Understanding labelling when Importing Cosmetics into India
Authorized cosmetic testing labs ensure manufactures make safe products especially since safety of cosmetics is a key regulatory aspect. Since all countries have differing cosmetic regulations it is important to understand the important points when importing cosmetics into India as the labels need to match the Indian the standards as prescribed in the Drugs and Cosmetics Act 1940 and Rules 1945.Besides labels two other important aspects cosmetic importers need to keep in mind are that all manufacturers or importers have to now submit a one-time undertaking that the imported cosmetics have not been tested on animals. Secondly bulk importers have to either provide a Free Sale Certificate or get their bulk cosmetics tested in a government or an approved cosmetic testing lab to get custom clearance.
Labels are one of the most important regulatory aspects because they provide the necessary information to consumers and to regulators that there is no risk in the use of these imported cosmetics.The Central Drugs Standard Control Organization (CDSCO) is the Authority for discharging functions assigned under the Drugs and Cosmetics Act. The CDSCO has legislated that “nocosmetic shall be imported into India unless the product is registered under these Rules (1945) by the licensing authority appointed by Central government”. Accordingly
- Premarket approval is required under state government licensing
- Food Labelling needs to comply with part XV ofD&C rules 1945
- Expiry of product is to be indicated as “Use before date” which is different from that of other countries
- Name of the cosmetic and name of manufacturer and manufacturing address needs to be mentioned both on the inner and outer packaging labels. For small size containers place of manufacture and pin-code are sufficient
- The label on the outside should contain the amount of net contents ofingredients in order of content’s percentage.
- The year and month of packing prior to import are to be mentioned
- The inside label must contain directions for safe use and warnings about any ingredients that are hazardous or poisonous in nature
- The label will have a distinctive batch number indicated by the letter “B”. For soapsthe month and year of manufacture shall be given instead of “B”. This is not applicable to cosmetics which have contents that weigh 10grams or less for solids or semi-solids and 25ml or less for liquid products
- The letter “M” indicates the manufacturing license number
- Cosmetic product labels must mention the MRP
The information on the inner and outer labels differs as the outer label declares total net contents while the inner label carries detailed information about the ingredients and use so consumers are well informed. Inner label therefore must have
- usage directions
- cautions and warnings
- any special directions for use
Most countries have similar labelling requirement. However, the labelling requirements for import of cosmetics products into India must be studied thoroughly so as not to make any mistake about Indian import regulations. Importers must also understand that only those products that are safe for the consumer must be imported.