COS-9 process depends heavily on getting the manufacturing agreement, product categorisation, technical-person qualification, and Second Schedule documentation right from the first filing — since queries and deficiency memos are the most common cause of delay.
Silvereye Certifications assists brands end-to-end with cosmetic loan license registration — from structuring the manufacturing arrangement and verifying the borrowed premises' compliance, to preparing the COS-6 filing, responding to State Licensing Authority queries, and tracking the five-year retention cycle so your COS-9 license never lapses.
Next step Planning to manufacture your cosmetic brand through a third-party facility? Talk to Silvereye Certifications for a documentation review and end-to-end COS-6/COS-9 filing support before you submit your application.
Frequently Asked Questions: Cosmetic Loan License Registration
A cosmetic loan license is a manufacturing authorisation that lets a brand produce cosmetics at another company's already-licensed facility, instead of owning its own factory. It is applied for in Form COS-6 and granted in Form COS-9 under the Cosmetics Rules, 2020.
COS-6 is the application form you file with the State Licensing Authority. COS-9 is the certificate issued once that application is approved. You file COS-6; you receive COS-9.
Any brand or individual that wants to manufacture cosmetics for sale or distribution but does not own manufacturing premises can apply, provided they have a formal arrangement with a manufacturer whose facility meets Seventh Schedule GMP norms.
No. That is the entire purpose of the loan license route — you use another company's GMP-compliant, licensed premises under a manufacturing agreement, rather than setting up your own unit.
Key documents include the manufacturing agreement, constitution documents of the applicant, premises proof for the borrowed facility, approved layout and machinery list, product composition and labelling details, technical person credentials, the Form COS-7 self-declaration, and the fee receipt — all as specified in Part II of the Second Schedule.
The State Licensing Authority is expected to decide on a complete COS-6 application within 45 days, granting the license in Form COS-9 once all requirements are verified as met.
Fee schedules commonly cite around Rs. 10,000 per product category (covering up to 10 items) and Rs. 500 for each additional category, under the Third Schedule of the Cosmetics Rules, 2020. Since fee notifications can be revised, always confirm the current amount on the SUGAM portal or with your State Licensing Authority before payment.
No fixed expiry date applies. A COS-9 loan license remains valid in perpetuity, provided the retention fee is paid before completion of every five-year period from the date of issue.
You get a 180-day grace period to pay the retention fee along with a late fee of 2% per month. If it still isn't paid within that window, the license is deemed cancelled.
Yes, in most cases new categories or SKUs can be added through the applicable portal-based endorsement process on your existing COS-9 license, without needing to file a completely fresh COS-6 application — though the product must still be correctly mapped to its Fourth Schedule category.
