StartupGrants India

Drug & Cosmetic License (CDSCO)

Mandatory

Manufacturing, Sale, and Distribution Licenses Under the Drugs and Cosmetics Act 1940

Validity: 1-5 years (category-dependent)

What is Drug & Cosmetic License (CDSCO)?

Get your CDSCO or State Drug Control licence before manufacturing, selling, or importing drugs or cosmetics — covers pharma, Ayurvedic products, and devices.

The Drugs and Cosmetics Act 1940 is the primary legislation governing the manufacture, distribution, sale, and import of drugs and cosmetics in India. The Act is administered through a two-tier regulatory structure: the Central Drugs Standard Control Organisation (CDSCO), headed by the Drugs Controller General of India (DCGI), exercises jurisdiction over import licenses, new drug approvals, clinical trials, and standards-setting; while the State Drug Control Authorities (SDCAs), each headed by a State Drugs Controller, issue manufacturing and retail or wholesale distribution licenses within their respective states. Understanding which authority has jurisdiction over a particular activity is the first step in any licensing exercise. The Act draws a fundamental distinction between drugs and cosmetics. Drugs include all medicines for internal or external use in the diagnosis, treatment, mitigation, or prevention of disease in human beings or animals, including substances used in the manufacture of such medicines, and medical devices as defined under the Medical Devices Rules 2017. Cosmetics are articles intended to be rubbed, poured, sprinkled, or sprayed on, or introduced into, or otherwise applied to, the human body for the purpose of cleansing, beautifying, promoting attractiveness, or altering the appearance, excluding soap. Different schedules of the Act and Rules apply to different sub-categories of drugs, and the applicable schedule determines the minimum manufacturing area, qualified person requirements, equipment standards, and record-keeping obligations. For pharmaceutical manufacturers, the cornerstone requirement is Good Manufacturing Practice (GMP) compliance as prescribed in Schedule M of the Drugs and Cosmetics Rules 1945. Schedule M was substantially revised in 2023 and aligns Indian GMP standards more closely with World Health Organization (WHO) GMP norms. A manufacturing license (Form 25 for allopathic formulations, Form 28 for bulk drugs) is issued by the State Drugs Controller after an inspection of the manufacturing premises confirms Schedule M compliance. The qualified person requirement mandates that manufacturing operations be supervised by a competent technical staff member, who must hold a degree in pharmacy, medicine, science (with specific subjects), or an equivalent qualification as specified in Schedule M. Wholesale distribution licenses (Form 20-B for drugs, Form 21-B for restricted drugs) and retail sale licenses (Form 20 for drugs, Form 21 for prescription drugs) are issued by the State Drugs Controller for businesses that stock and sell drugs without manufacturing them. Retail chemists must additionally comply with the conditions prescribed in Schedule H (prescription-only drugs that can only be sold on a valid prescription), Schedule H1 (drugs requiring additional recording of prescription details), and Schedule X (habit-forming drugs subject to strict quantity controls and record-keeping). For cosmetics, a manufacturing license under Form 32 and a wholesale dealer's license under Form 42 are required. Imported cosmetics require an import license under Form 43, which is issued by CDSCO. Since 2023, cosmetic imports are required to comply with the Cosmetics Rules 2020, which align with ASEAN Cosmetic Directive standards and require listing on the SUGAM portal before import. Ayurvedic, Unani, and Siddha (ASU) drugs are regulated under Chapter IV-A of the Act and the Drugs and Cosmetics Rules applicable to ASU drugs, with licensing by the State Drugs Controller using distinct forms and with oversight in many states by a separate Ayurvedic Drug Controller. Common pitfalls include applying to the wrong authority (central versus state), failing to meet the minimum area requirements specified in Schedule M or the Cosmetics Rules before applying for inspection, employing a qualified person who does not meet the educational qualification criteria for the specific drug category being manufactured, and omitting to obtain a No Objection Certificate from the local municipal body and the Pollution Control Board before the drug authority inspection. Many businesses also underestimate the time required to obtain Good Manufacturing Practice certification from CDSCO, which is required for export and for demonstrating equivalence to overseas regulators. Professional assistance is essential because the drug licensing framework is complex, highly technical, and subject to frequent amendments. Our team includes regulatory affairs specialists who work directly with State Drug Controllers and CDSCO, ensuring that your application is complete, your premises meet inspection readiness standards, and your qualified person arrangements are legally correct before any inspector visits.

Who Needs Drug & Cosmetic License (CDSCO)?

Pharmaceutical manufacturers (formulations and bulk drugs), retail and wholesale chemists and druggists, hospitals operating in-house pharmacies, cosmetic manufacturers and importers, Ayurvedic and herbal product manufacturers, medical device manufacturers and importers, and nutraceutical companies whose products are classified as drugs under the Act must all obtain the appropriate license before commencing regulated activities.

What's Included

  • Legal authority to manufacture, sell, or distribute drugs and cosmetics in India
  • GMP certification enabling export to regulated markets
  • Eligibility for government procurement and public sector supply contracts
  • Compliance with Schedule M, Schedule H, and H1 requirements protecting against prosecution
  • Access to CDSCO's SUGAM portal for import and new drug approval filings
  • Prerequisite for listing on National Pharmaceutical Pricing Authority (NPPA) portals
  • Foundation for WHO-GMP certification required for export to 100+ countries

⚠️ Penalty for Non-Compliance

Manufacturing, selling, stocking, or distributing any drug or cosmetic without a valid license under the Drugs and Cosmetics Act 1940 is a cognisable offence under Section 27 of the Act. Penalties include imprisonment for a minimum of one year (extendable to three years for adulterated or spurious drugs) and a minimum fine of ₹5,000, with enhanced penalties up to imprisonment for life for drugs likely to cause death or grievous hurt. The Drugs Inspector has the authority to seize and detain goods, seal premises, and initiate prosecution without any prior notice.

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How It Works

  1. 1

    Regulatory scoping and license identification

    We identify the correct license forms and authorities based on your product category (allopathic drug, ASU drug, cosmetic, medical device), activity type (manufacture, wholesale, retail, import), and state of operation, and review your premises and qualified person arrangement against the applicable schedule requirements.

  2. 2

    Premises and infrastructure readiness assessment

    We conduct a pre-inspection review of your manufacturing or storage premises against Schedule M (for drug manufacturers) or the Cosmetics Rules (for cosmetic manufacturers) and provide a gap analysis report with specific remediation actions before the official inspection.

  3. 3

    Qualified person verification and documentation

    We verify that your proposed technical staff member meets the educational and experience criteria prescribed in Schedule M or the applicable rules for the specific drug category, and compile the supporting educational and experience documentation.

  4. 4

    Application compilation and filing

    We prepare the prescribed application form (Form 24, 25, 28, 32, or equivalent), compile all supporting documents, arrange for payment of the prescribed license fee, and file the application with the State Drugs Controller or CDSCO as appropriate.

  5. 5

    Inspection coordination and representation

    We coordinate the premises inspection by the Drug Inspector, accompany the inspection team, respond to any observations raised during the inspection, and submit the compliance report within the prescribed timeline.

  6. 6

    License receipt, renewal planning, and ongoing compliance

    Upon grant of the license we collect the license certificate, brief your team on record-keeping requirements under the applicable schedules, set up a renewal calendar, and advise on post-licensing obligations including adverse drug reaction reporting and recall procedures.

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Documents Required

Items marked Required are mandatory; others are situational.

Entity and Location Documents

  • Certificate of Incorporation, Partnership Deed, or proprietorship declarationRequired
  • PAN of the entity and all directors or partnersRequired
  • Proof of ownership or registered lease of premisesRequired
  • Site plan and layout drawings of premises (dimensioned)Required
  • Municipal NOC for use of premises as manufacturing or storage unitRequired
  • Pollution Control Board consent to establish and consent to operateRequired

    Required for drug manufacturers; confirm applicability for cosmetics

Technical and Qualified Person Documents

  • Degree certificate of Qualified Person (B.Pharm, M.Pharm, MBBS, or equivalent)Required
  • Experience certificate of Qualified Person from previous employer(s)Required
  • Full-time employment agreement with the Qualified PersonRequired
  • List of all drug or cosmetic products proposed to be manufactured or soldRequired

GMP and Infrastructure Compliance (Manufacturers)

  • Air handling unit (AHU) and HVAC specifications meeting Schedule M requirementsRequired
  • Water purification system (purified water or WFI as applicable) in placeRequired
  • Quality control laboratory with required instruments (or third-party QC arrangement)Required
  • Standard Operating Procedures (SOPs) drafted for key manufacturing steps

    Inspectors expect SOPs to be in draft or final form at the time of inspection

  • Equipment list with make, model, and capacity detailsRequired
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Fees & Pricing

Government Fees (Indicative — state-specific schedules apply)

Manufacturing license (Form 25 — allopathic formulations, per dosage form)

Varies by state and number of dosage forms; check state drug rules for exact schedule

₹3,500 – ₹25,000

Wholesale drug license (Form 20-B)

Annual or biennial depending on state; some states charge per category of drug

₹3,000 – ₹5,000

Retail drug license (Form 20 + Form 21)

Varies by state; dual forms required for both OTC and prescription drugs

₹600 – ₹3,000

Cosmetic manufacturing license (Form 32)

Per product category; state fee schedule applies

₹1,500 – ₹10,000

Cosmetic import license (Form 43, CDSCO)

CDSCO fee schedule; filed on SUGAM portal

₹1,000 per product

Professional Fees

End-to-end drug or cosmetic licensing (application, inspection, follow-up)

Quoted on review of your specific case

Varies

* Government fees may vary. GST applicable on professional fees. Final pricing confirmed after review.

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Frequently Asked Questions

What is the difference between a CDSCO license and a State Drug Authority license?

CDSCO (Central Drugs Standard Control Organisation), headed by the DCGI, issues import licenses for drugs and cosmetics under Form 10 and 43 respectively, grants approval for new drugs and clinical trials, certifies medical devices, and sets national standards. State Drug Control Authorities (SDCAs) issue manufacturing licenses (Form 25 for formulations, Form 28 for bulk drugs, Form 32 for cosmetics) and retail or wholesale distribution licenses (Forms 20, 20-B, 21, 21-B). Most businesses manufacturing or distributing in India deal primarily with the State Drugs Controller, while importers must engage with both CDSCO and the state authority.

What is Schedule M and why does it matter for a manufacturing license?

Schedule M of the Drugs and Cosmetics Rules 1945 prescribes the Good Manufacturing Practices (GMP) that all licensed drug manufacturers must follow. It sets minimum standards for building and premises (minimum floor areas, air handling, water systems), equipment, sanitation, quality control laboratories, documentation, and personnel qualifications. In 2023 the Government of India issued revised Schedule M requirements that align Indian standards with WHO GMP norms. A manufacturing license will not be granted until a Drug Inspector has conducted an inspection and confirmed that the premises and processes comply with the applicable Schedule M requirements. Non-compliance after licensing can result in suspension or cancellation.

Who qualifies as a competent technical person (Qualified Person) for a drug manufacturing license?

Schedule M prescribes different qualification requirements depending on the category of drugs to be manufactured. For allopathic formulations the competent technical staff must hold a degree in pharmacy (B.Pharm), medicine (MBBS), science with chemistry or microbiology as a major subject, or an equivalent qualification, along with prescribed experience in drug manufacturing. For bulk drugs (APIs), a degree in pharmacy, chemical technology, or science with chemistry, plus experience, is required. The individual must be employed full-time at the manufacturing site and must not simultaneously be the qualified person for any other manufacturing license. Their credentials must be verified and supported by notarised copies of degree certificates during the inspection.

Is a drug license required to sell Ayurvedic or herbal products?

Yes, if the product is classified as an Ayurvedic, Unani, or Siddha (ASU) drug under Chapter IV-A of the Drugs and Cosmetics Act 1940. Products marketed with therapeutic or preventive claims are regulated as drugs regardless of whether they contain herbal or natural ingredients. A manufacturing license from the State Drug Authority under the ASU rules is required for manufacturers, and wholesale and retail distribution licenses are required for distributors and retailers. Products sold purely as food supplements without any therapeutic claims may instead fall under the Food Safety and Standards Authority of India (FSSAI) regime, but any therapeutic claim automatically triggers the Drugs and Cosmetics Act classification.

What is the license requirement for importing cosmetics into India?

Cosmetics imported into India require an import license under Form 43 issued by CDSCO. The application is filed on the SUGAM portal along with product details, the foreign manufacturer's GMP certificate, the Certificate of Analysis, and the formula or ingredient list. Since the Cosmetics Rules 2020 came into force, all imported cosmetics must comply with labelling requirements including the batch number, date of manufacture, best-before date, full ingredient list in INCI nomenclature, and the name and address of the Indian importer. Prohibited and restricted ingredients prescribed in the Second Schedule to the Cosmetics Rules must be checked before import. The import license is product-specific and must be obtained for each distinct cosmetic product.

How often does a drug manufacturing license need to be renewed?

Drug manufacturing licenses issued under Form 25 (allopathic formulations) are typically valid for five years from the date of issue and require renewal before expiry by filing Form 26 along with the renewal fee. Wholesale and retail drug licenses (Forms 20, 20-B, 21, 21-B) are generally valid for one year or five years depending on the state's rules and are renewed by filing the prescribed renewal application. Some state authorities issue licenses on a perpetual basis subject to annual renewal fees. Operating on an expired license, even during a pending renewal application, is an offence under the Act and should be avoided by filing the renewal application at least 60 days before expiry.

Can a licensed drug manufacturer add a new product without applying for a fresh license?

Adding a new product to an existing manufacturing license generally requires the manufacturer to apply to the State Drugs Controller for an amendment or endorsement of the existing license to include the new product. For most allopathic formulations, the new product must be notified and the license amended before manufacturing commences. For products that fall within the same pharmacopoeial category already covered by the license, a simpler endorsement procedure may apply. New drugs, as defined under the New Drugs and Clinical Trials Rules 2019, require separate approval from CDSCO before they can be manufactured under any license. The specific procedure depends on whether the product is a new drug, an already approved drug in a new dosage form, or a new combination.

What records must a licensed drug retailer (chemist) maintain?

A licensed retail chemist must maintain a Prescription Register recording the details of each dispensed Schedule H and H1 drug including the date, name and address of patient, prescribing doctor's name and registration number, drug name, quantity dispensed, and batch number. For Schedule X (habit-forming) drugs, a separate register with purchase and sale entries must be maintained and submitted to the Drug Inspector periodically. Invoices for all purchases and sales must be retained for a minimum of three years. The license certificate must be displayed prominently in the shop. A retail pharmacy must have a registered pharmacist present during all hours of operation.

What is the consequence of selling a drug without a valid Schedule H prescription?

Dispensing a Schedule H drug (which includes antibiotics, anti-infectives, hormones, and many other categories) without a valid prescription is an offence under Rule 65 of the Drugs and Cosmetics Rules 1945. The first offence attracts cancellation or suspension of the retail drug license and a fine. Repeated offences result in criminal prosecution under Section 27 of the Act with imprisonment of up to one year and a fine. Beyond personal liability, the licensed pharmacist present at the time of sale is also individually liable as the competent person responsible for the pharmacy's compliance. Drug Inspectors frequently conduct test purchase operations to detect over-the-counter sale of scheduled drugs.

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Drug & Cosmetic License (CDSCO)

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